OSC 2013 NO FEAR ACT TRAINING

YOUR RIGHTS AND REMEDIES UNDER FEDERAL

ANTIDISCRIMINATION AND WHISTLEBLOWER PROTECTION

LAWS

U.S. OFFICE OF SPECIAL COUNSEL

June 19, 2013

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What is the No Fear Act?What is the No Fear Act?

On May 15, 2002, Congress enacted theOn May 15, 2002, Congress enacted the “ “Notification and Federal Employee Notification and Federal Employee Antidiscrimination and Retaliation Act of 2002,” Antidiscrimination and Retaliation Act of 2002,” which is now known as the No FEAR Act. which is now known as the No FEAR Act.

One purpose of the Act is to “require that Federal One purpose of the Act is to “require that Federal agencies be accountable for violations of agencies be accountable for violations of antidiscrimination and whistleblower protection antidiscrimination and whistleblower protection laws.” laws.”

To this end, the No FEAR Act requires that all To this end, the No FEAR Act requires that all federal agencies train employees about the rights federal agencies train employees about the rights and remedies available to them under the and remedies available to them under the Antidiscrimination Laws and Whistleblower Antidiscrimination Laws and Whistleblower Protection Laws applicable to them. Protection Laws applicable to them.

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Federal Antidiscrimination and Federal Antidiscrimination and Whistleblower Protection LawsWhistleblower Protection Laws

““Federal Antidiscrimination Laws” refers to:Federal Antidiscrimination Laws” refers to:

5 U.S.C. 2302(b)(1)5 U.S.C. 2302(b)(1) 5 U.S.C. 2302(b)(9), as applied to conduct described in 5 5 U.S.C. 2302(b)(9), as applied to conduct described in 5

U.S.C. 2302(b)(1)U.S.C. 2302(b)(1) 5 U.S.C. 2302(b)(10)5 U.S.C. 2302(b)(10) 29 U.S.C. 206(d) Equal Pay Act29 U.S.C. 206(d) Equal Pay Act 29 U.S.C. 621 Age Discrimination in Employment Act29 U.S.C. 621 Age Discrimination in Employment Act 29 U.S.C. 791 Rehabilitation Act29 U.S.C. 791 Rehabilitation Act 42 U.S.C. 2000e–16 Civil Rights Act of 196442 U.S.C. 2000e–16 Civil Rights Act of 1964 42 U.S.C. 2000ff-11 Genetic Information Nondiscrimination Act42 U.S.C. 2000ff-11 Genetic Information Nondiscrimination Act

““Federal Whistleblower Protection Laws” refers Federal Whistleblower Protection Laws” refers to:to:

5 U.S.C. 2302(b)(8) or 5 U.S.C. 2302(b)(9), as applied to 5 U.S.C. 2302(b)(8) or 5 U.S.C. 2302(b)(9), as applied to conduct described in 5 U.S.C. 2302(b)(8).conduct described in 5 U.S.C. 2302(b)(8).

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Race DiscriminationRace Discrimination

Under Title VII of the Civil Rights Act of 1964, equal Under Title VII of the Civil Rights Act of 1964, equal employment opportunity cannot be denied any person employment opportunity cannot be denied any person because of his/her racial group or perceived racial group, because of his/her racial group or perceived racial group, race-linked characteristics (race-linked characteristics (e.ge.g., hair texture, color, facial ., hair texture, color, facial features), or marriage to or association with someone of a features), or marriage to or association with someone of a particular race or color. particular race or color.

Title VII also prohibits employment decisions based on Title VII also prohibits employment decisions based on stereotypes and assumptions about abilities, traits, or the stereotypes and assumptions about abilities, traits, or the performance of individuals of certain racial groups.performance of individuals of certain racial groups.

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Race Discrimination Race Discrimination (continued)(continued)

It is unlawful to discriminate against any individual in regard to It is unlawful to discriminate against any individual in regard to recruiting, hiring and promotion, transfer, work assignments, recruiting, hiring and promotion, transfer, work assignments, performance measurements, the work environment, job performance measurements, the work environment, job training, discipline and discharge, wages and benefits, or any training, discipline and discharge, wages and benefits, or any other term, condition, or privilege of employment.other term, condition, or privilege of employment.

Title VII prohibits not only intentional discrimination, but also Title VII prohibits not only intentional discrimination, but also

neutral job policies that disproportionately affect persons of a neutral job policies that disproportionately affect persons of a certain race or color and that are not related to the job and the certain race or color and that are not related to the job and the needs of the business.needs of the business.

Title VII also prohibits harassment based on race. Title VII also prohibits harassment based on race.

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National Origin DiscriminationNational Origin Discrimination

Title VII prohibits employers from discriminating against individuals Title VII prohibits employers from discriminating against individuals because of their national origin. National origin discrimination means because of their national origin. National origin discrimination means treating someone less favorably because he or she comes from a treating someone less favorably because he or she comes from a particular place, because of his or her ethnicity or accent, or because particular place, because of his or her ethnicity or accent, or because it is believed that he or she has a particular ethnic background. it is believed that he or she has a particular ethnic background. National origin discrimination also means treating someone less National origin discrimination also means treating someone less favorably at work because of marriage or other association with favorably at work because of marriage or other association with someone of a particular nationality.someone of a particular nationality.

Violations include: discrimination in employment decisions Violations include: discrimination in employment decisions (recruitment, hiring, firing, layoffs, etc.) and harassment based on (recruitment, hiring, firing, layoffs, etc.) and harassment based on national origin.national origin.

Discrimination against individuals employed in the United States is Discrimination against individuals employed in the United States is prohibited, regardless of citizenship. However, relief may be limited if prohibited, regardless of citizenship. However, relief may be limited if an individual does not have work authorization.an individual does not have work authorization.

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National Origin DiscriminationNational Origin Discrimination(Language) (Language)

Accent discriminationAn employer may not base a decision on an employee’s foreign An employer may not base a decision on an employee’s foreign accent unless the accent materially interferes with job accent unless the accent materially interferes with job performance.performance.

English fluencyA fluency requirement is only permissible if required for the A fluency requirement is only permissible if required for the effective performance of the position for which it is imposed.effective performance of the position for which it is imposed.

English-only rulesEnglish-only rules must be adopted for nondiscriminatory English-only rules must be adopted for nondiscriminatory reasons. An English-only rule may be used if it is needed to reasons. An English-only rule may be used if it is needed to promote the safe or efficient operation of the employer’s promote the safe or efficient operation of the employer’s business.business.

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Religious DiscriminationReligious Discrimination

Title VII prohibits employers from discriminating against Title VII prohibits employers from discriminating against individuals because of their religion in hiring, firing, and individuals because of their religion in hiring, firing, and other terms and conditions of employment. other terms and conditions of employment.

Employees cannot be forced to participate – or not Employees cannot be forced to participate – or not participate – in a religious activity as a condition of participate – in a religious activity as a condition of employment. employment.

Employers must take steps to prevent religious harassment Employers must take steps to prevent religious harassment of their employees.of their employees.

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Religious DiscriminationReligious DiscriminationReasonable AccommodationReasonable Accommodation

Employers must reasonably accommodate employees’ sincerely Employers must reasonably accommodate employees’ sincerely held religious practices unless doing so would impose an undue held religious practices unless doing so would impose an undue hardship on the employer. hardship on the employer.

A reasonable religious accommodation is any adjustment to the A reasonable religious accommodation is any adjustment to the work environment that will allow the employee to practice his work environment that will allow the employee to practice his religion. An employer might accommodate an employee’s religion. An employer might accommodate an employee’s religious beliefs or practices by allowing: flexible scheduling, religious beliefs or practices by allowing: flexible scheduling, voluntary substitutions or swaps, job reassignments and lateral voluntary substitutions or swaps, job reassignments and lateral transfers, modification of grooming requirements and other transfers, modification of grooming requirements and other workplace practices, policies and/or procedures. workplace practices, policies and/or procedures.

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Sex DiscriminationSex Discrimination

It is unlawful to discriminate against any employee or It is unlawful to discriminate against any employee or applicant because of his/her sex in regard to hiring, applicant because of his/her sex in regard to hiring, termination, promotion, compensation, job training, or any termination, promotion, compensation, job training, or any other term, condition, or privilege of employment. other term, condition, or privilege of employment.

Title VII also prohibits employment decisions based on Title VII also prohibits employment decisions based on stereotypes and assumptions about abilities, traits, or the stereotypes and assumptions about abilities, traits, or the performance of individuals on the basis of sex. performance of individuals on the basis of sex.

Title VII prohibits both intentional discrimination and neutral Title VII prohibits both intentional discrimination and neutral job policies that disproportionately exclude individuals on job policies that disproportionately exclude individuals on the basis of sex and that are not job-related.the basis of sex and that are not job-related.

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Sex Discrimination Sex Discrimination Pregnancy DiscriminationPregnancy Discrimination

The Pregnancy Discrimination Act is an amendment The Pregnancy Discrimination Act is an amendment to Title VII of the Civil Rights Act of 1964. to Title VII of the Civil Rights Act of 1964. Discrimination on the basis of pregnancy, childbirth, Discrimination on the basis of pregnancy, childbirth, or related medical conditions constitutes unlawful sex or related medical conditions constitutes unlawful sex discrimination under Title VII. discrimination under Title VII.

Women who are pregnant or affected by related Women who are pregnant or affected by related conditions must be treated in the same manner as conditions must be treated in the same manner as other applicants or employees with similar disabilities other applicants or employees with similar disabilities or limitations.or limitations.

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Sex DiscriminationSex DiscriminationPregnancy Discrimination Pregnancy Discrimination

(continued)(continued)

An employer cannot refuse to hire a pregnant woman An employer cannot refuse to hire a pregnant woman because of her pregnancy, because of a pregnancy-related because of her pregnancy, because of a pregnancy-related condition or because of the prejudices of co-workers, condition or because of the prejudices of co-workers, clients, or customers.clients, or customers.

Pregnant employees must be permitted to work as long as Pregnant employees must be permitted to work as long as they are able to perform their jobs. they are able to perform their jobs.

Employers must hold open a job for a pregnancy-related Employers must hold open a job for a pregnancy-related absence the same length of time jobs are held open for absence the same length of time jobs are held open for employees on sick or disability leave.employees on sick or disability leave.

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Sex DiscriminationSex DiscriminationSexual HarassmentSexual Harassment

Title VII’s prohibitions against sex-based discrimination also Title VII’s prohibitions against sex-based discrimination also covers:covers:

Sexual HarassmentThis includes practices ranging from direct requests for sexual This includes practices ranging from direct requests for sexual favors to workplace conditions that create a hostile environment favors to workplace conditions that create a hostile environment for persons of either gender, including same sex harassment.for persons of either gender, including same sex harassment.

Sex DiscriminationSex DiscriminationGender Identity and Sex-StereotypingGender Identity and Sex-Stereotyping

The EEOC has held that discrimination against an The EEOC has held that discrimination against an individual because that person is transgender (also individual because that person is transgender (also known as gender identity discrimination) is known as gender identity discrimination) is discrimination because of sex and therefore is covered discrimination because of sex and therefore is covered under Title VII of the Civil Rights Act of 1964. under Title VII of the Civil Rights Act of 1964. See Macy See Macy v. Department of Justicev. Department of Justice, EEOC Appeal No. 0120120821 , EEOC Appeal No. 0120120821 (April 20, 2012)(April 20, 2012)

The Commission has also found that claims by lesbian, The Commission has also found that claims by lesbian, gay, bisexual, and straight individuals alleging sex-gay, bisexual, and straight individuals alleging sex-stereotyping state a sex discrimination claim under Title stereotyping state a sex discrimination claim under Title VII. VII. See Veretto v. U.S. Postal ServiceSee Veretto v. U.S. Postal Service, EEOC Appeal No. , EEOC Appeal No. 0120110873 (July 1, 2011); 0120110873 (July 1, 2011); Castello v. U.S. Postal Castello v. U.S. Postal ServiceService, EEOC Request No. 0520110649 (Dec. 20, 2011), EEOC Request No. 0520110649 (Dec. 20, 2011)

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Equal PayEqual Pay

The Equal Pay Act of 1963 requires that men and women be The Equal Pay Act of 1963 requires that men and women be given equal pay for equal work in the same establishment. The given equal pay for equal work in the same establishment. The jobs need not be identical, but they must be substantially equal. jobs need not be identical, but they must be substantially equal.

Title VII also prohibits compensation discrimination on the basis Title VII also prohibits compensation discrimination on the basis of sex. Unlike the Equal Pay Act, however, Title VII does not of sex. Unlike the Equal Pay Act, however, Title VII does not require that the claimant’s job be substantially equal to that of a require that the claimant’s job be substantially equal to that of a higher paid person of the opposite sex or require the claimant to higher paid person of the opposite sex or require the claimant to work in the same establishment.work in the same establishment.

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Disability DiscriminationDisability Discrimination

Title I of the Americans with Disabilities Act of 1990 (ADA) Title I of the Americans with Disabilities Act of 1990 (ADA) prohibits private employers, state and local governments, prohibits private employers, state and local governments, employment agencies and labor unions from discriminating employment agencies and labor unions from discriminating against qualified individuals with disabilities in job against qualified individuals with disabilities in job application procedures, hiring, firing, advancement, application procedures, hiring, firing, advancement, compensation, job training, and other terms, conditions, and compensation, job training, and other terms, conditions, and privileges of employment.privileges of employment.

The ADA’s nondiscrimination standards apply to federal The ADA’s nondiscrimination standards apply to federal sector employees under section 501 of the Rehabilitation sector employees under section 501 of the Rehabilitation Act, as amended, and its implementing rules and regulations.Act, as amended, and its implementing rules and regulations.

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What is a Disability?What is a Disability?

An individual with a disability is a person who:An individual with a disability is a person who:

Has a physical or mental impairment that substantially Has a physical or mental impairment that substantially limits one or more major life activities limits one or more major life activities (such as walking, talking, seeing, hearing, or learning).

Has a record of such an impairment; orHas a record of such an impairment; or

Is regarded as having such an impairment. Is regarded as having such an impairment.

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Reasonable AccommodationReasonable Accommodation

A qualified employee or applicant with a disability is an A qualified employee or applicant with a disability is an individual who, with or without reasonable accommodation, can individual who, with or without reasonable accommodation, can perform the essential functions of the job in question. perform the essential functions of the job in question. Reasonable accommodation may include, but is not limited to:Reasonable accommodation may include, but is not limited to:

Making existing facilities used by employees readily Making existing facilities used by employees readily accessible to and usable by persons with disabilities;accessible to and usable by persons with disabilities;

Job restructuring, modifying work schedules, reassignment to Job restructuring, modifying work schedules, reassignment to a vacant position; a vacant position;

Acquiring or modifying equipment or devices, adjusting or Acquiring or modifying equipment or devices, adjusting or modifying examinations, training materials, or policies, and modifying examinations, training materials, or policies, and providing qualified readers or interpreters. providing qualified readers or interpreters.

An employer is required to make a reasonable accommodation to An employer is required to make a reasonable accommodation to the known disability of a qualified employee or applicant if it the known disability of a qualified employee or applicant if it would not impose an “undue hardship” on the operation of the would not impose an “undue hardship” on the operation of the employer’s business.employer’s business.

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Age DiscriminationAge Discrimination

The Age Discrimination in Employment Act of The Age Discrimination in Employment Act of 1967 (ADEA) protects individuals who are 40 1967 (ADEA) protects individuals who are 40 years of age or older from employment years of age or older from employment discrimination based on age. discrimination based on age.

Under the ADEA, it is unlawful to Under the ADEA, it is unlawful to discriminate against a person because of discriminate against a person because of his/her age with respect to any term, his/her age with respect to any term, condition, or privilege of employment, condition, or privilege of employment, including hiring, firing, promotion, layoff, including hiring, firing, promotion, layoff, compensation, benefits, job assignments, and compensation, benefits, job assignments, and training.training.

Genetic Information DiscriminationGenetic Information Discrimination

It is unlawful to discriminate against employees or applicants It is unlawful to discriminate against employees or applicants because of genetic information. Title II of the Genetic because of genetic information. Title II of the Genetic Information Nondiscrimination Act (GINA) prohibits the use of Information Nondiscrimination Act (GINA) prohibits the use of genetic information in making employment decisions and genetic information in making employment decisions and restricts employers and other entities covered by Title II from restricts employers and other entities covered by Title II from requesting, requiring, or purchasing genetic information, and requesting, requiring, or purchasing genetic information, and strictly limits the disclosure of genetic informationstrictly limits the disclosure of genetic information.

The law forbids discrimination on the basis of genetic The law forbids discrimination on the basis of genetic information when it comes to any aspect of employment, information when it comes to any aspect of employment, including hiring, firing, pay, job assignments, promotions, including hiring, firing, pay, job assignments, promotions, layoffs, training, fringe benefits, or any other term or condition layoffs, training, fringe benefits, or any other term or condition of employment.of employment.

It is also unlawful to harass a person because of his or her It is also unlawful to harass a person because of his or her genetic information.genetic information. 20

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Retaliation ProhibitedRetaliation Prohibited

It is unlawful to retaliate against an individual for It is unlawful to retaliate against an individual for opposing employment practices that discriminate opposing employment practices that discriminate based on race, color, religion, sex, age, national based on race, color, religion, sex, age, national origin, pregnancy, disability, or genetic information. origin, pregnancy, disability, or genetic information.

It is also unlawful to retaliate against an individual It is also unlawful to retaliate against an individual for filing a discrimination charge, testifying, or for filing a discrimination charge, testifying, or participating in any way in an investigation, participating in any way in an investigation, proceeding, or litigation.proceeding, or litigation.

Political Affiliation, Marital Status, Political Affiliation, Marital Status, Sexual Orientation, and Status as a ParentSexual Orientation, and Status as a Parent

The Civil Service Reform Act of 1978 makes it The Civil Service Reform Act of 1978 makes it illegal to discriminate in personnel actions against illegal to discriminate in personnel actions against Federal employees because of their marital status, Federal employees because of their marital status, political affiliation, or based on conduct which does political affiliation, or based on conduct which does not adversely affect the performance of the not adversely affect the performance of the applicant or employee -- which can include sexual applicant or employee -- which can include sexual orientation discrimination, or to retaliate against orientation discrimination, or to retaliate against employees for exercising their rights. 5 U.S.C. employees for exercising their rights. 5 U.S.C. 2302(b)(1), (b)(9) & (b)(10).2302(b)(1), (b)(9) & (b)(10).

Executive Order 11478, section 1 (as amended by Executive Order 11478, section 1 (as amended by Executive Orders 13087 and 13152) prohibits Executive Orders 13087 and 13152) prohibits discrimination on the basis of sexual orientation discrimination on the basis of sexual orientation and status as a parent. and status as a parent.

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Whistleblower ProtectionWhistleblower Protection5 U.S.C. 5 U.S.C. § § 2302 (b)(8)2302 (b)(8)

A federal employee authorized to take, direct others to A federal employee authorized to take, direct others to take, recommend or approve any personnel action may take, recommend or approve any personnel action may notnot engage in reprisal for whistleblowing – engage in reprisal for whistleblowing – i.ei.e., take, fail to ., take, fail to take, or threaten to take or fail to take a personnel action take, or threaten to take or fail to take a personnel action with respect to any employee or applicant because of:with respect to any employee or applicant because of:

Any disclosure of information by the employee or applicant Any disclosure of information by the employee or applicant that he or she reasonably believes evidences:that he or she reasonably believes evidences:

* A violation of a law, rule or regulation, * A violation of a law, rule or regulation, * Gross mismanagement,* Gross mismanagement,* Gross waste of funds,* Gross waste of funds,* Abuse of authority, or * Abuse of authority, or * A substantial and specific danger to public health * A substantial and specific danger to public health

or safety.or safety.

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Disclosure not protected (unless made to the Special Disclosure not protected (unless made to the Special Counsel or Inspectors General), when disclosure is –Counsel or Inspectors General), when disclosure is –

Prohibited by law,Prohibited by law,

oror

Required by Executive Order to be secret for Required by Executive Order to be secret for national security or foreign affairs reasons.national security or foreign affairs reasons.

Protected Whistleblower DisclosuresProtected Whistleblower Disclosures((continuedcontinued))

5 U.S.C. § 2302 (b)(8)5 U.S.C. § 2302 (b)(8)

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Corrective Action:Corrective Action:Whistleblower Reprisal MattersWhistleblower Reprisal Matters

5 U.S.C. §§ 1214(b)(4)(B), 1221(e)(1)5 U.S.C. §§ 1214(b)(4)(B), 1221(e)(1)

Can be obtained Can be obtained ifif - -

Disclosure of information was a Disclosure of information was a Contributing FactorContributing Factor in in a personnel action,a personnel action,

UnlessUnless

Agency shows by Agency shows by Clear and Convincing EvidenceClear and Convincing Evidence that it that it would have taken the same personnel action in the would have taken the same personnel action in the absence of the disclosure.absence of the disclosure.

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Other Protected Activities:Other Protected Activities:5 U.S.C. § 2302 (b)(9)5 U.S.C. § 2302 (b)(9)

Any employee who has authority to take, direct others to take, Any employee who has authority to take, direct others to take, recommend, or approve any personnel action, shall not, with recommend, or approve any personnel action, shall not, with respect to such authority :respect to such authority :

Take or fail to take, or threaten to take or fail to take, any Take or fail to take, or threaten to take or fail to take, any personnel action against any employee or applicant for personnel action against any employee or applicant for employment because of – employment because of –

(A) the exercise of any appeal, complaint, or grievance right (A) the exercise of any appeal, complaint, or grievance right granted by any law, rule, or regulation;granted by any law, rule, or regulation;

(B) testifying for or otherwise lawfully assisting any (B) testifying for or otherwise lawfully assisting any individual in the exercise of any right referred to in (A);individual in the exercise of any right referred to in (A);

(C) cooperating with or disclosing information to the (C) cooperating with or disclosing information to the Inspector General of an agency, or the Special Counsel, in Inspector General of an agency, or the Special Counsel, in accordance with applicable provisions of law; oraccordance with applicable provisions of law; or

(D) for refusing to obey an order that would require the (D) for refusing to obey an order that would require the individual to violate a law. individual to violate a law.

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Filing a ComplaintFiling a Complaint

If you think you have been subjected to retaliation, If you think you have been subjected to retaliation, contact the Complaints Examining Unit at the U.S. contact the Complaints Examining Unit at the U.S. Office of Special Counsel at 1-800-872-9855 or visit Office of Special Counsel at 1-800-872-9855 or visit www.osc.gov to file a written complaint to file a written complaint

If you feel you have been discriminated against in If you feel you have been discriminated against in violation of antidiscrimination laws, contact your OSC violation of antidiscrimination laws, contact your OSC EEO counselors, listed on OSC’s Intranet and slide EEO counselors, listed on OSC’s Intranet and slide 29. You may also contact the Equal Employment 29. You may also contact the Equal Employment Opportunity Commission if you have questions about Opportunity Commission if you have questions about filing a complaint (1-800-669-4000) or visit filing a complaint (1-800-669-4000) or visit www.eeoc.gov to learn more. to learn more.

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OSC EEO DirectivesOSC EEO Directives

The following EEO directives are accessible on OSC’s The following EEO directives are accessible on OSC’s intranet:intranet:

““EEO, Non-Discrimination, EEO, Non-Discrimination, OSC Directive OSC Directive 1400-511400-51

and Anti-Harassment Policy”and Anti-Harassment Policy”

““Procedures for AccommodationProcedures for Accommodation OSC OSC Directive 1400-52Directive 1400-52

of Persons with Disabilities”of Persons with Disabilities”

* OSC is currently in the process of updating the EEO Directive * OSC is currently in the process of updating the EEO Directive and creating a separate Anti-Harassment Policy and creating a separate Anti-Harassment Policy

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OSC EEO CounselorsOSC EEO Counselors

HEADQUARTERS James Booker (202) 254-3675

Mariama Liverpool (202) 254-36091730 M. St., N.W. (Suite 300)Washington, D.C. 20036-4505

DETROIT FIELD OFFICELovie Jones

211 West Fort Street, Room 521Detroit, MI 48226

Telephone: (313) 226-4441, ext. 6221

DALLAS FIELD OFFICEAnne Edgette

525 Griffin Street (Room 824, Box #103)Dallas, TX 75202

Telephone: (214) 747-1519, ext. 4233

SAN FRANCISCO BAY AREA FIELD OFFICEKristi van Greunen

Oakland Federal Building1301 Clay Street (Suite 1220N)

Oakland, CA 94612-5217Telephone (510) 637-3464, ext. 5227

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Acting OSC EEO DirectorActing OSC EEO Director

Shirine MoazedShirine Moazed

1730 M. St, N.W., Suite 3001730 M. St, N.W., Suite 300

Washington, DC 20036-4505Washington, DC 20036-4505

Telephone (202) 254-3600Telephone (202) 254-3600

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Congratulations!Congratulations!

You have now completed the No FEAR Act training of You have now completed the No FEAR Act training of 2013. Please complete your certification statement and 2013. Please complete your certification statement and email it to Osborne Mack.email it to Osborne Mack.