2017 SUPPLIER DIVERSITY REPORT - PUC · 2017 supplier diversity report filed on behalf of...

2017 SUPPLIER DIVERSITY REPORT

MINORITY / WOMAN / DISABLED BUSINESS ENTERPRISE

PROCUREMENT EFFORTS

On behalf of:

PENNSYLVANIA POWER COMPANY (Penn Power), METROPOLITAN EDISON COMPANY (Met-Ed),

PENNSYLVANIA ELECTRIC COMPANY (Penelec) and WEST PENN POWER COMPANY (West Penn Power)

Prepared by: Valerie Shearer FirstEnergy Supply Chain

TABLE OF CONTENTS

M/W/DBE PROCUREMENT EFFORTS

1. INTERNAL EFFORTS

1.1 Corporate Commitment and Policy 1.2 Training 1.3 2017 Supplier Diversity Program 1.4 2018 Goals and Objectives

2. EXTERNAL EFFORTS

2.1 Activities and Outreach Programs 2.2 Community Outreach / Professional Development 2.3 Awards/Recognition

3. SUBCONTRACTING EFFORTS

3.1 Second-Tiering Opportunities

4. DIVERSITY REPORTS

4.1 Utility Procurement Diversity Report

4.2 Procurement Data for Protected Classes Categorized

by Minority, Female and Physically Challenged

4.3 Supplier Diversity Activity by Material Group Code by Product and Service

5. CONCLUSION

FIRSTENERGY CORP. 2017 SUPPLIER DIVERSITY REPORT

filed on behalf of PENNSYLVANIA POWER COMPANY (Penn Power),

METROPOLITAN EDISON COMPANY (Met-Ed), PENNSYLVANIA ELECTRIC COMPANY (Penelec) and

WEST PENN POWER COMPANY (West Penn Power)

MINORITY/WOMAN/DISABLED BUSINESS ENTERPRISE (M/W/DBE) PROCUREMENT EFFORTS

1. INTERNAL EFFORTS

1.1 CORPORATE COMMITMENT AND POLICY

This report is being provided to the Pennsylvania Public Utility Commission on behalf of Pennsylvania Power Company (Penn Power), Metropolitan Edison Company (Met-Ed), Pennsylvania Electric Company (Penelec) and West Penn Power Company (West Penn Power) as wholly owned subsidiaries of FirstEnergy Corp. (“FirstEnergy”). At this time, FirstEnergy cannot segregate purchases intended strictly for these companies, therefore the narrative and statistical information provided herein is representative of our 2017 FirstEnergy companies and includes purchases made on a company-wide basis including FirstEnergy’s Energy Delivery, Fossil Generation and Nuclear business segments. As operating companies of FirstEnergy, Penn Power, Met-Ed, Penelec and West Penn Power remain committed to providing opportunities for minority, woman and disabled business enterprises. Diversity initiatives are integrated at FirstEnergy in its strategic vision and core values were communicated to all employees by Charles Jones, President & CEO FirstEnergy.

In 2017, FirstEnergy continued to enhance the activities of the Executive Diversity & Inclusion Council who provide oversight and guidance for the development of FirstEnergy’s overall integrated diversity strategy. Additionally, Supply Chain leveraged its internal Supplier Diversity Council, meeting with the Executive Diversity & Inclusion Lead and discussing ways to identify new areas to grow our portfolio of viable, competitive minority, women owned and disabled businesses. Supplier Diversity is a major component of Supply Chain’s business objectives and long-range strategies. FirstEnergy is committed to core values that are fundamental to achieving our vision to provide superior value to our customers and investors. Diversity is a core value inherent to all of our business operations. Supporting diversity is an essential element to locating sources of materials and services, selecting suppliers and managing supplier and contractor relationships. Diversity provides real business opportunities to traditionally underused suppliers. In 2017 our Supplier Diversity Program at FirstEnergy was led by Trent A. Smith - Vice President & Chief Procurement Officer and Joseph Loboda - Director, Supply Chain Support Services. FirstEnergy has a dedicated Supplier Diversity Coordinator (Torey Tolson) who reports to Valerie Shearer - Manager Planning & Supplier Diversity. Our Supplier Diversity Team provides full time guidance and assistance to Supply Chain

leadership in developing our supplier diversity program overview, direction, and goal setting. The Team oversees preparation of reports to management and those organizations, including federal and state governmental agencies that have a need to know FirstEnergy’s program achievements. The Team is responsible for the day-to-day administration of the Supplier Diversity Program. The Team attends staff meetings, shares information with Supply Chain buyers, introduces new suppliers, provides training and program orientation, reviews goal attainments, and solicits feedback from FirstEnergy personnel for help in identifying suppliers for future sourcing opportunities. In 2017, we continued to align our Supplier Diversity efforts with those of Supply Chain by reviewing our internal processes, external obligations, corporate culture, data management, reporting responsibilities and overall company position and philosophy on diversity at FirstEnergy.

1.2 TRAINING

In 2017, Supply Chain buyers received additional training updates on FirstEnergy’s supplier diversity program during sessions held for each of our sourcing areas. Training sessions were also conducted with several suppliers to further educate them on our diversity goals and how they can support them. Additionally, Supply Chain Management was invited to meetings with executive leadership to bring awareness of our diversity goals and initiatives and how their support contributes to the achievement of these goals.

1.3 2017 SUPPLIER DIVERSITY PROGRAM

FirstEnergy provides no premiums or set-asides for purchases from diverse suppliers. The intent is to ensure fair and equitable consideration is extended to all suppliers for the contracting of goods and services. Diverse businesses (minority, woman and disabled businesses enterprises) are among those suppliers we depend on to provide FirstEnergy with the best products and services for the best value.

FirstEnergy’s supplier diversity initiatives are designed to meet federal and state regulatory programming and certification reporting requirements. Business owners seeking to be designated as a diverse supplier in Pennsylvania must meet one of the following definitions:

MINORITY BUSINESS A minority owned business (MBE) as defined by the National Minority Supplier Development Council, Inc., must be at least 51% owned by one or more minority U.S. citizen. One or more such individuals must control its management and daily operation. In the case of a publicly owned business, one or more such individuals must own at least 51% of the stock. The minority owner(s) must be an U.S. citizen whose origins are:

Asian-Indian - from India, Pakistan and Bangladesh

Asian-Pacific - from Japan, China, Taiwan, Korea, Vietnam, Laos,

Cambodia, the Philippines, Samoa, Guam, the U.S. Trust Territories of the Pacific or the Northern Marianas.

Black - from any Black racial groups of Africa.

Hispanic - of true-born Hispanic heritage, from any of the Spanish-speaking areas of Latin America or the following regions: Mexico, Central America, South America and the Caribbean Basin only.

Native American- American Indian, Eskimo, Aleut or Native Hawaiian,

and regarded as such by the community of which the person claims to be a part. Native Americans must be documented members of a North American tribe, band or organized group of native people who are indigenous to the continental United States and proof can be provided by a Native American Blood Degree Certificate (i.e. tribal registry letter, tribal roll register number).

WOMEN-OWNED BUSINESS (WBE) A woman-owned business as defined by the U.S. Small Business Administration (FAR 52.219-1) is one that is at least 51% owned by one or more women; or in the case of any publicly owned business, at least 51% of the stock is owned by one or more women; and whose management and daily business operations are controlled by one or more such individuals. SERVICE-DISABLED VETERAN-OWNED SMALL BUSINESS (SDV) A service-disabled veteran-owned small business concern is a small business that is at least 51% owned by one or more service-disabled veterans. In the case of a publicly owned business, at least 51% of the stock is owned by one or more service-disabled veterans; and whose management and daily business operations are controlled by one or more such individuals. A service-disabled veteran is a veteran, as defined in 38 U.S.C. 101(2), with a disability that is service connected, as defined in 38 U.S.C. 101(16). DISABLED BUSINESS ENTERPRISE (DBE) A disabled business enterprise must be at least 51% owned by a person or group of persons with a disability as recognized by the Americans with Disabilities Act or as defined by the Commonwealth of Pennsylvania, Governor’s Office, Management Directive 205.25 amended April 15, 1994, or a publicly owned business with 51% of its stock owned by one or more persons with disabilities. One or more persons with disabilities must control the management and daily business operations.

For suppliers to participate in FirstEnergy’s Supplier Diversity Program, they need to register their company profiles electronically by going to www.firstenergycorp.com and completing the Supplier Registration form.

1.4 GOALS

Each year, our Supplier Diversity goals are developed by obtaining the corporate budgeted dollar figures for FirstEnergy’s Operation & Maintenance and Capital Improvement Projects and reviewing these figures with Senior Leadership to determine the trends in FirstEnergy’s corporate infrastructure cost spending for the new year.

http://www.firstenergycorp.com/

2017 ATTAINMENT

2018 GOALS

In 2018, we will strive to meet the following goals by continuing our memberships in supplier diversity advocacy organizations, participating in diversity related matchmakers and trade fairs, mentoring suppliers, and promoting the supplier diversity program to non-Supply Chain key requisitioners.

The principal products and services planned to be bid with Minority, Woman-Owned and Disabled Business Enterprises are as follows:

Products and Services:

2. EXTERNAL EFFORTS

2.1 ACTIVITIES AND OUTREACH PROGRAMS

Business Classification Goal %Attainment

%Total $

Total Dollars spend across FirstEnergy $2,971,317,227

Minority Business (MBE) 2.50% 2.05% $60,994,429

Woman-Owned Business (WBE) 2.50% 4.28% $127,065,008

Disabled Owned Business 0.05% 0.23% $6,818,047

Total Expenditures 5.05% 6.56% $194,877,485

2017 Expenditure Goals and Results Actual Expenditures

2018 Business Classification Goals Goal %

Minority Business (M/WBE) 2.50%

Woman-Owned Business (WBE) 2.50%

Disabled Owned Business 0.05%

Analytical/Testing Services Instruments Real EstateBuilding Materials IT Hardware/Software Regulatory ServicesCommunications Janitorial Rentals Construction Lab Supplies/Equipment Safety EquipmentConsultant/Technical Services Leases Service MetersConsumables Licenses StaffingCorporate Services Lighting Structures/PolesElectrical MRO (Maintenance/Overhaul/Repair) Technical ServicesElectronic System Installation Mechanical ToolsEngineering Mechanical Construction TransformersGeneral Utility Equipment Office Supplies/Equipment Utility ServicesInspections Protective Equipment Vehicles

In 2017, FirstEnergy continued to actively support Pennsylvania based supplier diversity initiatives through participation in various diversity events and advocacy organizations.

AFFILIATIONS/MEMBERSHIPS:

Pennsylvania - Women’s Business Enterprise Council of PA-DE-sNJ Eastern Minority Supplier Development Council

FirstEnergy also partnered with the following national, federal and state organizations:

National - Edison Electric Institute Supplier Diversity Task Force Committee U.S. Small Business Administration

U.S. General Services Administration

New Jersey - New Jersey Board of Public Utilities Supplier Diversity Development Council African American Chamber of Commerce – NJ New Jersey Statewide Hispanic Chamber of Commerce

Ohio - Public Utility Commission of Ohio – Ohio Gate Council

Ohio Minority Supplier Development Council Black Pages of Ohio NAACP - Cleveland

Maryland - Public Service Commission of Maryland – Forum Council

Maryland Washington Minority Companies Association Capital Region Minority Supplier Development

FirstEnergy personnel serve as a committee member and/or officer with the following organizations:

• Committee Member - Public Utility Commission of Ohio’s – Ohio Gate Council • Committee Member - New Jersey Board of Public Utility Supplier Diversity

Development Council • Secretary – Public Service Commission of Maryland Forum Council

SOURCING DATABASES UTILIZED AT FIRSTENERGY

FirstEnergy utilizes its own supplier registration database to identify qualified diverse suppliers for inclusion on bid solicitations and references to the following membership directories specifically targeted to diverse businesses:

National Minority Supplier Development Council – NMSDC Central VETBIZ.com WBENCLink

Pennsylvania Dept. of General Services – MBE/WBE Database State of Ohio MBE Search MDOT – Maryland Department of Transportation

ADVERTISING

FirstEnergy demonstrated its support in the minority community by advertising in the following minority or women-owned publications:

Black Pages of Ohio The Summit Magazine Edison Electric Institute Supplier Diversity Conference Business Journal Eastern Minority Supplier Development Council Business Journal Maryland Washington Minority Companies Association Brochure

2.2 COMMUNITY OUTREACH / PROFESSIONAL DEVELOPMENT

FirstEnergy’s goal is to make it easier for diverse businesses to partner with us. Our commitment to developing minority and women owned businesses is key to why we join organizations such as the local affiliates of the National Minority Supplier Development Council Inc. and the Women’s Business Enterprise Council of PA-DE-sNJ and others listed in 2.1.

FirstEnergy staff members have developed working relationships with various Small Business Development Centers and FirstEnergy Economic Development staff throughout our service territory and have enlisted them to assist us in promoting the growth and success of diverse businesses. We meet with Area Managers/Regional Presidents to share our diversity initiatives and to offer assistance in working with the diverse businesses in their region. Goals and key initiatives have been developed to build sustainable growth in our supplier diversity initiatives. Our business practice is to mentor and assist all diverse business owners seeking to do business with FirstEnergy. We facilitate one-on-one appointments for those diverse suppliers that match our procurement requirements. And we have taken advantage of various opportunities throughout the year to speak at events that allowed us to share our program’s message with potential suppliers and our Prime Contractors. A key driver to advancing supplier diversity at FirstEnergy is the Supply Chain link on FirstEnergy’s website http://www.firstenergycorp.com/supplychain/index.html.

2.3 AWARDS / RECOGNITION

FirstEnergy’s on-going commitment to Supplier Diversity and the communities we serve has resulted in the following program awards and recognition:

• Military Friendly Employer to recognize FirstEnergy’s commitment to members

of the military. • WBEC Regional Corporation Done Deals Award recognized FirstEnergy for

having the highest number of deals and spend with certified women business enterprises within the region of Pennsylvania, Delaware and southern New Jersey.

3. SUBCONTRACTING EFFORTS

3.1 SECOND TIERING OPPORTUNIITES

The total dollars subcontracted for 2017 are as follows:

Our 2nd Tier Reporting Program was implemented to enhance, not replace, our own efforts to increase meaningful opportunities for minority, women and disabled business enterprises that do not have the capacity to supply FirstEnergy directly. In 2017 we continued to ask large prime

Prime Contractor Scope of Work Direct Indirect Direct Indirect

ABB Incorporated Electrical Equipment $19,353 $1,611,925 $1,631,278Altec Industries Incorporated Cranes and Trucks $3,730 $82,890 $6,666 $93,285American Electrical Testing Co Electrical Contractor $325 $29,954 $30,279Arbormetrics Solutions Incorporated Vegatation Management $37,058 $37,058ARCA Recycling Energy Efficiency Program $52,787 $6,313 $2,596 $61,696Ardmore Logistics Freight Management $13,065 $13,065Asplundh Tree Expert Company Line Clearing/Tree Service $4,621,939 $169,369 $8,534,050 $13,325,358Aubrey Silvey Enterprises Substation Maintenance $4,353,616 $4,353,616Burns & McDonnell Engineering Firm/Consultants $1,034 $1,034C W Wright Construction Company Electrical Transmission Lines $18,578 $48,889 $67,467Eaton Distribution Transformers $6,677 $189,485 $122,507 $318,669Fastenal Fastener Distributor $1,119 $7,709 $376 $1,495 $975 $11,674Fwt, LLC Steel Pole Manufacturing $19,454 $77,751 $97,205General Cable Wire and Cable Manufacturer $225 $10,726 $12,183 $23,135Hewlett Packard IT Computer Components $27,604 $17,843 $45,447Honeywell International Inc Energy Efficiency Program $52,656 $52,656Hubbell Power Systems Pole Line Hardware $22,542 $386 $1,625 $24,553ICF Resources LLC Energy Efficiency Program $786,900 $786,900J W Didado Electric LLC Misc Electrical Work $40,195 $1,757,545 $147,625 $1,945,366Lewis Tree Vegatation Management $587 $11,938 $6,112 $18,638Marmon Wire and Cable Inc Wire and Cable Installer $55,838 $55,838McFarland Cascade Pole and Lumber Company $81,219 $797,907 $1,110,522 $1,989,648McGinley Maintenance Incorporated Janitorial/Custodial Services $1,711 $1,711Navigant Consulting Incorporated Energy Efficiency Program $32,060 $32,060Office Depot Office Suppliers $8,490 $17,074 $25,564Opower Incorporated Energy Efficiency Program $16,325 $16,325Osmose Utilities Services Inc T&D Inspection/Maintenance $186,733 $59,205 $245,938Pontoon Managed Service Provider $118,453 $1,860,461 $3,367,634 $5,346,548Power Line Supply Company Power Line Tools $48,206 $405,350 $453,556Professional Electric Products Co Wholesale Electrical Supply $190,443 $95,160 $285,603Prysmian Power Cables & Systems Telecom Cable and Systems $2 $25,486 $25,488New River Electrical Engineering Services $57 $1,252 $1,309Realtime Utility Engineers Engineering Firm $12,000 $12,000Siemens Industry Incorporated Pwr Plant Turbines & Generators $213,507 $213,507Sodexo Operations LLC Energy Efficiency Program $16,669 $560,620 $447,066 $1,024,355Southwire Electrical Wire & Cable $32 $17,188 $983 $38,057 $56,259The Goodyear Tire & Rubber Company Tires for Fleet Vehicles $9,460 $7,842 $17,302Trees Inc Vegatation Management $38,955 $46,792 $85,747TRC Engineers Oil & Gas Infrastructure Firm $950,576 $950,576USIC Locating Services Incorporated Underground Services $24,595 $132,561 $157,156Wright Tree Vegatation Management $6,380 $33,728 $36,468 $186,079 $262,655

Total Direct & Indirect: $460,274 $7,296,611 $7,502,969 $6,496,377 $12,441,290 $34,197,522

2017 Tier 2 Spend Report Phy. Challenged

Minority Women Combined Total

suppliers meeting the SBA’s dollar threshold of $700,000 for products and services and $1.5M for construction to share similar values regarding utilization of small diverse businesses, especially when fulfilling our work requirements. As part of our 2nd Tier Reporting Program we encourage suppliers to establish a Supplier Diversity Program similar to ours. A 2nd Tier Policy statement and web link are posted on our external website: https://www.firstenergycorp.com/supplychain/supplier_diversity/tier_ii_reporting.html FirstEnergy’s E-Sourcing tool, Request for Proposal, and Request for Quotations contain language incorporating the Federal Acquisition Regulation (FAR) flow down provisions. In addition, we have incorporated the following statement in our Terms & Conditions, Rev. 26 - Compliance with Laws, Regulations & Permits section: “If this Agreement is a subcontract under a government contract or a federally-funded project, Supplier shall comply with subcontractor flow down requirements under the Federal Acquisition Regulations (48 CFR Chapter 1), as amended from time to time, which are specified in supplemental terms to this Agreement."

Large Prime Suppliers meeting the dollar threshold for 2nd Tier reporting will be requested to submit a Plan as required in FAR 52.219-9. And these same large suppliers are asked to share similar values regarding utilization of diverse businesses, especially when fulfilling work requirements on behalf of FirstEnergy.

4. DIVERSITY REPORTS

4.1 Utility Procurement Diversity Report

NOTES:

• MBE - Minority includes male and female non-Caucasian owned businesses • WBE - Women includes only Caucasian women-owned businesses • DBE - 1) Disabled as defined by the Americans with Disabilities Act. Can also include agencies that employ 51% or more disabled persons, i.e. vocational rehabilitation agency or school for the blind

2) Service Disabled Veteran spend is included in the DBE total. • The Minority & Women supplier dollars are not doubled counted - race is

counted over gender.

Business Classification Goal %Attainment

%Total $

Total Dollars spend across FirstEnergy $2,971,317,227

Minority Business (MBE) 2.50% 2.05% $60,994,429

Woman-Owned Business (WBE) 2.50% 4.28% $127,065,008

Disabled Owned Business 0.05% 0.23% $6,818,047

Total Expenditures 5.05% 6.56% $194,877,485

2017 Expenditure Goals and Results Actual Expenditures

4.2 - Procurement Data for Protected Classes Categorized by Minority, Female and Disabled Business Enterprises

Goods / Services Commodity Description DBE MBE WBE Goods /

Services Commodity Description DBE MBE WBE

Goods Actuators and Parts X X X Goods Engines and Parts X

Goods Air Quality Control X Goods Fabrication X X

Goods Ash Hdlg Equip/Parts X Goods Fans and Parts X X X

Goods Battery -General Use X Goods Fasteners & Hardware X

Goods Battery-Operational X X Goods Fencing and Parts X

Goods Blowers and Parts X Goods Filters X X

Goods Boilers & Parts X X Goods Fire Protection Part X X X

Goods Burners & Parts X Goods Fleet Veh/Equip X X X

Goods Cable Tray & Parts X Goods Fleet-Misc Supply X X X

Goods Capacitor and Parts X Goods ForeignMatl Ex Items X X

Goods Chart Paper/Pens X Goods Fuses X X

Goods Chemicals X X Goods Gasket-Seal- Packing X X X

Goods Cleaning Supplies X X X Goods Heat Exch / Coolers X X X

Goods Coal Crusher & Parts X Goods Heaters and Parts X

Goods Coal Handling Syst X X X Goods HVAC and Parts X X

Goods Compressor and Parts X Goods I&C Compon. & Parts X X X

Goods Computer Hrdwr Non T X X Goods IdentificationSupply X

Goods Computer Hrdwr Trk X X Goods Industrial Gases X X

Goods Computer Sftwr - M&S X X Goods Insulation & Items X

Goods Computer Sftwr-NonTk X X X Goods Insulators-Bushings X

Goods Computer Sftwr-Tk X X Goods Laboratory Supplies X

Goods Condenser and Parts X Goods Lamps & Fixtures X X X

Goods Conduit & Fittings X X Goods Lawn & Garden Equip X X

Goods Construct/Bldg Matl X X Goods Lifting Equip/Items X X

Goods Containers & Items X X Goods Measuring Equipment X X

Goods Cooling Tower & Parts X Goods Mech-Miscellaneous X

Goods Crossarms & Braces X Goods Meter-XFMR-Curr-Volt X

Goods Cutouts and Switches X X X Goods Meter-1 PH & 3PH X X

Goods Dampers and Parts X Goods Meter-Service Access X

Goods Demineralizer/Parts X Goods Misc-Environmental X

Goods Doors and Parts X Goods Misc-Miscellaneous X

Goods Electronic Devices X X X Goods Motors-Gens-MG Sets X X X

Goods Elevators & Parts X Goods Network X



Goods Network-Trackable X Goods Transformer-NON Dist X

Goods Office Furniture X Goods Tubing-Hoses-Fitting X

Goods Office Paper X Goods Turbine/Gen.Equip X X

Goods Office-Print Supply X Goods Underground Equip X X

Goods Office Supplies X X Goods Valves and Parts X X X

Goods Oils and Lubricants X X Goods Vehicle Parts & Sup X X X

Goods Paint and Supplies X Goods Welding Supply X X

Goods Piping-Fittings-Hger X X X Goods Wire and Cable X X X

Goods Plastic and Glass X Goods Wire Device & Parts X

Goods Plumbing Fixtures X X X Services Boiler Ash Hdl Maint X X X

Goods Poline Hardware X Services Cafeteria Services X

Goods Power Trans-Bearings X X Services Calibration Services X

Goods Promotional/Ad Matl X X Services Chimney/Enviro Maint X X

Goods Pulverizer & Parts X Services Coal/Conveyer Equip X X

Goods Pump & Parts X X X Services Communication Srvcs X X

Goods Rad Monitor/DetEquip X Services Consulting Services X X X

Goods Rad Protection Suppl X Services Cooling Tower Maint X

Goods Railroad Equip/Parts X Services Customer Operations X X

Goods Reactor Equip/Parts X X Services Customer Program X X

Goods Reclosurer Electrical X Services Distribution Service X X

Goods Regulator-Mechanical X Services Door & Window X

Goods Regulator-Voltage X Services DSM Residential Prog X

Goods Relays X X Services Electrical X

Goods Safety Supplies& PPE X X X Services Eng/Architect Serv X X X

Goods Security Equipment X X X Services Equip Lease & Rental X X X

Goods Soot Blower and Parts X Services Fac Constr/Maint X X X

Goods Strainers & Traps X X Services Facility Lease/Rent X

Goods Street Lights & Parts X Services Fee-Cert of Matl X

Goods Structural Metals X Services Fees-Expediting X

Goods Substation/Equip/Com X X Services Fencing X

Goods Substation Misc X Services Finance X

Goods Surge Arrester & Parts X Services Fire Protection Serv X

Goods Swtchg-Brkrs-Swtch X X X Services FIXED-General Contra X

Goods T & D Pole & Tower X X Services Flagging Services X

Goods Tanks and Parts X X Services Fleet Vehicle Serv X X

Goods Telecom/NetworkParts X X X Services Floormat & Towel X

Goods Tools X X Services Food & Catering Service X X

Goods Transformer -Distrib X X Services General Contractor X X

4.3 2017 Spend with Pennsylvania MBE-WBE-DBE’s



Services HR-Benefit Administration X Services Pump Repair Service X

Services HR-Employee Medical X X Services Refurbishment Serv X

Services HR-Recruiting Srvc X Services Roofing Services X X X

Services Hazardous Waste Serv X Services Security Services X X

Services Hydro Plnt Service X X Services Snow Removal Service X X X

Services HVAC Services X Services Staff Augmentation X X X

Services Inspect & Test Serv X X X Services Storm Restoration X X

Services Insulation Srvcs X Services Substation Services X X

Services IT Hosted Services X Services T&E-Environmental X

Services IT - Software Dvlp X X Services T&E-Underground X

Services IT Services X Services Telecom/Network Serv X X

Services IT-System Instr X X X Services Tool Repair Services X X

Services Janitorial Services X X Services Training Services X X X

Services Landscaping Services X X Services Transportation Srvc X

Services Motor Repair Service X Services Transmission Serv X X

Services Nuc Bal of Plnt Serv X X Services Turbine&Condens Serv X X X

Services Office Equip Maint X X Services Underground Services X X

Services Painting X Services Valve Repair Service X X

Services Paving/Roadwork X X Services Veg Management Serv X

Services Plant Mechanical Gen X Services Waste Disp - NON-HAZ X X

Services Public Relations/Adv X Services Water Treatment Serv X X

Services Public Relations X

PENNSYLVANIA MINORITY BASED VENDORS DOING BUSINESS AS ST MINORITY INDICATOR DESCRIPTION TOTAL SPEND

IMAGETECH SYSTEMS INCORPORATED PA Asian-Indian Male SB 10,533.00$ INDOGEM INCORPORATED DBA GEMS SAFETY PRODUCTS PA Asian-Indian Male SB 52,565.50$ PENNSYLVANIA TRANSFORMER TECHNOLOGY INCORPORATED PA Asian-Indian Male SB-CERT 1,638,527.52$ TESTEX INCORPORATED PA Asian-Indian Male SB-CERT 108,025.00$ BUDD SCALE SERVICE & SALES PA Asian-Indian Woman SB 1,700.00$ BALDAUF AUTO BODY INCORPORATED PA Asian-Pacific Male SB 224.00$ SOURCEPRO INC PA Asian-Pacific Male SB-CERT 50.22$ APEX CONTROLS CORP PA Asian-Pacific Woman SB 1,049.60$ SSM INDUSTRIES INCORPORATED PA Black Male SB 9,234.30$ RIVER CITY FURNITURE LLC DBA RCF GROUP PA Black Male SB-CERT 12,751.77$ BOB FERRANDO FORD LINCOLN MERCURY PA Hispanic Male LB 17,216.70$ JOHN ANDERSON CONSTRUCTION INC PA Hispanic Male LB 3,933.12$ CREATIVE IMPRINT SYSTEMS INC PA Hispanic Male SB 5,844.11$ EM UTILITY CONTRACTORS LLC PA Hispanic Male SB 1,550,394.38$ GREGORY CARCHIDI DBA G & P CUSTOM SERVICE PA Hispanic Male SB 17,408.62$ HERRING TRUCK PARTS PA Hispanic Male SB 2,295.71$ JOHN W MARCINCAVAGE DBA H & M LAWN & TREE SERVICE PA Hispanic Male SB 20,506.80$ FERRANTES LAKEVIEW INC PA Hispanic Woman SB 1,000.00$ ENGLES BODY SHOP INCORPORATED PA Native Am Male SB 4,056.51$ FAYETTE PARTS SERVICE INCORPORATED DBA STANDARD AUTO SUPPLY PA Native Am Male SB 1,174.21$ INDIANA AUTO SUPPLY INCORPORATED PA Native Am Male SB 2,468.26$ MATTHEW K STOLTZFUS DBA MATT'S EXCAVATING PA Native Am Male SB 15,122.54$

PENNSYLVANIA MINORITY BASED VENDORS DOING BUSINESS AS ST MINORITY INDICATOR DESCRIPTION TOTAL SPENDR J SELLS BODY SHOP DBA R J SELLS TOWING & RECOVERY PA Native Am Male SB 7,652.99$ ROBERT H LYNN INCORPORATED PA Native Am Male SB 15,147.85$ CMC ENERGY SERVICES INCORPORATED PA Non-Minority Woman LB 698,918.99$ REED SMITH LLP PA Non-Minority Woman LB 229,545.46$ SKELLY AND LOY INCORPORATED PA Non-Minority Woman LB 562,139.44$ TRAFFIC CONTROL SERVICES LLC DBA FLAGGER FORCE PA Non-Minority Woman LB 4,400,983.70$ WELLINGTON ENERGY INCORPORATED PA Non-Minority Woman LB 23,109,484.91$ 84 LUMBER COMPANY PA Non-Minority Woman LB-CERT 4,051.85$ FIREFIGHTER SALES & SERVICE CO PA Non-Minority Woman LB-CERT 11,288.50$ MINITAB INCORPORATED PA Non-Minority Woman LB-CERT 10,833.75$ A & H EQUIPMENT COMPANY PA Non-Minority Woman SB 55,200.00$ ACE CONTROLS & INSTRUMENTATION INC PA Non-Minority Woman SB 351.92$ AFFORDABLE LANDCARE & LANDSCAPING L PA Non-Minority Woman SB 72,943.75$ ALLEGHENY RESTORATION INCORPORATED PA Non-Minority Woman SB 555,267.94$ AM PARTS INCORPORATED DBA JOHNSTONE SUPPLY PA Non-Minority Woman SB 7,781.23$ AUSTEEL STAMPING COMPANY PA Non-Minority Woman SB 215.00$ BARNO ELECTRONICS INCORPORATED PA Non-Minority Woman SB 917.28$ BATTERY WAREHOUSE PLUS PA Non-Minority Woman SB 1,587.79$ C DRISCOLLS POSITIVE ENERGY CONSULTING PA Non-Minority Woman SB 611,482.68$ CAPITAL SCREW & NUT COMPANY INC PA Non-Minority Woman SB 3,286.56$ CATERING PLUS LLC PA Non-Minority Woman SB 651.90$ CENTRAL CONTRACTORS SUPPLY CO INC DBA OVERHEAD DOOR CO OF JOHNSTOWN PA Non-Minority Woman SB 14,893.23$ CGI INTERNATIONAL LLC DBA CGI INTERNATIONAL INC & GENERAL PA Non-Minority Woman SB 638,399.12$ CONFIDENT CONTROLS USA INCORPORATED PA Non-Minority Woman SB 35,214.34$ CR BIRD EQUIPMENT DBA BIRD INDUSTRIAL PA Non-Minority Woman SB 2,341.13$ CRAIG FENCING INCORPORATED PA Non-Minority Woman SB 70,947.38$ CROSBY GARAGE DOOR COMPANY PA Non-Minority Woman SB 13,997.00$ DENISE I SKINNER PA Non-Minority Woman SB 1,092.50$ DYNAMIC ENERGY GROUP LLC PA Non-Minority Woman SB 238,598.34$ EASTERN OIL CORP PA Non-Minority Woman SB 69.60$ ELISHA WEBB AND SON CO INCORPORATED PA Non-Minority Woman SB 4,543.00$ ENGINES INCORPORATED PA Non-Minority Woman SB 8,501.71$ ENVIRO-AIR TECHNOLOGIES INC PA Non-Minority Woman SB 5,176,347.49$ ERIE TRUCK & TRAILER INCORPORATED PA Non-Minority Woman SB 5,780.60$ GATEWAY DIESEL INCORPORATED PA Non-Minority Woman SB 183.46$ GENERAL HYDROGEN CORPORATION OR CGI INTERNATIONAL PA Non-Minority Woman SB 254,740.51$ GOURMET AFFAIRS CATERING INC PA Non-Minority Woman SB 7,882.72$ GREENAWALT EXCAVATING INCORPORATED PA Non-Minority Woman SB 216,387.54$ HERITAGE ENVIRONMENTAL PA Non-Minority Woman SB 5,520.00$ HINKEL EQUIPMENT RENTAL ASSOC INC PA Non-Minority Woman SB 52,363.57$ HYDRAULIC REPAIRS DBA TARENTUM HARDWARE PA Non-Minority Woman SB 1,285.09$ IJN INCORPORATED DBA BETHS BARRICADES PA Non-Minority Woman SB 4,025.00$ INDUSTRIAL CONTROL CONCEPTS INC PA Non-Minority Woman SB 846,103.28$ KAZMAREK SPECIALTY FORMS INC PA Non-Minority Woman SB 359.00$ KEYSTONE DIVERSIFIED PIPE SUPPLY IN PA Non-Minority Woman SB 361.47$ KLAPEC TRUCKING COMPANY PA Non-Minority Woman SB 3,248.01$ KRATER SERVICES LLC PA Non-Minority Woman SB 14,832.50$ LEAF ENTERPRISES INCORPORATED DBA LEAF PEST CONTROL PA Non-Minority Woman SB 1,068.48$ LEVEL ONE LLC PA Non-Minority Woman SB 91,421.61$ M J REIDER ASSOCIATES INC PA Non-Minority Woman SB 1,111.40$ MARIAN E BRNA TOTAL SP LLC PA Non-Minority Woman SB 660.00$ MARJORIE P STEIN PA Non-Minority Woman SB 1,955.00$ MEADVILLE LAND SERVICE INCORPORATED PA Non-Minority Woman SB 695,306.23$ METROBRAND SERVICES LLC DBA MILL CREEK COFFEE COMPANY PA Non-Minority Woman SB 11,868.89$ MOBILE MEDICAL CORPORATION PA Non-Minority Woman SB 510,135.31$ NATIONAL TRUCK BODY SOLUTIONS PA Non-Minority Woman SB 9,834.85$ PDS CRANE SERVICE COMPANY INC PA Non-Minority Woman SB 96,306.55$ PENA-PLAS COMPANY PA Non-Minority Woman SB 784.71$ PENNY LEGAL LLC PA Non-Minority Woman SB 179,222.47$ PITTSBURGH REPORTING SERVICE PA Non-Minority Woman SB 1,508.20$ PORTAGE POWER WASH INCORPORATED PA Non-Minority Woman SB 1,457.80$ READING RENTALS PA Non-Minority Woman SB 137.59$ RIVERVIEW TREE & LANDSCAPING INC PA Non-Minority Woman SB 1,138,876.30$ RM BENNEY TECHNICAL SALES INC PA Non-Minority Woman SB 24,135.76$ RMC SANITATION LLC PA Non-Minority Woman SB 95.00$ ROBERT A REESMAN DBA REESMAN BODY SHOP LLC PA Non-Minority Woman SB 3,400.28$ ROBVON BACKING RING COMPANY PA Non-Minority Woman SB 490.33$ S & T EXCAVATING LLC PA Non-Minority Woman SB 54,101.67$ SIDELINES TREE SERVICE LLC PA Non-Minority Woman SB 39,121.10$ SPERANZA MACHINING INCORPORATED PA Non-Minority Woman SB 166,570.43$ STORAGE & ERGONOMIC EQUIPMENT CO PA Non-Minority Woman SB 14,253.00$ SUGAR RUN NURSERY LLC PA Non-Minority Woman SB 100.00$ SUSQUEHANNA WIRE ROPE & RIGGING INC PA Non-Minority Woman SB 1,107.58$ TAYLOR & ARMSTRONG CONTR INC PA Non-Minority Woman SB 1,332.80$ TECH SHEET METAL INCORPORATED PA Non-Minority Woman SB 1,413.05$ THE FIRELINE GROUP PA Non-Minority Woman SB 552.70$ THE NUT HOUSE PA Non-Minority Woman SB 473.99$ THE TITUS COMPANY INCORPORATED PA Non-Minority Woman SB 480.00$ THE TRUCK SHOP INCORPORATED PA Non-Minority Woman SB 1,714.36$ TRUBUILD LLC PA Non-Minority Woman SB 52,416.37$ TURJAN CONSTRUCTION COMPANY PA Non-Minority Woman SB 39,243.78$

5. CONCLUSION

FirstEnergy’s Supplier Diversity Program ensures the development of mutually advantageous business relationships with firms owned and operated by minorities, women and disabled business owners. Strengthening and utilizing diverse suppliers contributes to the economic growth and expansion of the communities we serve. At FirstEnergy, we will continue to provide guidance to senior management, buyers, key requisitioners, and our prime suppliers to continue fostering the relationships needed to strengthen the economic outlook and viability of all parties while building a value-added strategy and competitive advantage for all parties.

PENNSYLVANIA MINORITY BASED VENDORS DOING BUSINESS AS ST MINORITY INDICATOR DESCRIPTION TOTAL SPENDVINARSKI MCMULLEN SYSTEMS CORP PA Non-Minority Woman SB 137,659.57$ WAGNER HARDWARE & BUILDING SUPPLY DBA WAGNER ACE HARDWARE PA Non-Minority Woman SB 50,122.81$ WEST END GARAGE LLC PA Non-Minority Woman SB 7,366.44$ WITTERS SEPTIC & SANITATION LLC PA Non-Minority Woman SB 1,029.00$ WORLD CLASS TRANSMISSION SERVICE PA Non-Minority Woman SB 3,600.00$ WRIGHT INDUSTRIAL SUPPLY INC PA Non-Minority Woman SB 311,825.95$ ZERO ICE CORPORATION PA Non-Minority Woman SB 1,170.52$ ANTARES SITE WORK LLC PA Non-Minority Woman SB-CERT 18,564.72$ COMSTAR SUPPLY INCORPORATED PA Non-Minority Woman SB-CERT 8,968.00$ DON PARKER SALES INCORPORATED PA Non-Minority Woman SB-CERT 28,755.41$ ENVIRONMENTAL REMEDIATION & RECOVERY INCORPORATED PA Non-Minority Woman SB-CERT 149,993.85$ FICKESS PUMPS INCORPORATED PA Non-Minority Woman SB-CERT 5,001.34$ HAZLETON OIL & ENVIRONMENTAL INC PA Non-Minority Woman SB-CERT 2,158.60$ LEM PRODUCTS INCORPORATED PA Non-Minority Woman SB-CERT 11,195.18$ M & M LIME CO INC PA Non-Minority Woman SB-CERT 6,296.08$ M BETTERS CONSTRUCTION INC PA Non-Minority Woman SB-CERT 16,099,776.59$ PAGODA ELECTRICAL INCORPORATED PA Non-Minority Woman SB-CERT 1,735,267.95$ PURE ENERGY COACH LLC PA Non-Minority Woman SB-CERT 490,161.98$ SSM GROUP INCORPORATED PA Non-Minority Woman SB-CERT 45,216.41$ TOOL SALES & SERVICE CO PA Non-Minority Woman SB-CERT 3,533.04$ TYNDALE ENTERPRISES INCORPORATED DBA TYNDALE COMPANY INCORPORATED PA Non-Minority Woman SB-CERT 1,401,936.56$ URBASH PROFESSIONAL REPORTING INC DBA NETWORK DEPOSITION SERVICES PA Non-Minority Woman SB-CERT 137.60$ ZOOK MOTORS INCORPORATED PA Non-Minority Woman SB-CERT 29,653.38$ ALPHASOURCE INCORPORATED PA Non-Minority Woman SB-HUB-CERT 143,756.88$ DASH CONSTRUCTION COMPANY INC PA PhyChallenged SB 546,880.24$ JOSEPH M RICOTTA JOE RICOTTA PA PhyChallenged SB 117.60$ FLEXIBLE MATERIALS GROUP INC PA SDVet Male SB 7,043.00$ G J MILLER AUTO SUPPLY PA SDVet Male SB 6,350.25$ TERRA TESTING INCORPORATED PA SDVet Male SB 5,432.50$ THE RIBBON INC DBA OVERHEAD DOOR OF FRANKLIN/OVERHEAD DOOR GREATER ERIE PA SDVet Male SB 106,204.39$ TURBINE SERVICES INCORPORATED PA SDVet Male SB 78,477.12$ EMDESCO INCORPORATED DBA SECURITY 101 PITTSBURGH PA SDVet Male SB-CERT 130,838.06$ R E YATES ELECTRIC INCORPORATED PA SDVet Male SB-CERT 2,247,447.88$ HABSCO INCORPORATED PA Veteran Minority Male SB 3,169.31$ MAJR INCORPORATED DBA MAJOR RESTORATION SERVICES PA Veteran Minority Male SB 1,099.37$ RSB INVESTMENTS INCORPORATED DBA SKYWARD AVIATION PA Veteran Woman SB 33,231.49$

68,455,929.61$

2017 ANNUAL REPORT ON DIVERSITY TO THE

PENNSYLVANIA PUBLIC UTILITY COMMISSION

HUMAN RESOURCES SECTION

PENNSYLVANIA POWER COMPANY (Penn Power),

METROPOLITAN EDISON COMPANY (Met-Ed), PENNSYLVANIA ELECTRIC COMPANY (Penelec) and

WEST PENN POWER COMPANY (West Penn)

HUMAN RESOURCES LETTER 101 Issued March 24, 2014

EQUAL EMPLOYMENT OPPORTUNITY / AFFIRMATIVE ACTION POLICY This policy supersedes and cancels Human Resources Letter 101 dated February 28, 2011. PARTICIPATING COMPANIES The current list of FirstEnergy companies that are covered by the following policy letter is provided in Human Resources Letter 011 entitled Participating Companies. PURPOSE This policy reaffirms the commitment of FirstEnergy and its operating companies (“the Company”) to provide equal employment opportunity for employees and applicants in all terms and conditions of employment and to take affirmative action to employ and advance in employment qualified individuals in accordance with the Company’s affirmative action programs for minorities, women, protected veterans, and individuals with disabilities. ELIGIBILITY This policy applies to all employees and applicants. POLICY It is the policy of the Company to provide equal employment opportunity to all qualified employees and applicants regardless of race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital or domestic partnership or civil union status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service, status as a disabled veteran, recently separated veteran, an active duty wartime or campaign badge veteran (a veteran who served on active duty in the U.S. military, ground, naval or air service during a war or in a campaign or expedition for which a campaign badge has been authorized), or Armed Forces service medal veteran, and to comply with applicable federal, state, and local laws and regulations prohibiting discrimination in employment practices. This policy extends to all employment practices including recruiting, hiring, promotion, upgrade, benefits, pay, training, working conditions, employee treatment, and all other terms and conditions of employment and ensures that all employment decisions are based only on valid job requirements. In addition, the Company has implemented policies prohibiting sexual harassment (Human Resources Letter 102) and other discriminatory harassment. (Human Resources Letter 103).

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In furtherance of this policy, the Company has implemented an Affirmative Action Program for Minorities and Women (Human Resources Letter 105) and an Affirmative Action Program for Individuals with Disabilities, Disabled Veterans, Recently Separated Veterans, Active Duty Wartime or Campaign Badge Veterans, and Armed Forces Service Medal Veterans (Human Resources Letter 106) in accordance with federal regulations. The programs state the methods by which the Company provides equal employment opportunity and takes affirmative action to employ and advance in employment qualified minorities, women, individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. The Company is committed to encouraging full participation of employees in all areas and at all levels of the company. Employees and applicants shall not be subjected to harassment, intimidation, threats, coercion or discrimination because they have engaged in or may engage in any of the following activities: filing a complaint; assisting or participating in an investigation, compliance review, hearing, or any other activity related to the administration of applicable federal, state, or local laws requiring equal opportunity; opposing any act or practice made unlawful by such federal, state, or local laws; and exercising any other rights protected by such laws or the implementing regulations for these laws. All officers, managers, department heads, section heads, and others with responsibilities affecting or relating to employment opportunities, such as supervisors and local human resources representatives, are responsible for administering this policy within their respective areas. The Human Resources Department and, specifically, the Director, Employee Relations, Recruiting, and Compliance, shall provide assistance and guidance wherever and whenever needed to assure that this policy is administered and is responsible for all necessary monitoring and reporting. CLARIFICATION Questions concerning the interpretation or administration of this policy should be referred to the local human resources representative or to the Director, Employee Relations, Recruiting, and Compliance in the Human Resources Department. This human resources policy is not a binding contract, but a set of guidelines for implementation. The Company explicitly reserves the right to modify any of the provisions of this policy at any time and without notice.

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HUMAN RESOURCES LETTER 102 Issued February 28, 2011

SEXUAL HARASSMENT POLICY This policy supersedes and cancels Human Resources Letter 102 issued January 1, 2009. PARTICIPATING COMPANIES The current list of FirstEnergy companies that are covered by the following policy letter is provided in Human Resources Letter 011 entitled Participating Companies. PURPOSE The purpose of this letter is to state the policy of FirstEnergy and its operating companies (“the Company”) prohibiting sexual harassment and to define the procedure to report incidents of sexual harassment. ELIGIBILITY This policy applies to all employees and non-employees such as leased employees, contractors, vendors, customers and other individuals permitted access to any Company facility. POLICY It is the policy of the Company to provide a work environment that is free from all forms of unlawful discrimination, including sexual harassment. In addition to being a violation of federal, state, and local laws and regulations prohibiting discrimination in employment practices, sexual harassment is a form of misconduct which creates a harmful work atmosphere and interferes with the expected level of work performance and productivity. In keeping with this policy, the Company specifically prohibits sexual harassment of all employees and non-employees, such as contingent workers or contractors, by other employees, either supervisors or co-workers, or non-employees, such as contingent workers, contractors, vendors, or customers. Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature when:

• submitting to such conduct is made a term or condition of an individual’s employment;

• submitting to or rejecting such conduct by an individual is used as a basis for employment decisions affecting that individual;

• such conduct unreasonably interferes with an individual’s work performance or

creates an intimidating, hostile, or offensive work environment.

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HUMAN RESOURCES LETTER 102

Examples of behaviors that could be considered to be sexual harassment and, as such, are a violation of this policy are physical behavior of a sexual nature; verbal behavior such as sexual advances, propositions, or other sexual comments or jokes; or bringing into the workplace or displaying or transmitting sexually suggestive or sexually oriented materials such as pictures, posters, calendars, magazines, etc. by any method including electronic methods such as voice mail, e-mail, and the Internet. Following are additional examples of behaviors that may be considered to be sexual harassment and, as such, would be in violation of the Company’s policy prohibiting sexual harassment. This list is intended to expand upon the examples of behaviors that are stated in the policy; it does not include all activities that may be considered to be sexual harassment.

• Making any term or condition of employment (e.g., continued employment, wages, performance evaluations, promotions or transfer, work assignments, etc.) either explicitly or implicitly conditional on the individual or contractor providing sexual favors.

• Touching or grabbing a sexual part of an individual’s body.

• Touching or grabbing any part of an individual’s body after that person has

indicated, or it is known, that such physical contact was unwelcome.

• Telling sexually oriented jokes or using sexually explicit or offensive language.

• Referring to or calling an individual a sexually oriented name or term.

• Continuing to ask an individual to socialize on or off duty when that person has indicated he or she is not interested.

• Displaying or transmitting in the workplace sexually suggestive pictures,

cartoons, magazines, books, objects, or posters by any method including electronic methods such as voice mail, e-mail or the Internet.

• Writing sexually oriented notes or letters to an individual.

• Retaliating against an individual for filing a complaint of sexual harassment or for supporting another individual who has filed a complaint.

• Off-duty conduct which falls within the definition of harassment and which affects

the work environment or the working relationships of individuals. It is a violation of this policy for an individual to retaliate against anyone who reports any incidents of sexual harassment or who participates in an investigation of sexual harassment. All individuals are expected to conduct themselves so that they clearly are not in violation of this policy. Any individual who violates this policy will be subject to appropriate disciplinary action up to and including termination of employment in the case of an employee or termination of a Company work assignment in the case of a non-employee such as a leased employee or contractor.

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HUMAN RESOURCES LETTER 102

PROCEDURE Any individual who believes that he or she has experienced or witnessed sexual harassment should report the situation as soon as possible, but within 180 days of the incident, to any of the following employees as determined by the individual to be appropriate: the individual’s immediate supervisor; a higher level supervisor in the individual’s section or department; the local human resources representative; or the Director, Employee Relations, Recruiting, and Compliance in the Human Resources Department. A thorough investigation of the situation will be performed in accordance with the Company’s Internal Discrimination Complaint Procedure. All employees are expected to conduct themselves in accordance with this policy. It is a performance expectation that every employee exercise his/her full efforts in assisting the company in maintaining a harassment-free environment. This includes, but is not limited to, reporting all violations that an employee is subjected to or witnesses, as well as fully cooperating with investigations of complaints. In addition, all supervisory employees are responsible for enforcing this policy. To the fullest extent practicable, the Company will keep confidential any information regarding the investigation and resolution of the situation. CLARIFICATION Questions concerning the interpretation or administration of this policy should be referred to the local human resources representative or to the Director, Employee Relations, Recruiting, and Compliance in the Human Resources Department. This human resources policy is not a binding contract, but a set of guidelines for implementation. The Company explicitly reserves the right to modify any of the provisions of this policy at any time and without notice.

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HUMAN RESOURCES LETTER 103 Issued May 2, 2016

DISCRIMINATORY HARASSMENT POLICY This policy supersedes and cancels Human Resources Letter 103 dated March 24, 2014. PARTICIPATING COMPANIES The current list of FirstEnergy companies that are covered by the following policy letter is provided in Human Resources Letter 011 entitled Participating Companies. PURPOSE The purpose of this letter is to state the policy of FirstEnergy and its operating companies (“the Company”) or “the Contractor”) prohibiting harassment based on race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital or domestic partnership or civil union status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service, or veteran status (i.e., status as a disabled veteran, recently separated veteran, active duty wartime or campaign badge veteran, or Armed Forces service medal veteran) and to define the procedure to report incidents of such harassment. ELIGIBILITY This policy applies to all employees and to non-employees such as contingent workers, contractors, vendors, customers, and other individuals permitted access to any Company facility. POLICY It is the policy of the Company to provide a work environment which is free from all forms of unlawful discrimination, including harassment based on race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital or domestic partnership or civil union status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service, and status as a disabled veteran, recently separated veteran, active duty wartime or campaign badge veteran (a veteran who served on active duty in the U.S. military, ground, naval, or air service during a war or in a campaign or expedition for which a campaign badge has been authorized), or Armed Forces service medal veteran. In addition to being a violation of federal, state, and local laws and regulations prohibiting discrimination in employment practices, such harassment is a form of misconduct which creates a harmful work atmosphere and interferes with the expected level of work performance and productivity. In keeping with this policy, the Company specifically prohibits harassment based on race, color, creed, religion, gender, national origin, nationality, age, disability, ancestry, marital or domestic partnership or civil union status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service, or status as a disabled veteran, recently separated veteran, active duty wartime or campaign badge veteran, or Armed Forces service medal veteran of all employees and non-employees, such as contingent workers and contractors, by other employees, either supervisors or co-workers, or non-employees, such as contractors, vendors, or customers.


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Harassment is defined as verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital or domestic partnership or civil union status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service and status as a disabled veteran, recently separated veteran, active duty wartime or campaign badge veteran, or Armed Forces service medal veteran or that of the individual’s relatives, friends, or associates, which:

• has the purpose or effect of creating an intimidating, hostile, or offensive work environment;

• has the purpose or effect of unreasonably interfering with an individual’s work performance; or

• otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes, but is not limited to, any of the following conduct relating to race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital or domestic partnership or civil union status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service and status as a disabled veteran, recently separated veteran, active duty wartime or campaign badge veteran, or Armed Forces service medal veteran:

• epithets, slurs, negative stereotyping, or threatening, intimidating, or hostile acts;

• written or graphic material that denigrates or shows hostility or aversion toward an individual or group covered by the policy that is posted on walls, bulletin boards, or elsewhere on the premises or is displayed or transmitted in the workplace by any method including electronic methods such as voice mail, text messages, e-mail, and the Internet.

It is a violation of this policy for an individual to retaliate against anyone who reports any incidents of harassment under this policy or who participates in an investigation of such harassment. All individuals are expected to conduct themselves so that they clearly are not in violation of this policy. In addition, all supervisory employees are responsible for enforcing this policy. Any individual who violates this policy will be subject to appropriate disciplinary action up to and including termination of employment in the case of an employee or termination of the Company work assignment in the case of a non-employee such as a contractor. PAY TRANSPARENCY NONDISCRIMINATION The Contractor will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do


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not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with the contractor’s legal duty to furnish information. PROCEDURE Any individual who believes that he or she has experienced or witnessed harassment as defined in this policy should report the situation as soon as possible, but within 180 days of the incident, to any of the following employees as determined by the individual to be appropriate: the individual’s immediate supervisor, a higher level supervisor in the individual’s section or department, the local human resources representative, or the Director, Employee Relations, Recruiting, and Compliance in the Human Resources Department. A thorough investigation of the situation will be performed in accordance with the Company’s Internal Discrimination Complaint Procedure (HR Letter 107). All employees are expected to conduct themselves in accordance with this policy. It is a performance expectation that every employee exercise his/her full efforts in assisting the company in maintaining a harassment free environment. This includes, but is not limited to, reporting all violations that an employee is subjected to or witnesses, as well as fully cooperating with investigations of complaints. In addition, all supervisory employees are responsible for enforcing this policy. To the fullest extent practicable, the Company will keep confidential any information regarding the investigation and resolution of the situation. CLARIFICATION Questions concerning the interpretation or administration of this policy should be referred to the local human resources representative or to the Director, Employee Relations, Recruiting, and Compliance in the Human Resources Department. This human resources policy is not a binding contract, but a set of guidelines for implementation. The Company explicitly reserves the right to modify any of the provisions of this policy at any time and without notice.


EMPLOYMENT OF INDIVIDUALS WITH DISABILITIES This policy supersedes and cancels Human Resources Letter 104 dated February 11, 2011. PARTICIPATING COMPANIES The current list of FirstEnergy companies that are covered by the following policy letter is provided in Human Resources Letter 011 entitled Participating Companies. PURPOSE The purpose of this policy is to reaffirm the commitment of FirstEnergy and its operating companies (“the Company”) and to describe the procedures to be followed to ensure that applicants and employees who are individuals with disabilities will be given equal opportunity for employment and in all terms and conditions of employment in accordance with applicable federal, state, and local laws and regulations. ELIGIBILITY This policy applies to all employees. POLICY The Company provides equal opportunity to employees and applicants who are individuals with disabilities with respect to employment and all terms, conditions, and privileges of employment. The Company will make reasonable accommodations for qualified individuals with known disabilities to enable them to perform the essential functions of a job, provided the accommodations do not result in an undue hardship to the Company. PROCEDURES The procedures for employing individuals with disabilities first require that an individual, either an employee or an applicant, meets the definition of an individual with a disability. If the individual meets this definition, the determination must be made whether the individual is a qualified individual with a disability, which means that he or she is qualified to perform the essential functions of a job with or without a reasonable accommodation for a disability. A determination of qualifications also requires that the individual not pose a direct threat to the health or safety of the individual or others. During the hiring or selection process, Company representatives may not make inquiries which are specifically about an individual's disability or which would reveal information about a disability. This restriction does not apply to pre-offer inquiries made by the Company’s e-Recruiting system that are mandated by federal regulations, the responses to which are contained in a confidential data analysis file and not disclosed to Company representatives. The Company will give physical examinations and obtain medical and related information necessary to evaluate the ability of applicants and employees to perform the essential functions of a job, with or without a reasonable accommodation, and to ensure that the individual does not pose a direct threat to his or her health or safety or to the health or safety

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of others. For applicants, the physical examination will be given and medical information obtained only after an offer of employment has been made. The definition of an individual with a disability does not include individuals who are current illegal users of drugs, but does include, with specific restrictions, individuals who are recovering drug addicts who are no longer using drugs illegally and individuals who are alcoholics. Determination of Status As An Individual With a Disability An individual with a disability is a person who meets any of the following conditions:

• has a physical or mental impairment that substantially limits one or more major life activities;

• has a record of such an impairment; or

• is regarded as having such an impairment.

To meet the first condition, the individual must have a physical or mental impairment which is defined as any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of several body systems, or any mental or psychological disorder. An impairment is a disability if it substantially limits one or more major life activities when an individual is unable to perform an activity or is significantly limited in the ability to perform an activity compared to an average person in the general population. Major life activities fall into two categories:

• General Activities – These major life activities are activities that an average person can perform with little or no difficulty, such as caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, and working.

• Major Bodily Functions – These major life activities include but are not limited to,

functions of the immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions.

To determine if a person's impairment substantially limits a major life activity consideration must be given to the nature and severity of an impairment, how long the impairment will last or is expected to last, and the permanent or long-term impact of the impairment. Temporary, non-chronic impairments that do not last for a long time (generally less than six months) and that have little or no long-term impact usually are not considered to be disabilities. An impairment that is episodic or in remission is considered a disability if it would substantially limit a major life activity when active. To meet the second condition, an individual is considered to be disabled if he or she has a record or history of an impairment, whether or not the individual is currently substantially limited in a major life activity.

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In the third condition, even if an individual does not have an impairment which substantially limits one or more major life activity, the individual is considered to be an individual with a disability if he or she is regarded as having an impairment and is treated in that manner. Determination of Status As a Qualified Individual With a Disability A qualified individual with a disability is an individual who meets the job requirements of a position, such as requisite knowledge, skills, ability, work experience, education, etc., and who can perform the essential functions of the position with or without a reasonable accommodation for a disability. The job requirements include the requirement that an individual not pose a direct threat to his or her health or safety or to the health or safety of others. Determining the Essential Functions of a Position The essential functions of a position are the tasks which are fundamental to the job and which must be performed to accomplish the job. The term does not include marginal or peripheral functions which are incidental to the performance of the job. A job function may be considered essential under various circumstances which include, but are not limited to, the following: • if the reason the position exists is to perform the function; • if there are a limited number of employees available among whom the

performance of the job functions can be distributed; • if the function is so highly specialized that the person is hired for his or her

expertise or ability to perform the particular function. In determining the essential functions of a position, the emphasis should be on defining the task that is to be performed, not on specifying how the task would be performed or what equipment would be used to perform the task, because an individual with a disability may perform a task in a different manner or by using different equipment than other employees. Determining Reasonable Accommodations Once the essential functions of a position are identified, it must be determined whether the qualified individual with a disability can perform those essential functions with or without a reasonable accommodation. A reasonable accommodation is a modification or adjustment to the work environment or to a job which permits an otherwise qualified applicant or employee with a disability to have equal opportunity in the employment process, to perform the essential functions of a job, and to receive equal benefits and privileges of employment. Reasonable accommodations will be made for qualified individuals with disabilities, provided that the accommodation does not impose an undue hardship on the Company. An accommodation imposes an undue hardship if it is unduly costly, extensive, substantial, or disruptive, or if it would fundamentally alter the nature or operation of the business.

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To be considered for a reasonable accommodation, an individual with a disability must be otherwise qualified to perform the job and the disability must be known to the Company either through observation or by the individual informing a Company representative (human resources representative or supervisor). Once the need for an accommodation is known, the Company and the individual will engage in an interactive process to determine appropriate reasonable accommodation. The determination of an appropriate reasonable accommodation must be made on a case-by-case basis taking into consideration the specific abilities and functional limitations of a particular applicant or employee with a disability, the specific functional requirements of a particular job, and hardships upon the Company resulting from the reasonable accommodation. For an applicant who is an individual with a disability, the accommodations which would be considered shall be limited to those which would make the physical facilities accessible and which would enable the applicant to perform the job for which he or she has applied. Any accommodations to enable an employee to perform the essential functions of a job should first be considered in the employee's current job. If an accommodation cannot be made in the employee's current job without causing an undue hardship on the Company, consideration should be given to reassigning the employee to an existing vacant job that the Company would fill and for which the employee is qualified to perform, with or without a reasonable accommodation. For employees represented by a union, reassignment to another position may be limited by the terms of the applicable collective bargaining agreement. In accordance with the Company’s Affirmative Action Program for Individuals With Disabilities, Disabled Veterans, Recently Separated Veterans, Active Duty Wartime or Campaign Badge Veterans, and Armed Forces Service Medal Veterans (Human Resources Letter 106), if an employee with a known disability is having significant difficulty performing his or her job and it is reasonable to conclude that the performance problem may be related to the known disability, the local human resources representative or the employee’s supervisor shall confidentially notify the employee of the performance problem and inquire whether the problem is related to the employee’s disability. If the employee states that the performance problem is related to his or her disability, the human resources representative or supervisor shall confidentially inquire whether the employee needs a reasonable accommodation and shall take the necessary action to make the reasonable accommodation. An employee with a disability who temporarily is not qualified to perform an existing job with or without a reasonable accommodation may be eligible for sick pay benefits for non-industrial illness or injury or for disability offset benefits for industrial illness or injury. The determination of the employee's eligibility for such benefits shall be made in accordance with the appropriate collective bargaining agreement or the Disability Income Benefits section of the Employee Benefits Handbook for non-union employees.

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Establishing Job Qualifications for Health and Safety The Company may establish job qualifications, which require that an individual does not pose a direct threat to the health or safety of himself or herself or others. This qualification must be applied to all individuals who are in a job or who are being considered for the job and not just to individuals with disabilities. To determine if an individual poses a direct threat to the health and safety of himself or herself or others, there must be a significant risk of substantial harm as determined by objective medical or other factual evidence. The assessment of risk must be based on a particular individual's present ability to perform the essential functions of a job and cannot be based on speculation about future risk. If it is determined that there is a significant risk, a reasonable accommodation must be considered to either eliminate the risk or reduce it to an acceptable level. The requirements for job qualifications regarding health and safety must comply with applicable federal laws and with state and local laws provided the state and local laws do not conflict with federal laws prohibiting discrimination against individuals with disabilities. Appropriate Inquiries During the Hiring and Selection Process To ensure that qualified individuals with disabilities are not screened out during the hiring or selection process on the basis of their disability before their ability to perform a job is evaluated, Company representatives, such as supervisors or human resources representatives, may not inquire or otherwise obtain information about an individual's disability prior to making the job offer. This restriction extends to obtaining information about an individual's disability, record of illnesses, medical history, or record of workers' compensation claims and applies to any method which the Company uses to obtain employment information such as the employment application, employee resumes, interviews, reference checks, or background checks which may be conducted by a third party firm. This restriction does not apply to pre-offer inquiries made by the Company’s e-Recruiting system that are mandated by federal regulations, the responses to which are contained in a confidential data analysis file and not disclosed to Company representatives. Although Company representatives may not ask about an individual's disability, the representatives may and should ask all job applicants about their ability to perform specific job functions, tasks, or duties. If an individual has a known or apparent disability that might interfere with or prevent performance of job functions, the individual may be asked to describe or demonstrate how these job functions will be performed, with or without an accommodation, even if other applicants are not asked to do so. However, if an individual has a known or apparent disability which would not interfere with the performance of job functions, the individual may only be required to describe or demonstrate how he or she will perform a job if this is required of all applicants for the position. Medical information on an applicant may be obtained only as part of a physical examination which is given after the offer of employment is made. This restriction does not apply to inquiries made by the Company’s e-Recruiting system that are mandated by federal

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regulations, the responses to which are contained in a confidential data analysis file and not disclosed to Company representatives. The offer of employment to an individual will be made conditional upon the satisfactory results of the physical examination. Medical Examinations and Inquiries The Company will obtain medical and related information necessary to evaluate the ability of applicants and employees to perform the essential functions of a job, with or without a reasonable accommodation, and to ensure that the individual does not pose a direct threat to his or her health or safety or to the health or safety of others. For applicants, the medical examination will be given only after an offer of employment has been made. For employees, the Company may conduct medical examinations to determine current fitness to perform a particular job, if there is evidence of a job performance or safety problem, or when required by other federal laws or by state or local laws that are not in conflict with federal laws prohibiting discrimination on the basis of disability. All information obtained from medical examinations must be collected and maintained on separate forms, in separate medical files, and must be treated as a confidential medical record. All medical-related information must be kept confidential except that supervisors may be informed about necessary restrictions on the work or duties of an employee and necessary accommodations, and safety and first aid personnel may be informed, when appropriate, if the employee's disability might require emergency treatment or if any specific procedures are needed in the case of fire or other evacuations. Drug and Alcohol Abuse The terms of this letter are consistent with the Company’s position on the use and possession of drugs and alcohol to ensure that the workplace is free from the illegal use of drugs and the use of alcohol (Industrial Relations Letter 303). The definition of an individual with a disability does not include individuals who are current illegal users of drugs, but does include, with specific restrictions, individuals who are recovering drug addicts who are no longer using drugs illegally and individuals who are alcoholics, as explained below. Individuals who are current illegal users of drugs are not individuals with disabilities and are not entitled to consideration under the terms of this letter. The illegal use of drugs includes the use of illegal drugs, the illegal use of prescription drugs which are controlled substances, and the possession or distribution of illegal or controlled drugs. Individuals whose results on drug screens administered in accordance with applicable Company policies indicate use of an illegal drug are considered to be current drug users. The Company may discharge or deny employment to current illegal users of drugs on the basis of such drug use. Recovering drug addicts who are addicted to drugs, but who are no longer using drugs illegally and are receiving treatment for drug addiction or who have been rehabilitated successfully, are considered to be individuals with disabilities and are entitled to consideration under the terms of this letter. To ensure that drug use is not recurring, the

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Company may require evidence that an individual is participating in a drug rehabilitation program and may require that the individual undergo appropriate drug screens. Individuals who are alcoholics, although considered to be individuals with disabilities, are subject to the provisions of all Company policies, including the drug and alcohol policy, and are held to the same qualifications, job performance, attendance, and other behavior standards as other employees who are not considered to be individuals with disabilities, even if the individuals' behaviors are related to the condition of alcoholism. CLARIFICATION Questions concerning the interpretation or administration of this policy should be referred to the local human resources representative or to the Director, Employee Relations, Recruiting, and Compliance in the Human Resources Department. This human resources policy is not a binding contract, but a set of guidelines for implementation. The Company explicitly reserves the right to modify any of the provisions of this policy at any time and without notice.

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AFFIRMATIVE ACTION PROGRAM FOR MINORITIES AND WOMEN This policy supersedes and cancels Human Resources Letter 105 dated February 28, 2011. PARTICIPATING COMPANIES The current list of FirstEnergy companies that are covered by the following policy letter is provided in Human Resources Letter 011 entitled Participating Companies. PURPOSE FirstEnergy and its operating companies (“the Company”) have implemented an Affirmative Action Program for Minorities and Women which states the methods by which the Company provides equal employment opportunity and takes affirmative action to employ and advance in employment qualified minorities and women. ELIGIBILITY This policy applies to all employees and non-employees such as leased employees, contractors, vendors, customers, external applicants and other individuals permitted access to any Company facility. POLICY It is the policy of the Company to provide equal employment opportunity to all qualified employees and applicants regardless of race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital or domestic partnership or civil union status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service, status as a disabled veteran, recently separated veteran, active duty wartime or campaign badge veteran (a veteran who served in active duty in the U.S. military, ground, naval, or air service during a war or in a campaign or expedition for which a campaign badge has been authorized), or Armed Forces service medal veteran and to comply with applicable federal, state, and local laws and prohibiting discrimination in employment practices. This policy extends to all areas of employment practices including recruiting, hiring, promotions, upgrade, benefits, pay, training, working conditions, employee treatment, and all other terms and conditions of employment and ensures that all employment decisions are based only on valid job requirements. (The Company’s equal employment opportunity / affirmative action policy is published as Human Resources Policy 101.) In addition, the Company has implemented policies prohibiting sexual harassment and harassment based on race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital status, or domestic partnership or civil union, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, liability for military service or status as a disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. (The Company’s harassment policies are published as Human Resources Letters 102 and 103.)

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HUMAN RESOURCES LETTER 105 Issued March 24, 2014 In furtherance of the equal employment opportunity / affirmative action policy, the Company has implemented this Affirmative Action Program for Minorities and Women in accordance with Executive Order 11246 and an Affirmative Action Program for Individuals With Disabilities, Disabled Veterans, Recently Separated Veterans, Active Duty Wartime or Campaign Badge Veteran, and Armed Forces Service Medal Veterans (Human Resources Letter 106) in accordance with Section 503 of the Rehabilitation Act of 1973, as amended, and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended. These programs state the methods by which the Company provides equal employment opportunity and takes affirmative action to employ and advance in employment qualified minorities, women, individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veteran, and Armed Forces service medal veterans. Employees and applicants shall not be subjected to harassment, intimidation, threats, coercion or discrimination because they have engaged in or may engage in any of the following activities: filing a complaint; assisting or participating in an investigation, compliance review, hearing, or any other activity related to the administration of applicable federal, state, or local laws requiring equal opportunity for individuals based on race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital or domestic partnership or civil union status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service, status as a disabled veteran, recently separated veteran, active duty wartime or campaign badge veteran (a veteran who served in active duty in the U.S. military, ground, naval, or air service during a war or in a campaign or expedition for which a campaign badge has been authorized), or Armed Forces service medal veteran; opposing any act or practice made unlawful by such federal, state, or local laws; and exercising any other rights protected by such laws or the implementing regulations for these laws. All officers, managers, department heads, section heads, and others with responsibilities affecting or relating to employment opportunities, such as supervisors and local human resources representatives, are responsible for administering this policy within their respective areas. The Human Resources Department and, specifically, the Director, Employee Relations, Recruiting, and Compliance shall provide assistance and guidance wherever and whenever needed to assure that this policy is administered and is responsible for all necessary monitoring and reporting. DISSEMINATION OF POLICY Internal Dissemination The Company undertakes the following activities to disseminate internally information regarding its equal employment opportunity / affirmative action policy and affirmative action programs:

• Includes the equal employment opportunity / affirmative action policy and the affirmative action programs in the Human Resources Letters which provide direction for the Company’s human resources procedures. The Human Resources Letters are distributed to management and supervisory personnel and are available to employees through the Company’s on-line computerized network and the Company’s intranet system.

• Distributes the equal employment opportunity / affirmative action policy annually to

all employees.

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• Posts the equal employment opportunity / affirmative action policy on bulletin boards in all Company locations.

• Posts a notice on bulletin boards in all company locations informing employees

about the affirmative action programs. The notice also informs employees that the programs are available for review and states the location and hours during which they may request to review it.

• Includes in management and supervisory training programs information regarding

the equal employment opportunity / affirmative action policy, the affirmative action programs, and related policies, such as the harassment policies.

• Union Officials are informed of the Company’s EEO policy and affirmative action

programs.

• Informs new employees about the Company’s equal employment opportunity/ affirmative action policy, affirmative action programs, and related policies, such as the harassment policies, in new employee orientation sessions.

• Reviews the provisions of the collective bargaining agreements to ensure that they

are nondiscriminatory and include nondiscrimination clauses in the agreements. • Includes articles and pictures of minorities and women in Company publications

whenever articles and pictures of employees are used. External Dissemination The Company undertakes the following activities to disseminate externally information regarding its equal employment opportunity / affirmative action policy and affirmative action programs:

• Notifies recruiting sources of the Company’s equal employment opportunity/ affirmative action policy and the affirmative action programs and requests their cooperation and assistance in actively recruiting and referring qualified minorities, women, protected veterans, and individuals with disabilities for all positions.

• The Company uses a diverse slate of recruiting resources, including organizations

dedicated to the placement of minorities, females, protected veterans, and individuals with disabilities.

• The Company participates in job fairs which target minority, female, and protected

veteran recruits as well as those which target individuals with disabilities.

• Includes a statement in all recruiting literature that the Company is an equal employment opportunity / affirmative action employer / disability / veterans.

• Includes the phrase "An EEO/AA Employer – Min/Female/Disability/Vet" in all

classified advertisements for employment openings. • Includes a statement in the employment application that the Company is an equal

employment opportunity / affirmative action employer.

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• Posts the equal employment opportunity / affirmative action policy on Company bulletin boards that are available to applicants.

• Posts a notice on Company bulletin boards that are available to applicants informing

them about the affirmative action programs. The notice also informs applicants that the program is available for review and states the location and the hours during which they may request to review it.

• Includes pictures of both minority and female individuals in consumer, promotional,

or recruitment material whenever individuals are featured. • Includes an equal employment opportunity and affirmative action policy clause in all

purchase orders and contracts with vendors. RESPONSIBILITY FOR IMPLEMENTATION The Executive Director, Human Resources has delegated to the Director, Employee Relations, Recruiting, and Compliance the responsibility for the development and coordination of the Company's Affirmative Action Program. The Director has responsibilities which include, but are not limited to, the following:

• Develops policy statements, affirmative action programs, and methods of internal and external communication of the programs.

• Assists the local human resources representatives and members of management in

identifying problem areas and arriving at solutions to the problems. • Advises the human resources representatives and members of management in

interpreting and implementing the equal employment opportunity / affirmative action policy, the affirmative action programs, related Company policies, and the associated laws and regulations.

• Designs and implements audit and reporting systems to measure the effectiveness

of the affirmative action programs, indicate if a need for remedial action exists, and determine the degree to which affirmative action goals and objectives have been attained.

• Provides guidance and technical assistance to the human resources

representatives at each location in preparing and updating the affirmative action programs.

• Provides guidance and assistance to the human resources representatives at each

location to implement the affirmative action programs and to ensure that the location is in compliance with equal employment opportunity and affirmative action laws and regulations.

• Serves as the liaison between the Company and enforcement agencies.

The local human resources representatives have the responsibility to implement the provisions of the affirmative action program at their locations. The responsibilities of the human resources representatives include, but are not limited to, the following:

• Updates the affirmative action program annually for the location and communicates the goals and progress toward achieving the goals to members of management.

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• Prepares reports as needed to monitor the progress toward achieving the location’s

affirmative action goals. • Establishes and maintains contacts with the local office of the state Bureau of

Employment Services and local organizations that represent the interests of minorities, women, protected veterans, and individuals with disabilities for purposes of obtaining referrals for employment opportunities.

• Assists members of management in interpreting and implementing the Statement of

Policy and Affirmative Action Programs and the associated laws and regulations. • Assists members of management in identifying problem areas and arriving at

solutions to the problems. • Ensures that each location is in compliance with equal employment opportunity and

affirmative action laws and regulations, including the technical phases of compliance such as display of posters and policy statements, retention of employment applications, and record keeping.

• Monitors employment practices such as hiring, promotion, transfer, and selection for

training to ensure nondiscrimination in the decisions and to remove any impediments to the attainment of affirmative action goals and objectives.

• Assists members of management to ensure that minority and female employees

have the opportunity to participate in all Company-sponsored educational, training, recreational, and social activities.

• Serves as the liaison with local minority organizations and community action

organizations concerned with issues of equal employment opportunity for minorities, women, protected veterans, and individuals with disabilities.

All members of management are responsible for the implementation of the Equal Employment Opportunity/Affirmative Action Statement of Policy and the Affirmative Action Programs and the accomplishment of affirmative action objectives within their area of responsibility. This includes initiating or supporting programs and practices designed to develop understanding, acceptance, commitment, and compliance within the framework of the Statement of Policy and Affirmative Action Programs. The responsibilities of management include, but are not limited to, the following:

• Assists the human resources representatives in identifying problem areas and establishing affirmative action goals and objectives.

• Works with the human resources representatives to ensure that the location is in compliance with various equal employment opportunity and affirmative action laws and regulations.

• Ensures that the Company’s equal employment opportunity/affirmative action policies are being followed, including policies prohibiting harassment of employees.

• Maintains employment practices such as hiring, promotion, transfer, and selection for training which ensure nondiscrimination in the decisions and which remove any impediments to the attainment of affirmative action goals and objectives.

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• Consults, when necessary, with the local human resources representatives and the Director, Employee Relations, Recruiting, and Compliance to resolve problems that may arise related to the Company’s equal employment opportunity and affirmative action policies.

• Informs supervisors regularly that their work performance will be evaluated on their

equal employment opportunity efforts and results, as well as other criteria. • Provides job counseling for employees as appropriate. • Ensures that all facilities which are maintained for the use and benefit of the

employees are desegregated and that facilities such as locker rooms and rest rooms are comparable for both sexes.

• Encourages all employees, including minority and female employees and employees with protected veteran and individual with disability status, to participate in all Company-sponsored educational, training, recreational, and social activities.

• Becomes actively involved with local organizations that represent the interests of

minorities, women, protected veterans, individuals with disabilities, community action groups, and community service programs.

IDENTIFICATION OF PROBLEM AREAS As part of the Company's ongoing audit of its Equal Employment Opportunity/Affirmative Action Policy and Affirmative Action Programs, certain areas are analyzed to ensure that the Company does not engage in discriminatory practices. If any deficiencies are identified, corrective action will be taken to bring the Company into compliance with nondiscriminatory laws and regulations and the Company’s own Policy and Programs. The following areas are analyzed:

• Composition of the work force by minority group status, gender, protected veteran status, and individual with disability status.

• Composition of applicant flow by minority group status, gender, protected veteran

status, and individual with disability status. • The total selection process, including job specifications, job titles, statement of job

qualifications, application forms, interview procedures, test administration, test validity, recruitment and referral procedures, final selection process, and similar factors for minorities, women, protected veterans, and individuals with disabilities.

• Transfer and promotion practices for minorities, women, protected veterans, and

individuals with disabilities. • Company facilities, Company-sponsored recreational and social events, and special

programs such as education assistance for minorities, women, protected veterans, and individuals with disabilities.

• Seniority practices and seniority provisions of collective bargaining agreements.

• Company training programs, both formal and informal for minorities, women,

protected veterans, and individuals with disabilities.

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• Attitude of employees, managers, and supervisors toward equal employment opportunity and affirmative action for minorities, women, protected veterans, and individuals with disabilities.

• Technical phases of compliance, such as display of posters and policy statements, nondiscrimination clause in collective bargaining agreements, EEO/AAP clauses in purchase orders and contracts, retention of employment applications, and record keeping.

• Affirmative Action Program evaluation system.

DEVELOPMENT AND EXECUTION OF PROGRAMS The Company has developed and implemented the following programs and procedures to ensure that the employment practices are nondiscriminatory and to achieve the objectives of the Affirmative Action Program. Recruitment The Company uses the following methods to further the goals of the recruitment of minorities, women, protected veterans, and individuals with disabilities:

• Listings with the state Employment Service Delivery System (ESDS) the vacancies in all positions that will be filled through external sources, with the exception of executive and top management positions. The listing of these vacancies will be done concurrently with the use of any other recruiting sources.

• Contacts local groups representing the interests of minorities, women, protected

veterans, and individuals with disabilities.

• Requests the referral of qualified minority and female candidates and those with the statuses of protected veteran and individuals with disabilities.

• Recruits at colleges for qualified minority and female candidates and those with the

statuses of protected veteran and individuals with disabilities for management group positions and positions in the cooperative education program.

• Invites minority and female employees to partake for recruiting at colleges and job

fairs when employees are invited to partake in recruiting activities.

• Sponsors qualified minority college students as interns in cooperation with the program developed by INROADS, Inc.

• Includes a statement of the Company’s equal employment opportunity policy and

affirmative action policy and commitment in recruiting brochures. • Includes the statement "An EEO/AA Employer - Min/Female/Disability/Vet" in

employment advertising and recruiting material. • Makes copies of job specifications available to all recruiting sources.

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HUMAN RESOURCES LETTER 105 Issued March 24, 2014 Selection Process The Company’s total selection process is evaluated on an ongoing basis to ensure that it is nondiscriminatory. The Company’s job specifications are reviewed periodically to ensure that they accurately reflect the duties of the position and are consistent for the same position from one location to another. The qualifications for each position are based on job performance criteria. The statement of qualifications is consistent for the same job titles in all locations and is nondiscriminatory. The job specifications stating duties and qualifications are available to employees bidding on positions and to all members of management involved in the recruiting, selection, and promotion process. Copies of the job specifications for job openings are also available to all recruiting sources. All personnel having any part in the selection process are trained to ensure that the process is effective and remains nondiscriminatory. The Company complies with the requirements of the Uniform Guidelines on Employee Selection Procedures. Any test used or considered for use in the Companies’ selection process shall be approved by the Director, Employee Relations, Recruiting, and Compliance in compliance with the Guidelines. Promotions and Transfers The following methods are used to ensure that promotions and transfers are available to all qualified employees on a nondiscriminatory basis:

• Available positions in the Management and Administrative Group are posted according to the specifications of the Job Posting System. Bargaining unit positions are posted according to the provisions of the appropriate collective bargaining agreement.

• The job specifications are available to all employees bidding on the positions and to members of management involved in the selection decision.

• The qualifications stated in the job specifications are based on job performance criteria.

• Seniority practices and seniority clauses in collective bargaining agreements are reviewed to ensure that they are nondiscriminatory.

• An inventory of the skills, academic, training and experience level of current

employees is maintained and available to supervisors for the selection process. Salary Programs The Company has adopted a salary program for employees in the Management and Administrative Group that determines fair compensation for all employees in a nondiscriminatory manner.

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HUMAN RESOURCES LETTER 105 Issued March 24, 2014 The salary program provides that the compensation for each job is based on an evaluation of the job content. The evaluation defines a standard rate for each job which reflects the value of the job as compared to all other salaried jobs in the Company. The evaluations are performed by trained professionals of the Employee Compensation staff. For bargaining unit jobs, the description of job duties and the labor grade is established by the Company through a job evaluation performed by staff members of the Industrial Relations Department. The wage rate for each labor grade is negotiated by the Company and the Unions through the collective bargaining process, thus ensuring nondiscrimination in the determination of wage rates. Performance Appraisal Program The performance of employees in the Management and Administrative Group is evaluated according to the specifications of the Company's Performance Appraisal Program. The Performance Appraisal Program requires performance standards to be established for the job duties that comprise the major responsibilities of the job. The performance standards are based on actions and results that are controllable by the employee and are measurable or observable. All individuals who are responsible for the performance appraisal of employees are trained to establish objective job standards and to evaluate performance in a consistent, uniform, and nondiscriminatory manner. Training and Education Training programs are available to employees on a nondiscriminatory basis according to the requirements of the job. The Employee Educational Assistance Plan is available to all employees on a nondiscriminatory basis to further their formal education in job-related areas. Facilities and Company-Sponsored Activities The Companies’ physical facilities are desegregated and comparable facilities are provided for male and female employees. Company-sponsored social and recreational activities are available to all employees on a nondiscriminatory basis and all employees are encouraged to participate. Internal Discrimination Complaint Procedure The Company has implemented an Internal Discrimination Complaint Procedure (Human Resources Letter 107) which may be followed by any employee who believes he or she has been discriminated against on the basis of race, color, creed, religion, sex, gender, national origin, nationality, age, ancestry, disability, marital status, affectional or sexual orientation, atypical hereditary cellular or blood trait, liability for military service and status as a disabled veteran, recently separated veteran, active duty wartime or campaign badge veteran, or Armed Forces service medal veteran. The employee may initiate this procedure by contacting the local human resources representative or the Director, Employee Relations, Recruiting, and Compliance.

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HUMAN RESOURCES LETTER 105 Issued March 24, 2014 INTERNAL AUDIT AND REPORTING SYSTEM The Company regularly audits the results of its Affirmative Action Programs to measure the effectiveness of the Program, indicate areas where remedial action is needed, and provide information to determine the degree to which the goals and objectives have been met. COMPLIANCE WITH SEX DISCRIMINATION GUIDELINES The Company’s employment policies and practices are in compliance with the federal Sex Discrimination Guidelines as stated in the following section: Recruitment and Advertising The Company recruits both men and women for all jobs. There is no job in the Company for which gender is a bona fide occupational qualification. The Company’s employment advertisements or communications to recruitment sources do not indicate a preference for either male or female candidates. Because none of the newspapers in which the Company places employment advertisements uses separate help-wanted columns for male or female, the Company does not show a preference for applicants based on gender by the placing of advertisements. The Company’s employment advertisements include the phrase "An EEO/AA Employer - Min/Female/Disability/Vet." Job Policies and Practices The Company’s Equal Employment Opportunity / Affirmative Action Policy expressly prohibits discrimination because of gender in all areas of employment practices. The collective bargaining agreements between the Company and each union contain a clause that prohibits sex discrimination in the application of the terms of the agreement. All employees, regardless of the gender of the employee, are given equal opportunity to apply for jobs for which they are qualified. Many of the opportunities in non-union jobs are posted in accordance with the Company’s Job Posting System; opportunities in bargaining unit jobs are posted in accordance with the terms of the applicable collective bargaining agreements. The Company makes no distinction based on gender in employment opportunities, wages, hours, or other conditions of employment. None of the Company’s employee benefit programs differentiate between employees based on gender. The Company makes no distinction in any employment programs between male and female employees and applicants because of their marital status or existence of dependent children. The Company’s physical facilities are appropriate and adequate for employees of both genders wherever they are working. Employment opportunities will not be denied to either men or women because there are no rest rooms or associated facilities. The Company has constructed, and will continue to construct, appropriate physical facilities for employees of either gender, as necessary.

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HUMAN RESOURCES LETTER 105 Issued March 24, 2014 There are no protective laws in the states which the Company operates that limit employment opportunities for women and the Company has no policies or practices that have the same restrictive effect. Female employees are not penalized in their conditions of employment because they may require time away from work due to pregnancy, childbirth, and related medical conditions. Employees with disabilities resulting from pregnancy, childbirth, and related medical conditions are treated in the same manner as employees with disabilities resulting from other medical conditions with respect to eligibility for disability income benefits (sick pay), health care benefits, and other applicable employee benefits programs. The Company’s Leave of Absence policy is available to eligible male and female employees and is administered without regard to the gender of the employee. The Leave of Absence policy, which is in compliance with the Family and Medical Leave Act, provides leaves of absence for eligible employees to care for a newborn or newly-adopted child, to care for an employee’s spouse, child, or parent with a serious health condition, or for an employee’s serious health condition that makes the employee unable to perform the functions of his/her position. An employee who is granted a leave of absence shall return to the same job, or an equivalent position with equivalent benefits, pay, and other terms and conditions of employment without regard to the gender of the employee. Male and female employees have the same eligibility for retirement. Employees’ pensions are based on years of credited service and monthly earnings and are not related to the gender of the employee. Male and female employees are eligible for all training programs and benefits offered by the Company. Women are encouraged to participate in management training programs, both in house programs and outside the Company. Seniority System In Company locations where a seniority system exists, the lines of promotion and seniority lists are not based on gender. Wages and Job Classifications The wages of hourly jobs and the standard rate of salaried jobs are determined by formal job evaluation systems. The wage and standard rate schedule are based on the requirements of the job and are not related to the gender of the employee holding any job. No job classification is restricted to employees of either gender and all jobs are available to qualified employees without regard to gender. Affirmative Action The Company takes affirmative action to employ qualified women in various job classifications by recruiting at colleges and universities for entry-level professional positions and at local offices of the state Employment Services Delivery System (ESDS) for all positions that are filled through external sources. Enrollment in Company training programs is based on the requirements of the jobs and the qualifications of the employees and is not based on the gender of the employees. The Company encourages participation in training programs that are available to all qualified employees whose job skills would be increased by the completion of such training.

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HUMAN RESOURCES LETTER 105 Issued March 24, 2014 The Company’s Employee Educational Assistance Plan is available to all employees without regard to gender. Employees are encouraged to take advantage of the program to further their college education in work-related fields to increase their skills in their current job assignments and to prepare themselves for possible future advancement. SUPPORT OF COMMUNITY ACTION PROGRAMS Company representatives at all locations are encouraged to actively support and participate in local and national community action programs and community service programs which are designed to improve the employment opportunities of minorities, women, protected veterans, and individuals with disabilities. CONSIDERATION OF MINORITIES, WOMEN, PROTECTED VETERANS, AND INDIVIDUALS WITH DISABILITIES NOT IN THE WORK FORCE The Company will continue to work with organizations at each location that will help identify and refer for employment opportunities qualified minorities, women, protected veterans, and individuals with disabilities who are not currently in the work force. The intent of this continuing effort is to identify and recruit qualified minorities, women, protected veterans, and individuals with disabilities for employment with the Company. CLARIFICATION Questions concerning the interpretation or administration of this policy should be referred to the local human resources representative or to the Director, Employee Relations, Recruiting, and Compliance. This human resources policy is not a binding contract, but a set of guidelines for implementation. The Company explicitly reserves the right to modify any of the provisions of this policy at any time and without notice.

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AFFIRMATIVE ACTION PROGRAM FOR INDIVIDUALS WITH DISABILITIES, DISABLED VETERANS, RECENTLY SEPARATED VETERANS, ACTIVE DUTY

WARTIME OR CAMPAIGN BADGE VETERANS, AND ARMED FORCES SERVICE MEDAL VETERANS

This policy supersedes and cancels Human Resources Letter 106 dated February 28, 2011. PARTICIPATING COMPANIES The current list of FirstEnergy companies that are covered by the following policy letter is provided in Human Resources Letter 011 entitled Participating Companies. PURPOSE FirstEnergy and its operating companies (“the Company”) have implemented an Affirmative Action Program for individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veteran, and Armed Forces service medal veterans which states the methods by which the Company provides equal employment opportunity and takes affirmative action to employ and advance in employment qualified individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. ELIGIBILITY For purposes of this program, the following definitions apply: • Individual with a disability: Any person who has a physical or mental impairment which

substantially limits one of more of such person’s major life activities; has a history or record of such an impairment; or is regarded as having such an impairment.

• Disabled veteran: (a) A veteran of the U.S. military, ground, naval or air service who is

entitled to compensation (or who but for the receipt of military retired pay would be entitled to compensation) under laws administered by the Secretary of Veterans Affairs; or (b) A person who was discharged or released from active duty because of a service-connected disability.

• Recently separated veteran: Any veteran during the three-year period beginning on

the date of such veteran’s discharge or release from active duty in the U.S. military, ground, naval or air service.

• Active duty wartime or campaign badge veteran: A veteran who served on active duty

in the U.S. military, ground, naval or air service during a war or in a campaign or expedition for which a campaign badge has been authorized, under the laws administered by the Department of Defense.

• Armed Forces service medal veteran: a veteran who, while serving on active duty in

the U.S. military, ground, naval or air service, participated in a United States military

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operation for which an Armed Forces service medal was awarded pursuant to Executive Order 12985 (61 FR 1209).

A qualified individual with a disability or a qualified disabled veteran is an individual with a disability or a disabled veteran who satisfies the requisite skill, experience, education, and other job-related requirements of the employment position the individual holds or desires, and who can perform the essential functions of the position, with or without a reasonable accommodation. Additional information regarding the definition of a disability and exceptions to the definition of a disability is provided in Human Resources Letter 104, Employment of Individuals with Disabilities. POLICY It is the policy of the Company to provide equal employment opportunity to all qualified employees and applicants regardless of race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital status, or domestic partnership or civil union, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, liability for military service and status as a disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans and to comply with applicable federal, state, and local laws and regulations prohibiting discrimination in employment practices. This policy extends to all areas of employment practices including hiring, promotion, upgrading, benefits, pay, training, working conditions, employee treatment, and all other terms and conditions of employment and ensures that all employment decisions are based only on valid job requirements. (The Company’s Equal Employment Opportunity / Affirmative Action Policy is published as Human Resources Letter 101.) In addition, the Company has implemented policies prohibiting sexual harassment and harassment based on race, color, creed, religion, sex, gender, national origin, nationality, age, disability, ancestry, marital status, or domestic partnership or civil union, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, liability for military service or status as a disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. (The Company’s harassment policies are published as Human Resources Letters 102 and 103.) In furtherance of this policy, the Company has implemented an Affirmative Action Program for Minorities and Women (Human Resources Letter 105) in accordance with Executive Order 11246 and an Affirmative Action Program for Individuals with Disabilities, Disabled Veterans, Recently Separated Veterans, Active Duty Wartime or Campaign Badge Veterans, and Armed Forces Service Medal Veterans (Human Resources Letter 106), in accordance with Section 503 of the Rehabilitation Act of 1973, as amended, and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended. These programs state the methods by which the Company provides equal employment opportunity and takes affirmative action to employ and advance in employment qualified individuals with

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HUMAN RESOURCES LETTER 106 Issued March 24, 2014 disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. Employees and applicants shall not be subjected to harassment, intimidation, threats, coercion or discrimination because they have engaged in or may engage in any of the following activities: filing a complaint; assisting or participating in an investigation, compliance review, hearing, or any other activity related to the administration of applicable federal, state, or local laws requiring equal opportunity for individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans; opposing any act or practice made unlawful by such federal, state, or local laws; and exercising any other right protected by Section 503 of the Rehabilitation Act of 1973, as amended, or the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended, and the implementing regulations for these acts. All officers, managers, department heads, section heads, and others with responsibilities affecting or relating to employment opportunities, such as supervisors and local human resources representatives, are responsible for administering this policy within their respective areas. The Human Resources Department and, specifically, the Director, Employee Relations, Recruiting, and Compliance provide assistance and guidance wherever and whenever needed to assure that this policy is administered and is responsible for all necessary monitoring and reporting. REVIEW OF EMPLOYMENT PROCEDURES When new employment procedures and practices are implemented or existing procedures and practices are revised, the Company reviews these procedures and practices to ensure that the job qualifications of applicants and employees who have known disabilities or who are known to be disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans are carefully and thoroughly considered for job vacancies filled by hiring or promotion and are considered for offered or available training opportunities. When new employment procedures and practices are implemented or existing procedures and practices are revised, the Company reviews these procedures and practices to ensure that they do not stereotype individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans in a manner which limits such individuals’ access to jobs for which they are qualified. The Company’s employment application requests that those applicants with military service, including disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans provide information on their military duties and training that are relevant to the position for which they are applying so that this information may be considered as part of the applicants’ job-related qualifications.

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HUMAN RESOURCES LETTER 106 Issued March 24, 2014 PHYSICAL AND MENTAL QUALIFICATIONS When a new job is created or an existing job is reevaluated or when a job is posted in accordance with internal Company job posting systems, the physical and mental qualification standards for that job are reviewed to ensure that, to the extent that the qualification standards tend to screen out qualified individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans these qualifications are job-related for the position and are consistent with business necessity. Whenever physical or mental qualification standards are applied in the selection of applicants for hiring or the change in employees’ employment status for such reasons as promotion, demotion, or training, to the extent that qualification standards tend to screen out qualified individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans, the standards shall be related to the specific job or jobs for which the individual is being considered and consistent with business necessity. A qualification standard that may be used is the requirement that an individual must be able to perform the essential functions of the position held or desired with or without a reasonable accommodation and without posing a direct threat to the health or safety of the individual or others in the workplace. REASONABLE ACCOMMODATIONS FOR PHYSICAL AND MENTAL LIMITATIONS The Company shall make reasonable accommodations for the known physical or mental limitations of otherwise qualified individuals with disabilities and disabled veterans unless it can be demonstrated that such an accommodation would impose an undue hardship on the conduct of the Company’s business. A reasonable accommodation is a modification or adjustment to the work environment or to a job which permits an otherwise qualified applicant or employee with a disability or who is a disabled veteran to have equal opportunity in the employment process, to perform the essential functions of the job, and to receive equal benefits and privileges of employment. If a reasonable accommodation cannot be made in an employee’s current job without causing an undue hardship on the Company, the employee may be reassigned to an existing vacant position that the Company would fill for which the employee is qualified to perform with or without a reasonable accommodation. Additional information regarding reasonable accommodations is provided in Human Resources Letter 104, Employment of Individuals with Disabilities. Records regarding reasonable accommodations that are considered and/or made for individuals with disabilities or disabled veterans are maintained in the local human resources office in confidential files which are separate from the employees’ personnel files. If an employee with a known disability or an employee who is known to be a disabled veteran is having significant difficulty performing his or her job and it is reasonable to conclude that the performance problem may be related to the known disability, the local

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HUMAN RESOURCES LETTER 106 Issued March 24, 2014 human resources representative or the employee’s supervisor shall confidentially notify the employee of the performance problem and inquire whether the problem is related to the employee’s disability. If the employee states that the performance problem is related to his or her disability, the human resources representative or supervisor shall confidentially inquire whether the employee needs a reasonable accommodation and shall take the necessary action to make the reasonable accommodation. HARASSMENT POLICY The Company has implemented a policy prohibiting harassment of individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans which is published in Human Resources Letter 103. The policy defines the procedures for employees to report any incidents of harassment and provides for disciplinary action, up to and including discharge, for any employees who violate the policy. EXTERNAL DISSEMINATION OF POLICY, OUTREACH, AND POSITIVE RECRUITMENT The Company undertakes the following activities to recruit qualified individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans and to disseminate information regarding the equal employment opportunity / affirmative action policy and affirmative action program to external recruiting sources: • Lists with the state Employment Services Delivery System (EDS) the positions that will

be filled through external sources, with the exception of executive and top management positions. The listing of these positions will be done concurrently with the use of any other recruiting sources.

• Enlists the assistance and support of recruiting sources which represent the interests

of individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans, such as state employment services bureaus, state vocational rehabilitation agencies, local private rehabilitation agencies, and college placement officers, to refer qualified applicants. When appropriate, the Company holds formal briefing sessions with representatives from these recruiting sources to explain current and projected job openings, job descriptions and required qualifications, and the selection procedure and to establish procedures for the representatives of the recruiting sources to refer qualified applicants.

• Establishes contacts with organizations that serve and/or represent the interests of

individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans to seek advice and technical assistance regarding the placement of applicants and employees in appropriate jobs, training requirements, and reasonable accommodations that may be made.

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HUMAN RESOURCES LETTER 106 Issued March 24, 2014 • Includes a statement of the Company’s equal employment opportunity/affirmative

action policy in all contracts and purchase orders with vendors and suppliers. • Includes a statement of the Company’s equal employment opportunity/affirmative

action policy in all recruiting literature and in the Company’s employment application. • Includes the phase “An EEO/AA Employer - Min/Female/Disability/Vet” in all classified

advertisements for employment openings. INTERNAL DISSEMINATION OF POLICY The Company undertakes the following activities to disseminate information regarding the equal employment opportunity/affirmative action policy and affirmative action programs to employees: • Includes the equal employment opportunity / affirmative action policy and the

affirmative action programs in the Human Resources Letters which provide direction for the Company’s human resources procedures. The Human Resources Letters are distributed to management and supervisory personnel and copies are available in the departments for review by non-union employees.

• Posts a notice on bulletin boards in all Company locations informing employees about

the affirmative action programs. The notice also informs employees that the program is available for review and states the location and the hours during which they may request to review it.

• Distributes the equal employment opportunity/affirmative action statement of policy

annually to all employees. • Posts the equal employment opportunity/affirmative action statement of policy on

bulletin boards in all Company locations. • Includes in management and supervisory training programs information regarding the

equal employment opportunity/affirmative action policy, the affirmative action programs, and related policies, such as the harassment policies.

• Conducts meetings for management personnel to explain the intent of the equal

employment opportunity/affirmative action policy, the affirmative action programs, and related policies, such as the harassment policies, and to explain individual responsibility for effective implementation of these policies and program.

• Discusses the equal employment opportunity/affirmative action policy, the affirmative

action programs, and related policies, such as the harassment policies, in new employee orientation sessions and other employee meetings and explains the responsibility of the individual employee.

• Includes nondiscrimination clauses in all collective bargaining agreements.

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HUMAN RESOURCES LETTER 106 Issued March 24, 2014 • Includes articles and pictures of employees with disabilities and employees who are

disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans in Company publications, whenever articles and pictures of employees are used.

AUDIT AND REPORTING SYSTEM The Company’s various employment programs are reviewed on an on-going basis to determine the effectiveness of the affirmative action programs and to ensure that all programs are available to employees who are individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. Specific attention is given to the review of recruitment procedures, job qualifications, selection procedures, selection decisions, and reasonable accommodations to ensure that employment and promotional opportunities are available to all employees on a non-discriminatory basis. Effective remedial measures are taken if the review indicates deficiencies in any employment programs or procedures or in the availability or application of the programs or procedures with respect to employees who are individuals with disabilities, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. RESPONSIBILITY FOR IMPLEMENTATION All officers, managers, department heads, section heads, and others with responsibilities affecting or relating to employment opportunities, such as supervisors and local human resources representatives, are responsible for administering this policy within their respective areas. The Director, Employee Relations, Recruiting, and Compliance shall provide assistance and guidance wherever and whenever needed to assure that this policy is administered, and is responsible for all necessary monitoring and reporting. TRAINING All personnel who are involved in the recruitment, screening, selection, and promotion of employees and involved in other employment activities, such as discipline, are trained to ensure that their actions are in compliance with the Company’s equal employment opportunity / affirmative action policy and affirmative action programs. INVITATION TO SELF-IDENTIFY The Company invites all qualified applicants and employees who believe that they are covered by this affirmative action program and who wish to benefit from it to identify themselves and to provide information on any necessary accommodations for their disabilities. Applicants are invited to self-identify during the application process as permitted and required by federal regulations. New employees are invited to self-identify after the offer of employment has been made and they are informed that they may identify themselves at that time and/or at any time in the future. A permanent posting at all Company locations informs employees that they may identify themselves to benefit from the affirmative action

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HUMAN RESOURCES LETTER 106 Issued March 24, 2014 program and describes the procedure for them to follow to self-identify. The Company also invites its work force to self-identify as individuals with disabilities every five (5) years and in intervening intervals as permitted and required by federal regulations. Information about an employee’s status as an individual with a disability, disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans and any accommodations requested and/or made are maintained in the local human resources offices in confidential files which are separate from the employee’s personnel file. In addition, information about an employee’s status as a disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans is forwarded to the Human Resources Department and this information is maintained in employees’ computerized personnel files for required reporting to the federal government in the annual VETS-100 or VETS-100A Report. AVAILABILITY OF AFFIRMATIVE ACTION PROGRAM FOR REVIEW A permanent posting at all Company locations describes the Company’s affirmative action program and informs employees and applicants that the program is available for review. The location and hours during which the program may be obtained is included in the posting. CONFIDENTIALITY AND USE OF MEDICAL INFORMATION Information obtained under this program regarding the medical condition or history of any applicant or employee shall be collected and maintained on separate forms and in separate medical files and treated as a confidential medical record, except that supervisors and managers may be informed regarding necessary restrictions on the work or duties of the applicant or employee and necessary accommodations; first aid and safety personnel may be informed, when appropriate, if the disability might require emergency treatment; and government officials engaged in enforcing applicable laws shall be provided relevant information on request. RECORD RETENTION REQUIREMENTS Any personnel or employment record made or kept by the Company shall be preserved for a period of two years from the date that the record is made or the personnel action involving that record is taken, whichever occurs later, except records relating to Company recruiting and outreach self-assessment records which shall be kept for three (3) years from the time the self-assessment is recorded. Personnel and employment records include, but are not necessarily limited to, records relating to requests for reasonable accommodation, results of any physical examination, job advertisements and postings; applications and resumes; tests and test results, interview notes; and other records having to do with hiring, assignment, promotion, demotion, transfer, layoff or termination, rates of pay or other terms of compensation, and selection for training. In the case of involuntary termination of an employee, the personnel records of the individual terminated shall be kept for a period of two years from the date of the termination.

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HUMAN RESOURCES LETTER 106 Issued March 24, 2014 When the Company receives notice that a complaint or charge of discrimination has been filed, that a compliance review has been initiated, or that an enforcement action has commenced, all personnel records relevant to the complaint or charge, compliance review, or action shall be preserved until final disposition of the complaint or charge, compliance review, or action. In this context, personnel records relevant to the complaint or charge would include, for example, personnel or employment records relating to the individual who has filed the complaint or charge, to all other employees holding positions similar to that held or sought by this individual, and to all other unsuccessful candidates for the same positions. Personnel records relevant to a compliance review include all records for the past two years related to employment activity at the location undergoing the compliance review, such as records related to hiring, promotions, demotions or other job assignments, terminations, training, and accommodations for individuals with disabilities. INTERNAL COMPLAINT PROCEDURE The Company has implemented the Internal Discrimination Complaint Procedure which may be used by any employee who believes that he or she has been discriminated against on the basis of disability or status as a disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans. The employee may initiate this procedure by contacting their local human resources representative or the Director, Employee Relations, Recruiting, and Compliance. The Internal Discrimination Complaint Procedure is published as Human Resources Letter 107. CLARIFICATION Questions concerning the interpretation or administration of this policy should be referred to the local human resources representative or to the Director, Employee Relations, and Compliance in the Human Resources Department. This human resources policy is not a binding contract, but a set of guidelines for implementation. The Company explicitly reserves the right to modify any of the provisions of this policy any time and without notice.

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HUMAN RESOURCES LETTER 202 January 1, 2018

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HIRING PROCESS This policy supersedes and cancels Human Resources Letter 202 issued May 22, 2017. In the following sections of this Letter, the corporate Recruiter and the local HR Representative will be referred to collectively as the HR Representative. For the intent of this policy, a diverse candidate references a candidate self-identified in a protected class per HR Policy 101 (Equal Employment Opportunity / Affirmative Action Policy), and will apply throughout this policy. A diverse interview team is comprised of a non-homogenous group, with gender and/or race/ethnicity represented. PARTICIPATING COMPANIES The current list of FirstEnergy companies that are covered by the following policy letter is provided in the Human Resources Letter 011 entitled Participating Companies. INTERNAL JOB POSTING PROCESS Purpose The internal Job Posting Process has been implemented by FirstEnergy and its operating companies (“the Company”) to provide employees with career growth opportunities, notify employees of openings in professional, technical and administrative positions, and to provide a procedure by which qualified employees can apply for these openings. This Policy ensures that qualified candidates are selected in an expeditious manner, Company procedures and applicable employment laws are followed, and appropriate communication, documentation, and record-keeping occurs. Eligibility All regular full-time and part-time employees who have been in their current jobs for a minimum of one year are eligible to apply for positions posted on the FirstEnergy Today portal via the My Career Map>Map My Future career management application. The one-year job requirement does not include employees who have received a promotion in a regular line of progression within the same department. The one-year job requirement may be waived by the employee’s supervisor. Policy Except for the circumstances listed below, job openings will be posted after the appropriate approval process for professional, first-line supervisory, technical and administrative positions up to and including the level that is generally equivalent to most senior professional positions. Department heads are encouraged to post manager level openings. All manager and above open positions must be filled through the Manager and Above Selection Decision Process found on Manager Self Service (MSS), under “Hiring”. This includes all existing, modified, or new manager and above vacancies. A copy of this process will be provided to hiring managers who do not have access to MSS. Job openings may be filled without posting through the Job Posting Process under the following circumstances:

• When an employee would normally attain the position with increased competence and ability within a section or department, such as when an employee receives a promotion in a regular line of progression;

• When employees are available for transfer due to a reduction in work force or the reorganization or elimination of Company operations;


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• When an employee becomes disabled and unable to perform his or her current job but can fill some other position within his or her Company location;

• When there is an established need for persons with special skills and experiences that are available only outside the Company;

• When the specific job has been posted within the previous twelve-month period, the opening may be filled by a qualified candidate from the previous posting or from external sources if no qualified candidates exist from the previous posting; or,

• When it is determined that the best interests of the Company are served by selection without posting.

Job openings for professional, first-line supervisory, technical and administrative positions that are posted through the Job Posting Process in Map My Future will be available to employees at all Company locations (i.e., organization-wide). An employee who has applied for a posted position must notify his or her supervisor that he or she has applied for the position. An employee who does not meet the one-year job requirement as stated in the Eligibility section of this Letter must obtain the approval of his or her supervisor to waive the requirement before applying for the posted position. When an employee has expressed interest in a position through the application process, they may not be promoted in his/her department while the posting is still active. An employee who has been offered and/or accepted a position through the Job Posting Process will not be subsequently offered a promotion in his/her department. Only in cases where it is determined to be detrimental to operations can an employee’s supervisor decline to permit consideration of an eligible employee who has applied for a posted job which is at their current market rate. In such a case, the employee’s supervisor must contact the Manager of Recruiting to discuss impact and options. An employee who has accepted a job offer should be released for the new position within four weeks after accepting the new position. The release date of an employee who is required to complete a critical project may be delayed with the approval of both department heads. If the employee is not released within four weeks by the current department, the employee shall be paid the new salary (if higher) by the current department until the employee is released to the new department. PROCEDURE Selection Process Overview The selection process consists of a series of steps during which the HR Representative and the hiring manager consider relevant job-related information of the employees who applied for the posted jobs. The HR Representative will provide specific guidance to hiring manager for the selection, which includes an overview of the complete hiring process, interview guides, reviewing interviewing techniques, discussing use of any approved, additional selection tools, and working with the hiring manager to ensure a diverse interview team. Throughout the selection process, it is determined that some employees continue to the next steps in the process and other employees will be removed from further consideration. When making these decisions at key steps, the hiring manager will review with the HR Representative the basis for the decisions and ensure appropriate documentation. As agreed upon by the HR Representative and the hiring manager, the employees who have been removed from further consideration may be notified either following the step at which they are no longer being considered for the position or after the selection process.


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For jobs that have testing requirements to determine aptitudes, skills and abilities, the HR Representative will coordinate testing at the appropriate step in the selection process. Testing may occur at various points within the process; however, it is generally recommended that testing occur after initial screening of the candidates by HR or the hiring manager, prior to the interview. Detailed documentation should be maintained in Staff My Organization to explain the decisions made and the actions taken at each step of the selection procedure. Requisition To initiate the employment procedure, the hiring manager will contact his/her HR Representative from Corporate or local HR designated to support the requisition, to arrange a consultation meeting. During the consultation, the hiring manager and HR Representative will establish the position requirements, overall recruiting strategy, and responsibilities of the hiring manager and HR Representative. The hiring manager must complete a requisition online through My Career Map > Staff My Organization. The hiring manager will provide a summary of job duties, responsibilities, and qualifications required on the requisition. It is recommended the hiring manager refer to the requisition library on the Manager Self Service (MSS) page on the Portal. If necessary, the hiring manager may obtain copies of previous job descriptions for the same or similar position from the HR Representative. If the position is a new position for the business unit, the hiring manager must provide the job duties, responsibilities, and qualifications required to the Corporate Compensation department prior to submitting a requisition to establish a job title and market rate. The approved requisition will be sent electronically to the appropriate HR Representative to finalize the details of the position as discussed during the consultation meeting. For internal job postings, the HR Representative will prepare and publish the posting notice. Posting Notices A notice of the job openings will be posted for nine calendar days, and will be available via My Career Map > Map My Future. Employees without access to the online electronic postings can check designated bulletin boards to view current postings in Company buildings where they report. The local HR Representatives will determine the location and/or need of the bulletin boards in their Company locations. At times, it may be necessary to repost an internal job posting. Reposting occurs if no qualified applicants are found during the initial posting or if it is determined the level of work performed in the open position is higher or lower than indicated by the initial posting. Submitting an Employee Application Employees should apply online the via the FirstEnergy Today portal and My Career Map > Map My Future, by the posted deadline. Employees are encouraged to attach a resume and/or cover letter to their candidate profile and application. If access to a computer is not available, employees may obtain a copy of the posting from their local human resources office, complete form 490 and submit to the HR Representative listed on the posting before the posted deadline. Employees should notify their supervisor they have applied to a posted job. Employees who do not meet the one-year job requirement as stated in the Eligibility section of this Letter can submit an Employee Application for a posted job only if this requirement has been waived by their supervisor. Employee applications received after the posted deadline will not be accepted. Candidate Short-List After the job posting resume deadline has passed and the employee applications have been received, the HR Representative will review and submit a slate of employees who have met the minimum qualifications of the posted position to the hiring manager via the Short-List in Staff My Organization. The HR Representative


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will strive to provide a diverse candidate slate. The HR Representative will discuss questionable qualifications with the hiring manager to determine whether the candidate qualifies to be shortlisted. Hiring Manager Screening The hiring manager will screen the employee resumes and applications to determine those employees who meet the required qualifications and will notify the HR Representative of the results of this screening in preparation for the interviewing process. Detailed documentation should be maintained in Staff My Organization to explain the decisions made and the actions taken at each step of the selection procedure. The Candidate Profile within Staff My Organization provides the hiring manager with information relative to job history, education, training records, and other information from the employee’s Talent Profile. The hiring manager may also contact the employee‘s current and previous supervisors for references. After reviewing the information compiled (Employee Applications, Resumes, Candidate Profiles, and supervisor references), the hiring manager will determine the candidates to be interviewed. When possible and dependent upon the diversity of the candidate slate short-listed, the HR Representative will work with the hiring manager to include a diverse interview pool. The hiring manager will review the basis for the interview slate selections with the HR Representative and will document these reasons in Staff My Organization, with any additional detailed documentation, as appropriate. Employees who were not screened to move forward to the interviewing step will receive an email notification initiated by the HR Representative via Staff My Organization that they are not being considered for the position. Employee Interviews The HR Representative and the hiring manager will work together to arrange interviews as appropriate. The employee will notify his or her supervisor that an interview has been scheduled. Whenever possible, interviews should be conducted during regular business hours. An interview requiring extensive travel should be scheduled to minimize non-productive hours. If the interview requires extensive travel from an employee’s current residence and current reporting location, the employee will be eligible to be reimbursed for mileage, hotel, and meal expenses, if applicable. The HR Representative will provide guidance on interviewing, and assist in developing specific technical questions. The HR Representative will also work with the hiring manager to ensure a diverse interview team is used throughout the interviewing and selection process. Behavioral-based interviewing should be used, which includes consensus discussions to gain insights from the interviewing team. The hiring manager makes the final selection, with the input of the diverse interviewing team. Job Offer All selection documentation should be provided to the HR Representative coordinating the process or uploaded into Staff My Organization prior to the offer being made to the employee. The HR Representative will work with Compensation and the hiring manager to develop the salary recommendation for the employee in accordance with the Human Resources Letter 506 Promotions or Letter 508 Compensation Impacts on Employees. The HR Representative may be required to review this recommendation with Compensation and obtain approval prior to extension of the job offer. The hiring manager will notify the employee’s current supervisor that an offer will be made. The HR Representative and the hiring manager should jointly make the job offer to the employee, unless determined otherwise at the initial consultation meeting.


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If the job offer is accepted, the hiring manager will contact the employee’s supervisor to determine the employee’s transfer date into the new job and will confirm the details of the job offer, including job title, and salary. The hiring manager should contact the employees who were interviewed but not selected to provide coaching / feedback. All other employees who were not interviewed will receive a letter initiated by the HR Representative that they were not selected for the position. Documentation and Recordkeeping The hiring manager will review the candidate selection documentation interview notes to ensure that the documentation is complete. Interview notes, other documents compiled during the selection procedure, and any additional detailed documentation of the selection process should be uploaded into Staff My Organization or returned to the HR Representative in a timely manner. The HR Representative is responsible for reviewing the documentation for completeness in accordance with compliance requirements. All records will be maintained for six years from the date that the selection decision is made. EXTERNAL RECRUITMENT AND SELECTION Open positions which are classified as non-exempt (primarily physical and clerical in nature) may be filled through referrals from state employment offices and other agencies in the community. Notices of openings may be sent to various agencies, including those which are diversity-focused, to make their clientele aware of the openings as they occur. Advertisements may be placed in local publications and on the FirstEnergy website to increase the candidate pool. It is the Company’s expectation that any external hires will have acquired their high school diploma or GED equivalent. Open positions that are classified as exempt (professional in nature) must obtain required approval prior to external posting. Generally, applicants' resumes and employment applications are considered only for the specific vacant position for which they applied. However, a group of applicants recruited for a vacant position may be considered for other similar positions that occur within one year of the date the first position was advertised or posted for application, rather than recruiting a new group of applicants for each vacancy. For recordkeeping purposes, all resumes and applications are retained for a minimum of six years after a position is filled or longer if required. For Affirmative Action tracking purposes, all individuals who indicate interest in a specific position that FirstEnergy is acting to fill and who follow its procedures for submitting a resume/application for that position will be requested to voluntarily provide gender, race/ethnicity, veteran status, and disability information. Applicant statistics are compiled by position and are compiled prior to any selection screens being conducted. Not included in applicant data are individuals who submit unsolicited resumes, individuals who submit resumes through college recruiting or job fairs for potential future vacancies, and individuals whose resumes are viewed by recruiters on third-party resume banks, until these individuals indicate interest in a specific position that FirstEnergy is acting to fill and who follow its procedures for submitting a resume/application for that position. If individuals respond to FirstEnergy’s online postings intended to create pools of individuals interested in broad categories of jobs to be used for future vacancies, in accordance with the Internet Applicant Rule, criteria used to develop contacts when a specific vacancy occurs will be documented. When individuals are contacted about a specific vacancy and indicate interest in the specific position FirstEnergy is acting to fill,


Page 6 of 9

they must follow the procedures for submitting a resume/application for that position to be considered applicants. A request to voluntarily provide gender, race/ethnicity, veteran status, and disability information for Affirmative Action tracking purposes will be presented to the individuals. To begin the recruiting process, the HR Representative and the hiring manager will have a consultation meeting to establish roles and responsibilities, review the hiring process, and review any active applications that were previously submitted for similar openings and determine other sources for candidates. The HR Representative will notify appropriate agencies of the job vacancy, post the position on various websites, communicate to applicable professional organizations, trade associations, colleges, etc., ensuring diversity-focused channels are used throughout the publicizing process. Resumes and applications will be screened, and the candidates meeting minimum qualifications will be submitted to the hiring manager for review. The qualified candidate slate (short-list) will be diverse. The HR Representative shall screen applications and notify applicants of the following: testing, if applicable (request notification of necessary accommodation for the test); interview; or rejection, if screened out. The HR Representative shall coordinate appropriate testing of qualified applicants, if needed. The HR Representative shall reject applicants that do not meet test requirements, and coordinate interviews with those that meet test requirements. The HR Representative will work with the hiring manager to ensure a diverse interview slate. The hiring manager will review the basis for the decisions with the HR Representative and will document these reasons in Staff My Organization, with any additional detailed documentation, as appropriate. A diverse team made up of the hiring manager, department members, etc., will interview qualified candidates. Hiring managers can obtain further details and interview guides from their HR Representative. Behavioral-based interviewing should be used, which includes consensus discussions to gain insights from the interviewing team. Following the interview, the HR Representative shall review compensation and benefit programs, provide an overview of the Company, and answer any questions from the applicant. The hiring manager will review the decision with the HR Representative and document the reasons for the decision in Staff My Organization. The hiring manager should return all interview notes to the HR Representative coordinating the hiring process prior to an offer being extended. The HR Representative will verbally extend a job offer contingent upon satisfactory background verification, successful completion of a drug screen, and a pre-employment physical, if applicable, and inform the candidate of the date by which a response is expected. Upon acceptance of the offer, the HR Representative shall order the background verification and schedule a drug screen and, if appropriate, a pre-employment physical. If the results of the background verification, drug screen or physical are unsatisfactory, the offer may be rescinded. The HR Representative will coordinate preparation and mailing of an offer letter along with a new hire packet that identifies the required documents to bring to New Employee Orientation. Once the applicant accepts the offer and successfully passes a background check, drug test, and physical where appropriate, all other applicants will be notified that the position has been filled by another candidate. Employment of a Relative of an Employee of the Company The Employment Compliance Review Committee (ECRC), consisting of Corporate HR Directors and a Legal Department representative, must be notified prior to scheduling an interview for any internal or external applicant who is a relative of a current employee at the level of director or above including Board of Director members (see HR Policy 201 Employee Relationships). The Manager, Recruiting, will provide the Committee with copies of the job requisition and/or corresponding external posting, the candidate’s


Page 7 of 9

application and the applications of other candidates to be interviewed. Other information to be provided to the Manager, Recruiting, includes number of openings and selection criteria to determine interview list. The Manager, Recruiting, will provide a recommendation based upon review of all information provided. The Committee will review the recommendation and applicant information to ensure the qualifications are commensurate with the position and he/she can be considered for employment. The Committee will notify Manager, Recruiting, of its approval and then the normal procedure as outlined in this Letter may continue. Furthermore, prior to an offer being extended to a relative, the ECRC must approve the selection decision. The Manager, Recruiting, will provide the Committee with a summary of the hiring manager’s interview notes, selection decision criteria for all candidates considered, and the offer recommendation. The Committee will notify the Manager, Recruiting, of its approval. Upon receipt of this approval, the Manager, Recruiting, will notify the HR Representative, who will extend the employment offer. For the preceding two paragraphs, relative means either by blood, marriage or adoption, a spouse, parent, child, brother, sister, grandparent, grandchild, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, aunt, uncle niece, nephew, first cousin, and step relations of the preceding, or a person, other than a tenant or employee sharing the person’s household. Refer to Human Resources Letter 201 for additional information concerning employment of a relative of the Company. Eligibility Candidates must be eligible to work in the United States (U.S.) without sponsorship now or in the future. Eligibility is defined as U.S. citizenship, permanent resident of the U.S., possession of an Employment Authorization Document (EAD), or have asylum in the U.S. Background Verifications In accordance with Human Resources Policy Letter 210, the HR Representative will request background verifications for all candidates offered a position. The Company uses a consumer reporting agency to procure this information. All background checks will be performed in accordance with Federal, State and local laws, including the Fair Credit Reporting Act. The results of background checks are reported to Human Resources and are only disclosed to employees with a need for the information in performing their assigned duties. Pre-Employment Drug Screens and Physicals Once an applicant verbally accepts an offer of employment, the HR Representative coordinating the hiring process will arrange for a drug screen. In accordance with Human Resources Letter 402, all prospective employees who are applying for a job classified as “physical” will be required to pass a physical examination prior to employment. The Company also may require satisfactory completion of physical examinations in specific situations set forth in Human Resources Letter 402. All applicants are required to pass a drug screen as a condition of employment. Orientation to Company New hire orientation is held on the start of a pay period, typically twice per month. Orientation sessions are held at the Akron General Office, the Greensburg Corporate Center, the Fairmont facility, the Reading office or either of the JCP&L offices (Holmdel or Morristown). Travel arrangements are made for new hires to participate in a full day experience to learn more about the Company. New employees will also have pictures for their identification badges taken at this session. Additionally, the US Government requires all employers to verify eligibility to work for each person they hire by completing an I-9. All new hires and rehires are required to complete Section 1 of the I-9 no later than the first day of employment. The new hire orientation session facilitator or local HR Representative must examine the original document(s) to establish identity and work eligibility and complete Section 2 of the form within three business days of the date of hire. At times, it may be necessary for local HR to facilitate the on-boarding session at the primary Company location for that area when a centralized session is not available. The representative will coordinate the badging process,


Page 8 of 9

the I-9 process, their enrollment in various Company benefit programs and review pertinent Company information with them. Interview Recordkeeping Hiring managers are required to document the results of all interviews. For business units that have developed competency models, a structured interview guide provides areas to document the interview. Hiring managers should return all interview notes to the HR Representative coordinating the hiring process prior to an offer being extended. Human Resources will maintain application materials for all other interviewed candidates for six years or longer if required. Advertisements Human Resources pays for general advertising costs under normal circumstances. Advertising costs beyond what is customary are paid for by the hiring department, as mutually agreed upon. Referrals For exempt and non-exempt positions, potential candidates should be referred to firstenergycorp.com/careers website. An Employee Referral Bonus program is in place as needed for hard-to-fill openings. For a current list of positions eligible for a referral bonus, refer to the FirstEnergy Today portal, My Career Map. Refer to HR Policy 209 for details on the program. Unsolicited Resumes The Company does not encourage unsolicited resumes. Those interested in employment should be advised to create an online candidate profile and submit an application via the firstenergycorp.com/careers website. If unsolicited resumes are received by Human Resources Recruiting, individuals will be directed to the website for completion of a profile and an application for a specific position. College Recruitment The Corporate Recruiting staff maintains relationships with career placement offices and key faculty members at a variety of colleges and universities in a multi-state area. This includes attendance at career fairs sponsored by these colleges, utilizing the college resume referral systems, and conducting sessions to provide information about the Company or other career related topics. Departments are encouraged to assist in this effort, either financially or by attending events with an HR Representative. Refer to HR Policy 203 for more information on student related programs and opportunities. Professional Diversity Outreach The Corporate Recruiting staff and local Human Resources departments work in partnership with the Diversity & Inclusion team to build and maintain relationships with Diversity Organizations across our service territory. This may include attendance at events, supporting networking and development sessions, as well as sponsorship opportunities. Contact the Lead, Diversity & Inclusion in Corporate Human Resources for more information. Search Firms On occasion and after the internal Recruiting department has exhausted all avenues for sourcing candidates, the Company may utilize search firms to source experienced senior or executive level employees. Firms engaged will be expected to provide diverse candidate slates. The Manager, Recruiting, maintains relationships with preferred vendors who have executed contracts through the Supply Chain department. They must sign an agreement to supply a diverse set of candidates. The hiring department pays for all search firm fees. The Manager, Recruiting, will work with the hiring department to coordinate all search firm activities.


Page 9 of 9

CLARIFICATION Questions concerning the administration of this policy should be referred to the respective corporate HR Representatives for professional positions or the local HR Representative for nonexempt and administrative positions. Questions concerning the interpretation of this policy should be referred to the Manager, Recruiting, in the Human Resources Department. This Human Resources policy is not a binding contract, but a set of guidelines for implementation. The Company explicitly reserves the right to modify any of the provisions of this policy at any time and without notice.

Position Regarding Violence in the Workplace Human Resources Letter 412 Revised May 3, 2011 This policy supersedes and cancels Human Resources Letter 412 issued February 28, 2011 PARTICIPATING COMPANIES The FirstEnergy companies covered by this policy letter are included in Human Resources Letter 011 entitled Participating Companies. PURPOSE This policy states the position of FirstEnergy and its operating companies (“the Company”) on defining and prohibiting violence in its workplace and maintaining a safe, professional workplace for its employees and customers. ELIGIBILITY All employees are covered by this policy. POLICY It is the policy of the Company to provide a safe, professional workplace for its employees. Any acts or threats of violence, whether verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment, will not be tolerated. Further, anyone engaging in violent behavior will be subject to discipline, up to and including discharge, and may also be personally subject to other civil or criminal liabilities. For the purpose of this policy, violent behavior is defined as:

Physically harming, intimidating or threatening an individual, group of individuals, or relatives of those individuals.

Verbally harming by means of slandering, ridiculing or maligning an individual, group of individuals

or relatives of those individuals; name calling which is hurtful, insulting or humiliating; abusive and offensive remarks

The possession on Company property of weapons of any kind or the brandishing of any object that

could reasonably be perceived as a weapon. Loud, angry or disruptive behavior. Callous or intentional disregard for the physical safety or well being of others. Intentional destruction of Company or employee property. Committing a felony or misdemeanor on Company property. Any other conduct that a reasonable person would perceive as constituting a threat of violence.

The unauthorized possession of any deadly weapon, dangerous ordnance or substance on

Company property, Company functions, Company vehicles, personal vehicles used on Company business, or on an employee while conducting Company business.

Note: A State, Federal, or other license to carry a firearm, concealed or otherwise, does not constitute authorization to possess a firearm or other ordnance while on company property. Authorization to possess a weapon necessary for the performance of work or for any other reason must be obtained from the Manager of Physical Security prior to bringing the weapon onto company property. PROCEDURE Any employee who is subjected to, witnesses, or has knowledge of violent behavior of any of the types listed above, or has reason to believe that violent behavior may occur at or in connection with the activities of FirstEnergy is required to report it promptly to his or her supervisor and to the local human resources representative. Employees can raise concerns and make reports without fear of reprisal, and the Company will treat such reports as confidential to the extent circumstances permit. CLARIFICATION Questions concerning the interpretation or administration of this policy should be referred to the local human resources representative, Manager of Health & Safety in the Industrial Relations and Safety Department or the Manager of Physical Security. This policy is not a binding contract, but a set of guidelines for implementation. The Company explicitly reserves the right to modify any of the provisions of this policy at any time and without notice.

FirstEnergy Corporation EXECUTIVE ORDER 11246

AFFIRMATIVE ACTION PROGRAM

Plan Effective Date: 01/01/2017 Plan Expiration Date: 12/31/2017 AAP Administrator: Melisse Boyd Manager, Employee Relations Approved by: Mark Julian VP, Utility Operations Establishment’s Name: FirstEnergy Corporation

FE,FEUC - FirstEnergy, FirstEnergy Utilities Corporate Establishment’s Address: 76 South Main Street

Akron, OH 44308

FirstEnergy Corporation


for

EXECUTIVE ORDER 11246

CONFIDENTIAL TRADE SECRET MATERIALS

The material set forth in the AAP is deemed to constitute trade secrets, operations information,

confidential statistical data, and other confidential commercial and financial data, within the

meaning of the Freedom of Information Act, U.S.C. 552, Title VII of the Civil Rights Act of 1964 (as

amended), 42 U.S.C. 2000e et seq., the Trade Secrets Act, 18 U.S.C. 1905, and 44 U.S.C. 3508,

the disclosure of which is prohibited by law and would subject the individual making the disclosure

to criminal and/or civil sanctions.


EXECUTIVE ORDER 11246 AFFIRMATIVE ACTION PROGRAM

TABLE OF CONTENTS

Page

I. Establishment of Responsibilities for Implementation of the Written Affirmative Action Program (41 CFR 60-2.17(a)) 1

A. Designation of Responsibilities of AAP Administrator (41 CFR 60-2.17(a)) 1 B. The Responsibilities of the Company’s Management to Ensure Implementation

of the AAP (41 CFR 60-2.17(a)) 2

II. Identification of Problem Areas (41 CFR 60-2.17(b)) 3

III. Accomplishment of Prior Year Placement Goals 6

IV. The Development and Execution of Action-Oriented Programs (41 CFR 60-2.17(c)) 8

V. Internal Audit and Reporting Systems (41 CFR 60-2.17(d)) 10

1

I. Establishment of Responsibilities for Implementation of the Written Affirmative Action Program (41 CFR 60-2.17(a))

A. Designation of Responsibilities of AAP Administrator (41 CFR 60-2.17(a))

Melisse Boyd, the Manager, Employee Relations, has the primary management responsibility,

authority, and resources for ensuring full compliance with the provisions of E.O. 11246, as

amended, and with implementing all applicable regulations. The Manager, Employee

Relations’s appointment and a description of the position’s basic responsibilities have been

communicated to all levels of personnel in the company. The responsibilities of the Manager,

Employee Relations include, but are not necessarily limited to, the following:

1. Developing EEO policy statements, Affirmative Action Programs, and internal and

external communication procedures;

2. Assisting in the identification of AAP/EEO problems;

3. Assisting management in arriving at effective solutions to AAP/EEO problems;

4. Designing and implementing an internal audit and reporting system that:

a. Measures the effectiveness of the Affirmative Action Program;

b. Determines the degree to which AAP goals and objectives are met; and

c. Identifies the need for remedial action

5. Keeping company’s management informed of equal opportunity progress and reporting

potential problem areas within the company through reports;

6. Reviewing the company’s AAP for qualified minorities and women with all levels of

management to ensure that the policy is understood and is followed in all personnel

activities;

7. Auditing the contents of the company’s bulletin board to ensure compliance information

is posted and up-to-date; and

8. Serving as liaison between FirstEnergy Corporation and enforcement agencies.

2

B. The Responsibilities of the Company’s Management to Ensure Implementation of the AAP (41 CFR 60-2.17(a))

In implementing this written Affirmative Action Program, the responsibilities of the company’s

supervisors and managers working with the Manager, Employee Relations include, but are

not necessarily limited to, the following:

1. Assisting in the identification of problem areas, formulating solutions, and establishing

departmental goals and objectives when appropriate;

2. Reviewing the qualifications of all applicants and employees to ensure qualified

individuals are treated in a nondiscriminatory manner when hiring, promotion, transfer,

and termination actions occur; and

3. Reviewing the job performance of each employee to assess whether personnel actions

are justified based on the employee’s performance of his or her duties and

responsibilities.

3

II. Identification of Problem Areas (41 CFR 60-2.17(b)) FirstEnergy Corporation performs in-depth analysis of its total employment process to determine

if there are areas where minority and/or female groups may face impediments to equal

opportunity. The following analyses are conducted in order to reveal any potential problem areas:

1. Placement Goals: An analysis of incumbency versus availability is performed to

determine whether there are problems of minority and/or female utilization. Whenever

a problem exists, as defined by a statistical methodology, Placement Goals are set

(see the Placement Goals report which follows this section).

Whether there are Placement Goals or not, steps will be taken to encourage and

increase the percentage of qualified minorities and/or females applying for positions

both externally and internally. These steps may include, but are not limited to the

following:

• Working with hiring managers and recruiters to determine appropriate

outreach to attract qualified applicant pools;

• Recruiting at colleges and universities with a significant percentage of minority

and/or female students;

• Publishing job advertisements in newspapers and/or magazines that target

minorities and/or females;

• Offering mentorship programs for minority and/or female employees;

• Offering job training to minorities and/or females currently employed by the

company in order to increase their chances of advancement;

• Offering tuition reimbursement to employees to obtain training that will

increase their chances of advancement;

• Using recruitment companies that specifically target minorities and/or females;

and

• Continuing to use the services of the respective Employment Service Delivery

System.

4

2. Review of Employment Decisions: A review of employment decisions is made in

order to determine whether or not minorities and/or females are selected at a less

favorable rate than non-minorities and/or males. A review of non-minorities and/or

males is also conducted to determine if either group is being selected at a statistically

significant lessor rate than minorities and/or females.

3. Review of Hires/Promotions: Whenever minorities and/or females are selected at a

lower rate than non-minorities and/or males, a review of the applicant flow is

conducted to determine possible reasons why minorities and/or females were not

selected at a more favorable rate. If the company is attracting fewer than expected

minorities and/or females that fit the qualifications for the job groups, good faith efforts

will be put into place to attempt to improve the applicant flow of qualified minorities

and/or females. If non-minorities and/or males are selected at a statistically

significantly lessor rate than minorities and/or females, a review of the applicant flow

and selection decisions is also made to ensure that there is no evidence of

discrimination.

4. Review of Terminations: For terminations, if minorities and/or females are being

involuntarily terminated or are voluntarily leaving at a higher rate than non-minorities

and/or males, a review of the employee files will be made to ensure the company is

applying its policies and procedures for termination equally for protected as well as

non-protected classes. If non-minorities and/or males have a statistically significant

higher rate of termination than minorities and/or females, an investigation will also be

conducted to determine the cause.

5. Compensation: Compensation is reviewed at least annually in order to determine if

there are significant discrepancies in pay when comparing female to male rates of pay

and minority versus non-minority rates of pay. If discrepancies do exist, a thorough

review is conducted to determine if the difference in pay is justified due to appropriate

factors. If the difference in pay cannot be justified, FirstEnergy Corporation will put a

plan in place to bring pay into greater alignment.

5

Placement Goals Report

Plan: FE,FEUC - FirstEnergy, FirstEnergy Utilities Corporate Job Group Class Goal Placement Rate

% 0221 – Sr. Professional - Engineering Female 41.3% 0223 – Professional - Engineering Female 63.62% 0261 – Sr. Professional - Nuclear - Non-Eng Female 47.62% 0321 – Sr. Technician - Engineering Minority 7.59% 0535 – Meter Readers Female 26.08% 0620 – Entry Craft Female 13.86%

6

III. Accomplishment of Prior Year Placement Goals

Where goals were established for the prior year, the company developed action-oriented

programs designed to accomplish the established goals and objectives, thereby enhancing

employment and advancement opportunities in the company for minorities and/or females. The

results of the prior year’s Affirmative Action Program are identified on the Goal Attainment report.

7

Goal Attainment Report

Plan: FE,FEUC - FirstEnergy, FirstEnergy Utilities Corporate Job Group

Class Employees at plan

date #

Goal Placement Rate

%

Placemen

ts #

Actual Placement Rate

%

Goal Attained?

0221 – Sr. Professional - Engineering

97 18

Female 10 40.32% 1 5.55% No 0223 – Professional - Engineering

48 31

Female 1 66.69% 7 22.58% No 0231 – Sr. Professional - Business

211 40

Female 77 44.29% 19 47.5% Yes 0321 – Sr. Technician - Engineering

211 70

Minority 9 9.00% 2 2.85% No

8

IV. The Development and Execution of Action-Oriented Programs (41 CFR 60-2.17(c))

Programs have been instituted to ensure no barriers to employment exist. These programs may

include, but are not limited to, the following:

1. Conducting annual analyses of job descriptions to ensure they accurately reflect job

functions;

2. Making job descriptions available to recruiting sources and available to all members of

management involved in the recruiting, screening, selection and promotion processes;

3. Evaluating the total selection process to ensure freedom from bias through:

a. Reviewing job applications and other pre-employment forms to ensure information

requested is job-related;

b. Evaluating selection methods that may have a disparate impact to ensure that they

are job-related and consistent with business necessity;

c. Training personnel and management staff on proper interview and selection

procedures; and

d. Training on EEO and other related policies for management and supervisory staff.

4. Using techniques to improve recruitment and retention and to increase the flow of

qualified applicants, including minority and/or female applicants, FirstEnergy

Corporation undertakes the following actions:

a. Including the phrase “As an EEO/Affirmative Action Employer all qualified

applicants will receive consideration for employment without regard to race, color,

religion, sex, sexual orientation, gender identity, national origin, disability, veteran

status” or other acceptable tagline in all printed employment advertisements;

b. Placing employment advertisements in local minority news media and women’s

interest media;

c. Disseminating information on job opportunities to organizations representing

minorities and women and to employment development agencies when job

opportunities become available;

d. Encouraging all employees to refer qualified applicants;

e. Actively recruiting at secondary schools, junior colleges, colleges and universities

with predominantly minority and/or female enrollments; and

f. Requesting employment agencies to refer qualified minorities and women.

5. Reviewing company’s compensation practices;

6. Ensuring that all employees are given equal opportunity for promotions and/or transfers.

9

This is achieved by:

a. Posting opportunities internally;

b. Offering guidance to employees in identifying opportunities, training and

educational programs to enhance promotions and opportunities for job rotation or

transfer; and

c. Evaluating job requirements to ensure that they are appropriate.

10

V. Internal Audit and Reporting Systems (41 CFR 60-2.17(d))

The company believes that one of the most important elements in effectively implementing a

written Affirmative Action Program is an adequate internal audit and reporting system. Through

this system, the total program can be monitored for effectiveness, and management can be kept

informed. FirstEnergy Corporation’s audit and reporting system is designed to:

1. Measure the effectiveness of the AAP/EEO program;

2. Document and analyze personnel activities;

3. Identify problem areas and develop action plans where remedial action is needed; and

4. Determine the degree to which AAP goals and objectives have been attained.

The following personnel activities are reviewed, as necessary and desirable, to ensure

nondiscrimination and EEO for all individuals without regard to their race, color, gender, religion,

national origin, age, sex, sexual orientation, gender identity, pregnancy, genetic information,

disability, veteran status, or any other legally protected status covered by applicable state or local

law:

1. Recruitment, advertising, and job application procedures;

2. Hiring, promotion, upgrading, layoff, recall from layoff;

3. Rates of pay and any other forms of compensation including fringe benefits;

4. Job assignments, job classifications, job descriptions, and seniority lists;

5. Sick leave, leaves of absence, or any other leave;

6. Training, attendance at professional meetings and conferences; and

7. Any other term, condition, or privilege of employment.

The following documents may be maintained as a component of FirstEnergy Corporation’s

internal audit process:

1. An applicant flow log;

2. Summary data of external job offers and hires, promotions, terminations;

3. Summary data of applicant flow;

4. Employment applications; and

5. Records pertaining to company’s compensation system and decisions.

11

FirstEnergy Corporation’s audit system includes periodic review of employment decisions.

Managers and supervisors are asked to report any current or foreseeable EEO problem areas

and are asked to outline their suggestions/recommendations for solutions. If problem areas arise,

the manager or supervisor is to report problem areas immediately to the AAP Administrator.

During the reporting cycle, the following occurs:

1. The AAP Administrator will discuss any problems relating to substantial disparate

impact, EEO charges, etc., with management; and

2. The AAP Administrator will report the status of the company’s AAP goals and objectives

to management. The AAP Administrator will recommend remedial actions for the

effective implementation of the AAP.

OFFICE OF FEDERAL CONTRACT COMPLIANCE PROGRAMS (OFCCP)

AFFIRMATIVE ACTION PROGRAM (AAP) FOR SECTION 503 OF THE REHABILITATION ACT



Akron, OH 44308



for

INDIVIDUALS WITH DISABILITIES

CONFIDENTIAL TRADE SECRET MATERIALS The material set forth in the AAP is deemed to constitute trade secrets, operations information,


meaning of the Freedom of Information Act, U.S.C. 552, Title VII of the Civil Rights Act of 1964

(as amended), 42 U.S.C. 2000e et seq., the Trade Secrets Act, 18 U.S.C. 1905, and 44 U.S.C.

3508, the disclosure of which is prohibited by law and would subject the individual making the

disclosure to criminal and/or civil sanctions.


AFFIRMATIVE ACTION PROGRAM FOR INDIVIDUALS WITH DISABILITIES

TABLE OF CONTENTS

Page I. Equal Employment Opportunity (EEO) Policy Statement (41 CFR 60-741.44(a)) 1

II. Review of Personnel Processes (41 CFR 60-741.44(b)) 3

III. Review of Physical and Mental Job Qualification Standards (41 CFR 60-741.44(c)) 4

IV. Reasonable Accommodation to Physical and Mental Limitations (41 CFR 60-741.44(d)) 5

V. Anti-Harassment Procedures (41 CFR 60-741.44(e)) 6

VI. External Dissemination of Policy, Outreach, and Positive Recruitment (41 CFR 60-741.44(f)) 7

VII. Internal Dissemination of Policy (41 CFR 60-741.44(g)) 8

VIII. Audit and Reporting Systems (41 CFR 60-741.44(h)) 9

IX. Responsibility for Implementation (41 CFR 60-741.44(i)) 10

A. Responsibilities of EEO Coordinator: 10

B. Responsibilities of Managers and Supervisors: 11

X. Training (41 CFR 60-741.44(j)) 12

XI. Applicant and Hiring Data (41 CFR 60-741.44(k)) 13

XII. Utilization Analysis (41 CFR 60-741.45(d)) 14

XIII. Identification of Problem Areas and Action-oriented Programs (41 CFR 60-741.45(e) and (f)) 15

APPENDIX A – Outreach and Positive Recruitment Error! Bookmark not defined.

APPENDIX B – Self-Audit Error! Bookmark not defined.

APPENDIX C – Identification of Problem Areas and Action-Oriented Programs Error!

Bookmark not defined.

1

I. Equal Employment Opportunity (EEO) Policy Statement (41 CFR 60-741.44(a))

The EEO Policy Statement on the following page is posted on our company’s bulletin board

along with our required employment posters and is viewable by both employees and applicants.

The EEO is the Law poster is also posted on our company’s bulletin board as well as made

available electronically through our company website for viewing by online applicants.

2

FirstEnergy Corporation EQUAL EMPLOYMENT OPPORTUNITY POLICY STATEMENT

It is the policy of FirstEnergy Corporation not to discriminate against any employee or applicant for employment because of his or her race, color, religion, sex, sexual orientation, gender identity, national origin, or because he or she is an individual with a disability or disabled veteran, Armed Forces service medal veteran, recently separated veteran, or active duty wartime or campaign badge veteran, or thereinafter referred collectively as “protected veterans.” It is also the policy of FirstEnergy Corporation to take affirmative action to employ and to advance in employment, all persons regardless of their status as individuals with disabilities or protected veterans, and to base all employment decisions only on valid job requirements. This policy shall apply to all employment actions, including but not limited to recruitment, hiring, upgrading, promotion, transfer, demotion, layoff, recall, termination, rates of pay or other forms of compensation, and selection for training, including apprenticeship, at all levels of employment. Furthermore, the company will provide qualified applicants and employees who request an accommodation due to a disability with reasonable accommodations, as required by law.

FirstEnergy Corporation prohibits harassment of employees and applicants because they are individuals with disabilities or protected veterans. FirstEnergy Corporation also prohibits retaliation against employees and applicants for filing a complaint, opposing any discriminatory act or practice, assisting or participating in any manner in a review, investigation, or hearing or otherwise seeking to obtain their legal rights under any Federal, State, or local EEO law requiring equal employment opportunity for individuals with disabilities and protected veterans. Prohibited retaliation includes, but is not limited to, harassment, intimidation, threats, coercion or other adverse actions that might dissuade someone from asserting their rights.

As CEO of FirstEnergy Corporation, I am committed to the principles of affirmative action and equal employment opportunity. In order to ensure dissemination and implementation of equal employment opportunity and affirmative action throughout all levels of the company, I have selected Melisse Boyd as the Manager, Employee Relations for FirstEnergy Corporation. One of the Manager, Employee Relations’s duties will be to establish and maintain an internal audit and reporting system to allow for effective measurement of FirstEnergy Corporation’s programs.

In furtherance of FirstEnergy Corporation’s policy regarding affirmative action and equal employment opportunity, FirstEnergy Corporation has developed a written Affirmative Action Program (AAP) which sets forth the policies, practices and procedures that FirstEnergy Corporation is committed to in order to ensure that its policy of nondiscrimination and affirmative action for qualified individuals with disabilities and qualified protected veterans is accomplished. This AAP is available for inspection by any employee or applicant for employment upon request between 8:30AM to 5:30PM at the Human Resources department. Any questions should be directed to me, your supervisor, or Melisse Boyd, Manager, Employee Relations.

Charles E. Jones, Jr. CEO FirstEnergy Corporation 01/01/2017

3

II. Review of Personnel Processes (41 CFR 60-741.44(b))

FirstEnergy Corporation complies with the requirement to “periodically review” its personnel

processes by reviewing these processes annually to determine whether its present procedures

assure careful, thorough, and systematic consideration of the qualifications of known individuals

with disabilities. As part of this review, FirstEnergy Corporation also ensures that its personnel

processes do not stereotype individuals with disabilities in a manner which limits their access to

all jobs for which they are qualified. This review covers all procedures related to the filling of job

vacancies either by hire or by promotion, as well as to all training opportunities offered or made

available to employees.

The following is a set of procedures which may be used to meet the requirements of

§60-741.44(b):

1. Applicant records are maintained which indicate whether or not an applicant self-

identified as an individual with a disability. This information can be retrieved for review by

the Department of Labor and the contractor's personnel officials for use in investigations

and internal compliance activities.

2. Records are maintained which indicate employees considered for competitive

promotions within the organization. Employees are given the opportunity to voluntarily

self-identify disability status.

3. Records are maintained regarding training opportunities granted to employees which

include whether or not the employee has self-identified as an individual with a disability.

4. Any time a known applicant or employee with a disability is rejected for employment,

promotion, or training, the company prepares a statement outlining the reason.

5. Requests for accommodation due to a disability are maintained along with the nature of

the request and whether or not the accommodation was granted. If the accommodation

was denied, the company prepares a statement describing the reason for denying the

accommodation request. All accommodation records are treated as a confidential

medical record in accordance with §60-741(d).

4

III. Review of Physical and Mental Job Qualification Standards (41 CFR 60-741.44(c))

FirstEnergy Corporation reviews the physical and mental job qualification standards of each job

opening before it is publicly or internally posted to ensure that, to the extent that such

qualification requirements tend to screen out qualified individuals with disabilities, they are

related to the job(s) in question and consistent with business necessity and the safe

performance of the job. The physical and mental qualifications are also reviewed as new jobs

are established or job requirements are modified.

All job qualification requirements were found to be job related and consistent with business

necessity and safety. FirstEnergy Corporation will continue to review physical and mental job

qualification requirements whenever a job vacancy will be filled through either hiring or

promotion and will conduct a qualifications review whenever job duties change.

If FirstEnergy Corporation at any time should inquire into an applicant’s physical or mental

condition or should conduct a medical examination, such inquiries or exams will be conducted in

accordance with the Section 503 regulations and the information obtained as a result of the

inquiry or exam will be kept confidential, except as otherwise provided for in the Section 503

regulations. The results of the examination or inquiry will only be used in accordance with the

Section 503 regulations.

5

IV. Reasonable Accommodation to Physical and Mental Limitations (41 CFR 60-741.44(d))

FirstEnergy Corporation will continue its longstanding commitment to making reasonable

accommodation to the known physical or mental limitations of qualified individuals with

disabilities unless doing so would impose an undue hardship on the operation of its business.

The company also commits to engaging in an interactive process with the person requesting the

accommodation (or the person’s representative), as needed, to determine an appropriate

accommodation.

If an employee with a known disability has significant difficulty performing his or her job and it is

reasonable to conclude that the performance problem may be related to the known disability,

the manager or appropriate HR personnel will confidentially notify the employee of the

performance problem and inquire whether the problem is related to the employee's disability. If

the employee indicates that the performance problems are related to his or her disability, the

employee is asked if reasonable accommodation is needed.

In determining the extent of the company’s accommodation obligations, the following factors are

considered:

1. Business necessity; and

2. Financial cost and expense.

FirstEnergy Corporation will also ensure that all requests for reasonable accommodation and

any medical or disability-related information provided to FirstEnergy Corporation will be treated

as confidential medical records and maintained in a separate medical file.

6

V. Anti-Harassment Procedures (41 CFR 60-741.44(e))

Employees and applicants of FirstEnergy Corporation will not be subject to harassment because

of disability. Retaliation, including intimidation, threat, coercion, or discrimination, against an

employee or applicant because they have objected to discrimination, engaged or may engage in

filing a complaint, assisted in a review, investigation, or hearing or have otherwise sought to

obtain their legal rights under any Federal, State, or local EEO law regarding individuals with

disabilities is prohibited. Any employee or applicant who believes that he or she has been

subject to retaliation should promptly contact a manager in their chain of command, or promptly

contact the EEO Coordinator for assistance.

This policy is made available for employees and applicants to view. Furthermore, FirstEnergy

Corporation monitors its environment for the presence of any forms of harassment, intimidation,

or coercion and, where warranted, takes corrective action.

7

VI. External Dissemination of Policy, Outreach, and Positive Recruitment (41 CFR 60-741.44(f))

FirstEnergy Corporation undertakes appropriate outreach and positive recruitment efforts in

order to effectively attract individuals with disabilities. In order to comply with the external

dissemination of the EEO and Affirmative Action policy, the company provides written or

electronic notification to all current subcontractors, vendors, and suppliers and will continue to

do so on an annual basis. The company will also provide such notification to new

subcontractors, vendors, and suppliers upon entering into a relationship with them. FirstEnergy

Corporation has informed its recruiting sources, including State employment agencies and local

employment service delivery systems, of the company’s policy concerning the employment of

qualified individuals with disabilities and will notify them of employment opportunities as they

become available. FirstEnergy Corporation requested all recruiting sources to actively recruit

and refer qualified persons for job opportunities. FirstEnergy Corporation will include the equal

opportunity clause concerning the employment of qualified individuals with disabilities in all non-

exempt subcontracts and purchase orders. See Appendix A for detailed information regarding

our outreach and positive recruitment activities during the AAP year.

8

VII. Internal Dissemination of Policy (41 CFR 60-741.44(g))

FirstEnergy Corporation has developed internal procedures to communicate its obligation to

engage in affirmative action efforts to employ and advance in employment qualified individuals

with disabilities. Procedures are designed to foster understanding, acceptance, and support

among all employees and to encourage them to help FirstEnergy Corporation meet this

obligation.

The company realizes that an outreach program is ineffective without the adequate internal

support from management personnel and other employees. In order to ensure greater employee

cooperation and participation in the company’s affirmative action efforts, FirstEnergy

Corporation has adopted policies and engaged in activities which are not limited to the following:

1. Copy of our AAP for Individuals with Disabilities is available for inspection to any

employee or applicant upon request;

2. EEO Policy Statement and the EEO is the Law poster are placed on bulletin boards

located throughout our facilities and work areas;

3. Electronic versions of the EEO Policy Statement and the EEO is the Law poster are

clearly labeled and posted on the company’s intranet;

4. Meetings with executive, management, and supervisory personnel are held to explain

the intent of the policy and individual responsibility for effective implementation;

5. Managers and supervisors are provided with affirmative action and EEO training upon

commencement of their management roles;

6. Policy is discussed during employee orientation;

7. Union officials and/or employee representatives are informed of these policies;

8. When employees are featured in publications, individuals with disabilities are included

when available.

9

VIII. Audit and Reporting Systems (41 CFR 60-741.44(h))

The Manager, Employee Relations has the responsibility for the preparation and implementation

of the AAP. Responsibility for the effective implementation of the AAP is also vested with each

department manager and supervisor.

The following activities are reviewed at least annually to ensure freedom from discrimination

against, or stereotyping of, individuals with disabilities in any manner. The results of the most

recent self-audit are included in Appendix B. During the self-audit, the following activities are

reviewed:


2. Implementation of hiring, promotion, upgrading, award of tenure, layoff, and recall from

layoff;



5. Awarding of sick leave, leaves of absence, or implementation of any other leave

policies;

6. Participation in training, mentoring, or apprenticeship programs, and attendance at

professional meetings and conferences; and

7. Application of any other term, condition, or privilege of employment, including

participation in company-sponsored educational, training, recreational, and social

activities.

FirstEnergy Corporation’s audit system includes periodic reports provided by Manager,

Employee Relations documenting FirstEnergy Corporation’s efforts to achieve its EEO/AAP

responsibilities. Managers and supervisors are asked to report any current or foreseeable EEO

problem areas and are asked to outline their suggestions/recommendations for solutions.

The following documents are maintained as a component of FirstEnergy Corporation’s internal

audit process: documentation of self-audit; summary data of personnel activity including

external job offers and hires, promotions, resignations, terminations, and layoffs by job group

relating to individuals with disabilities; and an applicant flow log showing the name, race,

ethnicity, sex, disability status, veteran status, date of application, job title, and action taken for

all individuals applying for job opportunities.

10

IX. Responsibility for Implementation (41 CFR 60-741.44(i))

A. Responsibilities of EEO Coordinator:

Melisse Boyd, the Manager, Employee Relations, has been designated to direct the

activities of the affirmative action program. This person has the responsibility for ensuring

the effective implementation of the company’s AAP. These responsibilities include, but are

not limited to:

1. Implementing the AAP for individuals with disabilities, policy statements, personnel

policies and procedures, internal and external communication of the policy, and

monitoring the effectiveness of these actions;

2. Reviewing all personnel actions, policies, and procedures to ensure compliance with

FirstEnergy Corporation’s affirmative action obligations;

3. Assisting Human Resources department with reviewing the qualifications of all

applicants and employees considered/eligible for hiring, promotion, transfer, or

layoff/reduction in force to ensure qualified individuals with disabilities are treated in a

nondiscriminatory manner when hiring, promotion, transfer, or layoff/reduction in force

occur;

4. Assisting in the development of solutions for any identified problem areas;

5. Monitoring the effectiveness of the program on a continuing basis through the

development and implementation of an internal audit and reporting system that

measures the effectiveness of the program;

6. Keeping management informed of equal opportunity progress and problems within the

company through, at a minimum, periodic reports;

7. Providing department managers with a copy of the AAP for individuals with disabilities

and reviewing the program with them on an annual basis to ensure knowledge of their

responsibilities for implementation of the program;

8. Reviewing the company’s AAP for individuals with disabilities with all managers and

supervisors at all levels to ensure that the policy is understood and is followed in all

personnel activities;

9. Assisting in ensuring that career development of employees who are individuals with

disabilities is equal to that of other employees;

10. Auditing the contents of company bulletin boards to ensure that required information is

posted and up-to-date;

11

11. Serving as a liaison between FirstEnergy Corporation and enforcement agencies; and

12. Serving as a liaison between FirstEnergy Corporation and outreach and recruitment

sources for individuals with disabilities.

B. Responsibilities of Managers and Supervisors:

Managers and supervisors are advised annually of their responsibilities under the

company’s AAP for individuals with disabilities. These responsibilities include, but are not

limited to:

1. Reviewing the company’s affirmative action policy for individuals with disabilities with

subordinate managers and supervisors to ensure that they are aware of the policy and

understand their obligation to comply with it in all personnel actions;

2. Reviewing the qualifications of all applicants and employees to ensure individuals with

disabilities are treated in a nondiscriminatory manner when hiring, promotion, transfer,

or layoff/reduction in force occur; and

3. Reviewing all employees’ performance to ensure that non-discrimination is adhered to

in all personnel activities.

12

X. Training (41 CFR 60-741.44(j))

All personnel involved in the recruitment, screening, selection, promotion, disciplinary, and

related processes receive annual training regarding FirstEnergy Corporation’s AAP and their

role in its implementation. Employees hired or promoted into these roles also receive training on

regulatory requirements under Section 503 of the Rehabilitation Act soon after being hired or

placed into these roles.

During the annual training, personnel are advised of their responsibilities under the AAP for

individuals with disabilities and of their obligations to:

• Assist in the identification of problem areas, formulate solutions, and establish

departmental goals and objectives when necessary;

• Ensure qualified applicants and employees who are individuals with disabilities are

treated in a nondiscriminatory manner in all employment practices, including when

making selection decisions, such as for hire, promotion, training, or to receive awards

or bonuses:

• Provide reasonable accommodation to the known physical or mental limitations of

qualified individuals with disabilities unless such accommodation would impose an

undue hardship on the conduct of its business;

• Maintain confidentiality of any information regarding self-identification of individuals

with disabilities; and

• Ensure that nondiscrimination is adhered to in all personnel activities.

13

XI. Applicant and Hiring Data (41 CFR 60-741.44(k))

FirstEnergy Corporation collects employee data pertaining to individuals with disabilities in order

to assess the effectiveness of the company’s outreach and recruitment efforts. We invite

applicants to voluntarily inform the company whether they believe they are individuals with

disabilities in compliance with the Section 503 requirements. This data will be maintained for

three years.

14

XII. Utilization Analysis (41 CFR 60-741.45(d))

The utilization analysis is designed to evaluate the representation of individuals with disabilities

in each job group within the contractor's workforce with the 7 percent utilization goal established

by the OFCCP. The utilization goal is not a rigid and inflexible quota which must be met, nor is it

to be considered either a ceiling or a floor for the employment of particular groups. Quotas are

expressly forbidden.

15

XIII. Identification of Problem Areas and Action-oriented Programs (41 CFR 60-741.45(e) and (f))

When the percentage of individuals with disabilities in one or more job groups is less than the

utilization goal, the company takes steps to determine whether and where impediments to equal

employment opportunity exist. When making this determination, we assess personnel

processes, the effectiveness of the outreach and recruitment efforts, the results of our

affirmative action program audit, and any other areas that might affect the success of the

affirmative action program.

The company develops and executes action-oriented programs designed to correct any

identified problems areas. These action-oriented programs may include the modification of

personnel processes to ensure equal employment opportunity for individuals with disabilities,

alternative or additional outreach and recruitment efforts, and/or other actions designed to

correct the identified problem areas and attain the established goal. Appendix C documents

action-oriented programs FirstEnergy Corporation will implement to address any problem areas.


AFFIRMATIVE ACTION PROGRAM (AAP) FOR VEVRAA



Akron, OH 44308



for

PROTECTED VETERANS

CONFIDENTIAL TRADE SECRET MATERIALS The material set forth in the AAP is deemed to constitute trade secrets, operations information,







AFFIRMATIVE ACTION PROGRAM FOR PROTECTED VETERANS

TABLE OF CONTENTS

Page I. Equal Employment Opportunity (EEO) Policy Statement (41 CFR 60-300.44(a)) 1



IV. Reasonable Accommodation to Physical and Mental Limitations

(41 CFR 60-300.44(d)) 5


VI. External Dissemination of Policy, Outreach, and Positive Recruitment

(41 CFR 60-300.44(f)) 7






X. Training (41 CFR 60-300.44(j)) 12


XII. Hiring Benchmarks (41 CFR 60-300.45) 14


APPENDIX B – Self-Audit Error! Bookmark not defined.

1






2







3




assure careful, thorough, and systematic consideration of the qualifications of known protected

veterans. As part of this review, FirstEnergy Corporation also ensures that its personnel

processes do not stereotype protected veterans in a manner which limits their access to all jobs

for which they are qualified. This review covers all procedures related to the filling of job




§60-300.44(b):

1. Applicant records are maintained which indicate whether or not an applicant self-identified

as a protected veteran. This information can be retrieved for review by the Department of

Labor and the contractor's personnel officials for use in investigations and internal

compliance activities.

2. Records are maintained which indicate employees considered for competitive promotions

within the organization. Employees are given the opportunity to voluntarily self-identify

protected veteran status.


include whether or not the employee has self-identified as a protected veteran.

4. Any time a known protected veteran applicant or employee is rejected for employment,





accommodation request. All accommodation records are treated as a confidential medical

record in accordance with §60-300.23(d).

4




qualification requirements tend to screen out qualified disabled veterans, they are related to the

job(s) in question and consistent with business necessity and the safe performance of the job.

The physical and mental qualifications are also reviewed as new jobs are established or job

requirements are modified.







accordance with the VEVRAA regulations and the information obtained as a result of the inquiry

or exam will be kept confidential, except as otherwise provided for in the VEVRAA regulations.

The results of the examination or inquiry will only be used in accordance with the VEVRAA

regulations.

5



accommodation to the known physical or mental limitations of qualified disabled veterans unless

doing so would impose an undue hardship on the operation of its business. The company also

commits to engaging in an interactive process with the person requesting the accommodation

(or the person’s representative), as needed, to determine an appropriate accommodation.

If an employee who is known to be a qualified disabled veteran is having significant difficulty

performing his or her job and it is reasonable to conclude that the performance problem may be

related to the known disability, the manager or appropriate HR personnel will confidentially

notify the employee of the performance problem and inquire whether the problem is related to

the employee's disability. If the employee indicates that the performance problems are related to

his or her disability, the employee is asked if reasonable accommodation is needed.


considered:






6



of protected veteran status. Retaliation, including intimidation, threat, coercion, or discrimination,

against an employee or applicant because they have objected to discrimination, engaged or

may engage in filing a complaint, assisted in a review, investigation, or hearing or have

otherwise sought to obtain their legal rights under any Federal, State, or local EEO law

regarding protected veterans is prohibited. Any employee or applicant who believes that he or

she has been subject to retaliation should promptly contact a manager in their chain of

command, or promptly contact the EEO Coordinator for assistance.




7



order to effectively attract protected veterans. In order to comply with the external dissemination

of the EEO and Affirmative Action policy, the company provides written or electronic notification

to all current subcontractors, vendors, and suppliers and will continue to do so on an annual

basis. The company will also provide such notification to new subcontractors, vendors, and

suppliers upon entering into a relationship with them. FirstEnergy Corporation has informed its

recruiting sources, including State employment agencies and local employment service delivery

systems, of the company’s policy concerning the employment of qualified protected veterans

and will notify them of employment opportunities as they become available. FirstEnergy

Corporation requested all recruiting sources to actively recruit and refer qualified persons for job

opportunities. FirstEnergy Corporation will include the equal opportunity clause concerning the

employment of qualified protected veterans in all non-exempt subcontracts and purchase

orders. See Appendix A for detailed information regarding our outreach and positive recruitment

activities during the AAP year.

8



engage in affirmative action efforts to employ and advance in employment qualified protected

veterans. Procedures are designed to foster understanding, acceptance, and support among all

employees and to encourage them to help FirstEnergy Corporation meet this obligation.





1. Copy of our AAP for Protected Veterans is available for inspection to any employee or

applicant upon request;











8. When employees are featured in publications, protected veterans are included when

available.

9






against, or stereotyping of, protected veterans in any manner. The results of the most recent

self-audit are included in Appendix B. During the self-audit, the following activities are reviewed:


2. Implementation of hiring, promotion, upgrading, award of tenure, layoff, and recall

from layoff;




policies;





activities.


Employee Relations documenting any efforts to achieve its EEO/AAP responsibilities. Managers

and supervisors are asked to report any current or foreseeable EEO problem areas and are

asked to outline their suggestions/recommendations for solutions.




relating to protected veterans; and an applicant flow log showing the name, race, ethnicity, sex,

disability status, veteran status, date of application, job title, and action taken for all individuals

applying for job opportunities.

10






not limited to:

1. Implementing the AAP for protected veterans, policy statements, personnel policies

and procedures, internal and external communication of the policy, and monitoring

the effectiveness of these actions;

2. Reviewing all personnel actions, policies, and procedures to ensure compliance

with FirstEnergy Corporation’s affirmative action obligations;



layoff/reduction in force to ensure qualified protected veterans are treated in a

nondiscriminatory manner when hiring, promotion, transfer, or layoff/reduction in

force occur;





6. Keeping management informed of equal opportunity progress and problems within

the company through, at a minimum, periodic reports;

7. Providing department managers with a copy of the AAP for protected veterans and

reviewing the program with them on an annual basis to ensure knowledge of their


8. Reviewing the company’s AAP for protected veterans with all managers and



9. Assisting in ensuring that career development of employees who are protected

veterans is equal to that of other employees;

10. Auditing the contents of company bulletin boards to ensure that required

information is posted and up-to-date;

11

11. Serving as a liaison between FirstEnergy Corporation and enforcement agencies;

and

12. Serving as a liaison between FirstEnergy Corporation and outreach and

recruitment sources for protected veterans.



company’s AAP for protected veterans. These responsibilities include, but are not limited to:

1. Reviewing the company’s affirmative action policy for protected veterans with

subordinate managers and supervisors to ensure that they are aware of the policy

and understand their obligation to comply with it in all personnel actions;


individuals are treated in a nondiscriminatory manner when hiring, promotion,

transfer, or layoff/reduction in force occur; and

3. Reviewing all employees’ performance to ensure that non-discrimination is

adhered to in all personnel activities.

12

X. Training (41 CFR 60-300.44(j))




regulatory requirements under Vietnam Era Veterans’ Readjustment Assistance Act soon after

being hired or placed into these roles.


protected veterans and of their obligations to:



• Ensure qualified applicants and employees who are protected veterans are treated

in a nondiscriminatory manner in all employment practices, including when making

selection decisions, such as for hire, promotion, training, or to receive awards or

bonuses:


qualified disabled veterans unless such accommodation would impose an undue

hardship on the conduct of its business;

• Maintain confidentiality of any information regarding self-identification of protected

veteran status; and


13


FirstEnergy Corporation collects employee data pertaining to protected veterans in order to

assess the effectiveness of the company’s outreach and recruitment efforts. We invite

applicants to voluntarily inform the company whether they believe they are protected veterans in

compliance with the VEVRAA requirements. This data will be maintained for three years.

14

XII. Hiring Benchmarks (41 CFR 60-300.45)

FirstEnergy Corporation has adopted the national percentage of veterans in the civilian labor

force provided by OFCCP as its hiring benchmark for the AAP year. This benchmark is used as

one of the criteria in its assessment of the effectiveness of its outreach and recruitment efforts.

FirstEnergy Corporation EXECUTIVE ORDER 11246



FE,FEUROC - FirstEnergy, FirstEnergy Utilities Regional Operating Companies

Establishment’s Address: 76 South Main Street

Akron, OH 44308



for

EXECUTIVE ORDER 11246




meaning of the Freedom of Information Act, U.S.C. 552, Title VII of the Civil Rights Act of 1964 (as

amended), 42 U.S.C. 2000e et seq., the Trade Secrets Act, 18 U.S.C. 1905, and 44 U.S.C. 3508,

the disclosure of which is prohibited by law and would subject the individual making the disclosure

to criminal and/or civil sanctions.


EXECUTIVE ORDER 11246 AFFIRMATIVE ACTION PROGRAM

TABLE OF CONTENTS

Page

I. Establishment of Responsibilities for Implementation of the Written Affirmative Action Program (41 CFR 60-2.17(a)) 1

A. Designation of Responsibilities of AAP Administrator (41 CFR 60-2.17(a)) 1

B. The Responsibilities of the Company’s Management to Ensure Implementation of the AAP (41 CFR 60-2.17(a)) 2

II. Identification of Problem Areas (41 CFR 60-2.17(b)) 3

III. Accomplishment of Prior Year Placement Goals 6

IV. The Development and Execution of Action-Oriented Programs (41 CFR 60-2.17(c)) 8

V. Internal Audit and Reporting Systems (41 CFR 60-2.17(d)) 10

1

I. Establishment of Responsibilities for Implementation of the Written Affirmative Action Program (41 CFR 60-2.17(a))

A. Designation of Responsibilities of AAP Administrator (41 CFR 60-2.17(a))

Melisse Boyd, the Manager, Employee Relations, has the primary management responsibility,

authority, and resources for ensuring full compliance with the provisions of E.O. 11246, as

amended, and with implementing all applicable regulations. The Manager, Employee

Relations’s appointment and a description of the position’s basic responsibilities have been

communicated to all levels of personnel in the company. The responsibilities of the Manager,

Employee Relations include, but are not necessarily limited to, the following:

1. Developing EEO policy statements, Affirmative Action Programs, and internal and

external communication procedures;

2. Assisting in the identification of AAP/EEO problems;

3. Assisting management in arriving at effective solutions to AAP/EEO problems;

4. Designing and implementing an internal audit and reporting system that:

a. Measures the effectiveness of the Affirmative Action Program;

b. Determines the degree to which AAP goals and objectives are met; and

c. Identifies the need for remedial action

5. Keeping company’s management informed of equal opportunity progress and reporting

potential problem areas within the company through reports;

6. Reviewing the company’s AAP for qualified minorities and women with all levels of

management to ensure that the policy is understood and is followed in all personnel

activities;

7. Auditing the contents of the company’s bulletin board to ensure compliance information

is posted and up-to-date; and

8. Serving as liaison between FirstEnergy Corporation and enforcement agencies.

2

B. The Responsibilities of the Company’s Management to Ensure Implementation of the AAP (41 CFR 60-2.17(a))

In implementing this written Affirmative Action Program, the responsibilities of the company’s

supervisors and managers working with the Manager, Employee Relations include, but are

not necessarily limited to, the following:

1. Assisting in the identification of problem areas, formulating solutions, and establishing

departmental goals and objectives when appropriate;


individuals are treated in a nondiscriminatory manner when hiring, promotion, transfer,

and termination actions occur; and

3. Reviewing the job performance of each employee to assess whether personnel actions

are justified based on the employee’s performance of his or her duties and

responsibilities.

3

II. Identification of Problem Areas (41 CFR 60-2.17(b)) FirstEnergy Corporation performs in-depth analysis of its total employment process to determine

if there are areas where minority and/or female groups may face impediments to equal

opportunity. The following analyses are conducted in order to reveal any potential problem areas:

1. Placement Goals: An analysis of incumbency versus availability is performed to

determine whether there are problems of minority and/or female utilization. Whenever

a problem exists, as defined by a statistical methodology, Placement Goals are set

(see the Placement Goals report which follows this section).

Whether there are Placement Goals or not, steps will be taken to encourage and

increase the percentage of qualified minorities and/or females applying for positions

both externally and internally. These steps may include, but are not limited to the

following:

• Working with hiring managers and recruiters to determine appropriate

outreach to attract qualified applicant pools;

• Recruiting at colleges and universities with a significant percentage of minority

and/or female students;

• Publishing job advertisements in newspapers and/or magazines that target

minorities and/or females;

• Offering mentorship programs for minority and/or female employees;

• Offering job training to minorities and/or females currently employed by the

company in order to increase their chances of advancement;

• Offering tuition reimbursement to employees to obtain training that will

increase their chances of advancement;

• Using recruitment companies that specifically target minorities and/or females;

and

• Continuing to use the services of the respective Employment Service Delivery

System.

4

2. Review of Employment Decisions: A review of employment decisions is made in

order to determine whether or not minorities and/or females are selected at a less

favorable rate than non-minorities and/or males. A review of non-minorities and/or

males is also conducted to determine if either group is being selected at a statistically

significant lessor rate than minorities and/or females.

3. Review of Hires/Promotions: Whenever minorities and/or females are selected at a

lower rate than non-minorities and/or males, a review of the applicant flow is

conducted to determine possible reasons why minorities and/or females were not

selected at a more favorable rate. If the company is attracting fewer than expected

minorities and/or females that fit the qualifications for the job groups, good faith efforts

will be put into place to attempt to improve the applicant flow of qualified minorities

and/or females. If non-minorities and/or males are selected at a statistically

significantly lessor rate than minorities and/or females, a review of the applicant flow

and selection decisions is also made to ensure that there is no evidence of

discrimination.

4. Review of Terminations: For terminations, if minorities and/or females are being

involuntarily terminated or are voluntarily leaving at a higher rate than non-minorities

and/or males, a review of the employee files will be made to ensure the company is

applying its policies and procedures for termination equally for protected as well as

non-protected classes. If non-minorities and/or males have a statistically significant

higher rate of termination than minorities and/or females, an investigation will also be

conducted to determine the cause.

5. Compensation: Compensation is reviewed at least annually in order to determine if

there are significant discrepancies in pay when comparing female to male rates of pay

and minority versus non-minority rates of pay. If discrepancies do exist, a thorough

review is conducted to determine if the difference in pay is justified due to appropriate

factors. If the difference in pay cannot be justified, FirstEnergy Corporation will put a

plan in place to bring pay into greater alignment.

5

Placement Goals Report

Plan: FE,FEUROC - FirstEnergy, FirstEnergy Utilities Regional Operating Companies Job Group Class Goal Placement Rate

% 0121 – Managers Female 17.25% 0221 – Sr. Professional - Engineering Female 27.37% 0223 – Professional - Engineering Female 44.28% 0331 – Sr. Technician - Other Female 20.04% Minority 11.5% 0333 – Technician - Other Female 36.43% 0535 – Meter Readers Female 19.87% Minority 16.49% 0610 – Sr. Craft Female 1.22% 0620 – Entry Craft Female 7.96%

6

III. Accomplishment of Prior Year Placement Goals

Where goals were established for the prior year, the company developed action-oriented

programs designed to accomplish the established goals and objectives, thereby enhancing

employment and advancement opportunities in the company for minorities and/or females. The

results of the prior year’s Affirmative Action Program are identified on the Goal Attainment report.

7

Goal Attainment Report

Plan: FE,FEUROC - FirstEnergy, FirstEnergy Utilities Regional Operating Companies Job Group

Class Employees at plan

date #

Goal Placement Rate

%

Placemen

ts #

Actual Placement Rate

%

Goal Attained?

0221 – Sr. Professional - Engineering

109 3

Female 12 26.28% 0 0% No 0223 – Professional - Engineering

14 5

Female 0 56.84% 2 40% No 0331 – Sr. Technician - Other 61 10 Female 5 20.83% 0 0% No 0333 – Technician - Other 485 101 Female 142 48.08% 28 27.72% No Minority 37 13.35% 10 9.9% No 0535 – Meter Readers 615 252 Minority 35 14.96% 18 7.14% No 0610 – Sr. Craft 3130 368 Female 27 2.73% 2 0.54% No Minority 236 9.30% 18 4.89% No 0710 – Operatives 224 29 Female 16 25.18% 6 20.68% No

8

IV. The Development and Execution of Action-Oriented Programs (41 CFR 60-2.17(c))

Programs have been instituted to ensure no barriers to employment exist. These programs may

include, but are not limited to, the following:

1. Conducting annual analyses of job descriptions to ensure they accurately reflect job

functions;

2. Making job descriptions available to recruiting sources and available to all members of

management involved in the recruiting, screening, selection and promotion processes;

3. Evaluating the total selection process to ensure freedom from bias through:

a. Reviewing job applications and other pre-employment forms to ensure information

requested is job-related;

b. Evaluating selection methods that may have a disparate impact to ensure that they

are job-related and consistent with business necessity;

c. Training personnel and management staff on proper interview and selection

procedures; and

d. Training on EEO and other related policies for management and supervisory staff.

4. Using techniques to improve recruitment and retention and to increase the flow of

qualified applicants, including minority and/or female applicants, FirstEnergy

Corporation undertakes the following actions:

a. Including the phrase “As an EEO/Affirmative Action Employer all qualified

applicants will receive consideration for employment without regard to race, color,

religion, sex, sexual orientation, gender identity, national origin, disability, veteran

status” or other acceptable tagline in all printed employment advertisements;

b. Placing employment advertisements in local minority news media and women’s

interest media;

c. Disseminating information on job opportunities to organizations representing

minorities and women and to employment development agencies when job

opportunities become available;

d. Encouraging all employees to refer qualified applicants;

e. Actively recruiting at secondary schools, junior colleges, colleges and universities

with predominantly minority and/or female enrollments; and

f. Requesting employment agencies to refer qualified minorities and women.

5. Reviewing company’s compensation practices;

6. Ensuring that all employees are given equal opportunity for promotions and/or transfers.

9

This is achieved by:

a. Posting opportunities internally;

b. Offering guidance to employees in identifying opportunities, training and

educational programs to enhance promotions and opportunities for job rotation or

transfer; and

c. Evaluating job requirements to ensure that they are appropriate.

10

V. Internal Audit and Reporting Systems (41 CFR 60-2.17(d))

The company believes that one of the most important elements in effectively implementing a

written Affirmative Action Program is an adequate internal audit and reporting system. Through

this system, the total program can be monitored for effectiveness, and management can be kept

informed. FirstEnergy Corporation’s audit and reporting system is designed to:

1. Measure the effectiveness of the AAP/EEO program;

2. Document and analyze personnel activities;

3. Identify problem areas and develop action plans where remedial action is needed; and

4. Determine the degree to which AAP goals and objectives have been attained.

The following personnel activities are reviewed, as necessary and desirable, to ensure

nondiscrimination and EEO for all individuals without regard to their race, color, gender, religion,

national origin, age, sex, sexual orientation, gender identity, pregnancy, genetic information,

disability, veteran status, or any other legally protected status covered by applicable state or local

law:


2. Hiring, promotion, upgrading, layoff, recall from layoff;



5. Sick leave, leaves of absence, or any other leave;

6. Training, attendance at professional meetings and conferences; and

7. Any other term, condition, or privilege of employment.

The following documents may be maintained as a component of FirstEnergy Corporation’s

internal audit process:

1. An applicant flow log;

2. Summary data of external job offers and hires, promotions, terminations;

3. Summary data of applicant flow;

4. Employment applications; and

5. Records pertaining to company’s compensation system and decisions.

11

FirstEnergy Corporation’s audit system includes periodic review of employment decisions.

Managers and supervisors are asked to report any current or foreseeable EEO problem areas

and are asked to outline their suggestions/recommendations for solutions. If problem areas arise,

the manager or supervisor is to report problem areas immediately to the AAP Administrator.

During the reporting cycle, the following occurs:

1. The AAP Administrator will discuss any problems relating to substantial disparate

impact, EEO charges, etc., with management; and

2. The AAP Administrator will report the status of the company’s AAP goals and objectives

to management. The AAP Administrator will recommend remedial actions for the

effective implementation of the AAP.


AFFIRMATIVE ACTION PROGRAM (AAP) FOR SECTION 503 OF THE REHABILITATION ACT




Akron, OH 44308



for

INDIVIDUALS WITH DISABILITIES


AFFIRMATIVE ACTION PROGRAM FOR INDIVIDUALS WITH DISABILITIES

TABLE OF CONTENTS

Page

I. Equal Employment Opportunity (EEO) Policy Statement (41 CFR 60-741.44(a)) 1




(41 CFR 60-741.44(d)) 5



(41 CFR 60-741.44(f)) 7






X. Training (41 CFR 60-741.44(j)) 12


XII. Utilization Analysis (41 CFR 60-741.45(d)) 14

XIII. Identification of Problem Areas and Action-oriented Programs (41 CFR 60-741.45(e)

and (f)) 15


1






2







3




assure careful, thorough, and systematic consideration of the qualifications of known individuals

with disabilities. As part of this review, FirstEnergy Corporation also ensures that its personnel

processes do not stereotype individuals with disabilities in a manner which limits their access to

all jobs for which they are qualified. This review covers all procedures related to the filling of job




§60-741.44(b):

1. Applicant records are maintained which indicate whether or not an applicant self-

identified as an individual with a disability. This information can be retrieved for review by

the Department of Labor and the contractor's personnel officials for use in investigations

and internal compliance activities.

2. Records are maintained which indicate employees considered for competitive

promotions within the organization. Employees are given the opportunity to voluntarily

self-identify disability status.


include whether or not the employee has self-identified as an individual with a disability.

4. Any time a known applicant or employee with a disability is rejected for employment,





accommodation request. All accommodation records are treated as a confidential

medical record in accordance with §60-741(d).

4




qualification requirements tend to screen out qualified individuals with disabilities, they are

related to the job(s) in question and consistent with business necessity and the safe

performance of the job. The physical and mental qualifications are also reviewed as new jobs

are established or job requirements are modified.







accordance with the Section 503 regulations and the information obtained as a result of the

inquiry or exam will be kept confidential, except as otherwise provided for in the Section 503

regulations. The results of the examination or inquiry will only be used in accordance with the

Section 503 regulations.

5



accommodation to the known physical or mental limitations of qualified individuals with

disabilities unless doing so would impose an undue hardship on the operation of its business.

The company also commits to engaging in an interactive process with the person requesting the

accommodation (or the person’s representative), as needed, to determine an appropriate

accommodation.

If an employee with a known disability has significant difficulty performing his or her job and it is

reasonable to conclude that the performance problem may be related to the known disability,

the manager or appropriate HR personnel will confidentially notify the employee of the

performance problem and inquire whether the problem is related to the employee's disability. If

the employee indicates that the performance problems are related to his or her disability, the

employee is asked if reasonable accommodation is needed.


considered:






6



of disability. Retaliation, including intimidation, threat, coercion, or discrimination, against an

employee or applicant because they have objected to discrimination, engaged or may engage in

filing a complaint, assisted in a review, investigation, or hearing or have otherwise sought to

obtain their legal rights under any Federal, State, or local EEO law regarding individuals with

disabilities is prohibited. Any employee or applicant who believes that he or she has been

subject to retaliation should promptly contact a manager in their chain of command, or promptly

contact the EEO Coordinator for assistance.




7



order to effectively attract individuals with disabilities. In order to comply with the external

dissemination of the EEO and Affirmative Action policy, the company provides written or

electronic notification to all current subcontractors, vendors, and suppliers and will continue to

do so on an annual basis. The company will also provide such notification to new

subcontractors, vendors, and suppliers upon entering into a relationship with them. FirstEnergy

Corporation has informed its recruiting sources, including State employment agencies and local

employment service delivery systems, of the company’s policy concerning the employment of

qualified individuals with disabilities and will notify them of employment opportunities as they

become available. FirstEnergy Corporation requested all recruiting sources to actively recruit

and refer qualified persons for job opportunities. FirstEnergy Corporation will include the equal

opportunity clause concerning the employment of qualified individuals with disabilities in all non-

exempt subcontracts and purchase orders. See Appendix A for detailed information regarding

our outreach and positive recruitment activities during the AAP year.

8



engage in affirmative action efforts to employ and advance in employment qualified individuals

with disabilities. Procedures are designed to foster understanding, acceptance, and support

among all employees and to encourage them to help FirstEnergy Corporation meet this

obligation.





1. Copy of our AAP for Individuals with Disabilities is available for inspection to any

employee or applicant upon request;











8. When employees are featured in publications, individuals with disabilities are included

when available.

9






against, or stereotyping of, individuals with disabilities in any manner. The results of the most

recent self-audit are included in Appendix B. During the self-audit, the following activities are

reviewed:


2. Implementation of hiring, promotion, upgrading, award of tenure, layoff, and recall from

layoff;




policies;





activities.


Employee Relations documenting FirstEnergy Corporation’s efforts to achieve its EEO/AAP

responsibilities. Managers and supervisors are asked to report any current or foreseeable EEO

problem areas and are asked to outline their suggestions/recommendations for solutions.




relating to individuals with disabilities; and an applicant flow log showing the name, race,

ethnicity, sex, disability status, veteran status, date of application, job title, and action taken for

all individuals applying for job opportunities.

10






not limited to:

1. Implementing the AAP for individuals with disabilities, policy statements, personnel

policies and procedures, internal and external communication of the policy, and

monitoring the effectiveness of these actions;

2. Reviewing all personnel actions, policies, and procedures to ensure compliance with

FirstEnergy Corporation’s affirmative action obligations;



layoff/reduction in force to ensure qualified individuals with disabilities are treated in a

nondiscriminatory manner when hiring, promotion, transfer, or layoff/reduction in force

occur;





6. Keeping management informed of equal opportunity progress and problems within the

company through, at a minimum, periodic reports;

7. Providing department managers with a copy of the AAP for individuals with disabilities

and reviewing the program with them on an annual basis to ensure knowledge of their


8. Reviewing the company’s AAP for individuals with disabilities with all managers and



9. Assisting in ensuring that career development of employees who are individuals with

disabilities is equal to that of other employees;

10. Auditing the contents of company bulletin boards to ensure that required information is

posted and up-to-date;

11

11. Serving as a liaison between FirstEnergy Corporation and enforcement agencies; and

12. Serving as a liaison between FirstEnergy Corporation and outreach and recruitment

sources for individuals with disabilities.



company’s AAP for individuals with disabilities. These responsibilities include, but are not

limited to:

1. Reviewing the company’s affirmative action policy for individuals with disabilities with

subordinate managers and supervisors to ensure that they are aware of the policy and

understand their obligation to comply with it in all personnel actions;

2. Reviewing the qualifications of all applicants and employees to ensure individuals with

disabilities are treated in a nondiscriminatory manner when hiring, promotion, transfer,

or layoff/reduction in force occur; and

3. Reviewing all employees’ performance to ensure that non-discrimination is adhered to

in all personnel activities.

12

X. Training (41 CFR 60-741.44(j))




regulatory requirements under Section 503 of the Rehabilitation Act soon after being hired or

placed into these roles.


individuals with disabilities and of their obligations to:



• Ensure qualified applicants and employees who are individuals with disabilities are

treated in a nondiscriminatory manner in all employment practices, including when

making selection decisions, such as for hire, promotion, training, or to receive awards

or bonuses:


qualified individuals with disabilities unless such accommodation would impose an

undue hardship on the conduct of its business;

• Maintain confidentiality of any information regarding self-identification of individuals

with disabilities; and


13


FirstEnergy Corporation collects employee data pertaining to individuals with disabilities in order

to assess the effectiveness of the company’s outreach and recruitment efforts. We invite

applicants to voluntarily inform the company whether they believe they are individuals with

disabilities in compliance with the Section 503 requirements. This data will be maintained for

three years.

14

XII. Utilization Analysis (41 CFR 60-741.45(d))

The utilization analysis is designed to evaluate the representation of individuals with disabilities

in each job group within the contractor's workforce with the 7 percent utilization goal established

by the OFCCP. The utilization goal is not a rigid and inflexible quota which must be met, nor is it

to be considered either a ceiling or a floor for the employment of particular groups. Quotas are

expressly forbidden.

15

XIII. Identification of Problem Areas and Action-oriented Programs (41 CFR 60-741.45(e) and (f))

When the percentage of individuals with disabilities in one or more job groups is less than the

utilization goal, the company takes steps to determine whether and where impediments to equal

employment opportunity exist. When making this determination, we assess personnel

processes, the effectiveness of the outreach and recruitment efforts, the results of our

affirmative action program audit, and any other areas that might affect the success of the

affirmative action program.

The company develops and executes action-oriented programs designed to correct any

identified problems areas. These action-oriented programs may include the modification of

personnel processes to ensure equal employment opportunity for individuals with disabilities,

alternative or additional outreach and recruitment efforts, and/or other actions designed to

correct the identified problem areas and attain the established goal. Appendix C documents

action-oriented programs FirstEnergy Corporation will implement to address any problem areas.


AFFIRMATIVE ACTION PROGRAM (AAP) FOR VEVRAA




Akron, OH 44308



for

PROTECTED VETERANS


AFFIRMATIVE ACTION PROGRAM FOR PROTECTED VETERANS

TABLE OF CONTENTS

Page

I. Equal Employment Opportunity (EEO) Policy Statement (41 CFR 60-300.44(a)) 1




(41 CFR 60-300.44(d)) 5



(41 CFR 60-300.44(f)) 7






X. Training (41 CFR 60-300.44(j)) 12


XII. Hiring Benchmarks (41 CFR 60-300.45) 14