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!f you need additional space for ANY section, please attach an additional sheet and reference that section.l
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A
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Ptaintiff - Astnt", *l
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)United States District Court
Northern District of Illinois
REGEIVED
ilagistrate Judge Sidney t. SchenlierNov 01 20tg
___TH@SGBRt Tfl
cr.ERK, U.S. Dfinrusiannr
1:19-cv{l721n
Judge Sara L. EllisDefendant
=pt dT)Ho^rjroe\t I
COlvIPLAINT
[lf you need additional space for ANY sectior,q, please attach an additional sheet and referertce that section.] Case 4:20-cv-00823-RK Document 1 Filed 11/01/19 Page 1 of 8
lfiled a discrimination & retaliation complaint against Honeywell Federal Manufacturing &
Technologies with the EEOC and notified OFCCP. I served as a Senior Human Resource Generalist from
July 2O77 until April 2018. During my employment, I was subjected to discrimination, retaliation, and
harassment due to my race, origin, and refusing to support violations of EEOC, USERRA, NLRA, FMLA,
FLSA and other related laws. ln January 2018, I received a Performance lmprovement Plan after I
reported unfair treatment, sexual harassment, and failed to support a discipline that wrongfully accused
an African American Male employee (Bill Burgess) for theft in the cafeteria.
I received office supplies in poor condition, did not receive the same training, and access to HR systems
as my White HR Generalist coworkers. My Manager told me that I could not have a business cell phone
but my other coworkers received a cell. However, I supported unionized populations and third shift
workers. I also was taken off projects that leaders (i.e. Amy Tills, Senior Human Director & Randy
White, Chief Technology Officer) invited me on. I endured several racist and micro-aggression
comments made by Manager & coworkers (lindsey Curnmings & Nicole McParlan). Lindsey Cummings
later apologized for offensive comments and communicated that she did not receive a PlP. This further
confirmed that I received wrongful performance review. My Manager (Katelynn Paul, Senior HR
Manager) added to my workload and directed me to oversee Lindsey's client group (AME) because she
was unresponsive and had several absences due to a personal problem. I took on additional
responsibilities and received thank you notes from AME business leaders and Lindsey Cummings.
However, my manager never said thank you or good job on anything.
Nicole McParlan apologized for making comments that made me and my colleagues feel uncomfortable.
She wanted the HR Suite to be a safe space to talk freely about anything. I apologized too because my
intent was not to restrict her from speaking freely but only bringing awareness that it may offend some
people. I thought it was extremely important to call this out to her because she had some complaints
from her client group reporting similar concerns. We had a private conversation and then moved
forward in good standing.
My manager (Katelynn Paul) asked me why I only ate with Black employees, which was a prejudice
assumption. I ate with all employees. I met with her, other team members for lunch, or dinner after
work. My Manager called me a northerner and an elitist. I believe because I came from Corporate HR
and an Upper Midwestern.
Regarding my PlP, I was told that I met my results but did not meet Honeywell Behaviors, which was
newly rolled out and subjective. Many of the managers did not know how to evaluate employees using
the new behaviors. There was inconsistent communications around the new HON behaviors. I also
communicated that the HR Department was an underperforming. FM&T Human Resources had the
highest turnover rate at the site. Furthermore, I noticed the Performance Management Process in place
adversely impacted African Americans associates, other People of Color, Women and older White Men.
These employees are evaluated more harshly. Rashawnda Walker (African American, Woman) received
a poor performance review (5 to 8 rating) with no justification or documentation of conversation leading
to PIP written by her manager. She received an award nominated by her manager's boss. I did not
support this PlP. I also challenged a decision and got it overturned when my manager tried to
compensate an hourly associate (Bruce Johns, White Man) hired to a salaried position at a much lower
rate than salaried employee hired to that position with same experience and education level. My
business leaders brought this to my attention and I presented a business case to our compensation
/,r*hlltlap,
Case 4:20-cv-00823-RK Document 1 Filed 11/01/19 Page 2 of 8
leader. Shortly after, I was retaliated against and she blocked hiring for my Quality division which
impacted our ability to meet some business goals. lt impacted Steve Condron's group.
I reported these incidents to Human Resources and there was never a follow-up with me and no
improvements in my experience. I requested a transferto another Honeywellsite on the Commercial
side of the business and was told I had to stay at least 18 months. FM&T culture was extremely hostile
and the leaders support workplace bullying. My coworkers witnessed and is aware of the unfair
treatment that I received. I had a business leader (Rick Vanhoose, White Man) slams his fist on my desk
and threw a stapler at me.
Toby "Frank "Johnson (African American, Man) reported that money was being deducted from his pay
check. I conducted an investigated and learned that several employees were getting money deducted
due to overpayment without any notice. There was several payroll issues and once I caught them I made
team members correct the errors. I later found out that thes members received good performance
ratings at a 5 or better. However, they made several critical errors that negatively impacted our
employees pay and major compliance issues. Some of these errors were due to HR failing to provide
proper information, which I pointed out in a rneeting. l'm a strong advocate for self, team, and
leadership accountability.
There are many cases I reported when we were in violations or did not handle a situation appropriately.
There were cases managers tried to give an employee random drug screenings without establishing
reasonable suspicion. I protected leaders from committing discrimination or setting a bad practice.
Patricia Wilson (White Woman), reported age discrimination and other forms of unfair treatment. She
requested to take a demotion to leave her division. She wanted to transfer to my division. I learned
about this incident and reported it to Sarah Zillox, Senior HR Manager.
U nfair Performance Evaluations
One group of employees receives pay for no work while other employees worked and are evaluated
through a 9 block Performance Management Frogram. I was told non-working employees are watching
movies and playing cards because they did not have a security clearance so there is no work for them to
do. ln succession planning, more Whites were being promoted than non-whites to upper management.
ln fact, upper management is not racially diverse at all and many employees complained about unequal
treatment and access to leadership roles.
Raciallv Charged Environment
Many employees reported racial harassments and JR, President at FM & T conducted a town hall
meeting with all employees to discuss these incidents and to remind them that our Business code
conduct will be enforced to maintain hostile-free environment. There are many forms of harassment,
discrimination, and retaliation happening at this site. lt needs to stop and there should be some
leadership accountability.
l was afraid to speak out because I received death threats, sffange phone calls, and I was told that l will
no longer have a career in my field. I was unwell after this traumatic experience and suffered from
severe situational depression and anxiety.
ilr"h k2lirei-ru
Case 4:20-cv-00823-RK Document 1 Filed 11/01/19 Page 3 of 8
t referenced our policies, mission, and values to guide my decision making. I also had the words of
Dave Cote, Former CEO on my wall, which said,
"Acting with integrity protects the Honeywell brand. Our Reputation, and our brand mean everything to
us. Employees want to feel good about the company they work for. From the shop floor to the
boardroom, all of us associated with Honeywell want to be proud of our company and hold our heads
up high in our communities. Getting everybody committed to the highest standards for integrity and
compliance ensures that every employee gets to feel this sense of pride. This directly translates into
positive perceptions of how others view us. Honeywell has zero tolerance for employees who do not
conduct business according to the law. When we identify irregularities, we deal with them swiftly! ln
fact, we have referred employees who have committed wrongdoing to law enforcement, regardless of
the potential embarrassment to us as a company anywhere in the world."
Many incidents led to this wrongful termination and violation of my civil rights. This termination creates
an inaccurate portrayal of my work ethic, values, and character. Honeywell FM&T continues to provkle
negative referrals to potential employers.
I interviewed with several companies and specifically had hiring manager strongly recommend that I
apply to a HR position, which I did. I had a hiring manager tell me that she really want me on her team
but extended no offer. She alluded to Honeywell being the reason for not moving forward with an offer.
I had interviewers make comments leading me to believe that Honeywell FM & T is committing
defamation. Furthermore, I had professional associates contact me to apply for roles and then go
unresponsive. For that reason and more, I believe ongoing retaliation is happening.
frrturb3Ii' hi'
Case 4:20-cv-00823-RK Document 1 Filed 11/01/19 Page 4 of 8
EEOC Form 161 (11116) U. S. EQUAL EMPLOYUENT OPPORT.IJNITY COTUTU ISSIOIV
DlswussRL AI{D Notlce or Rlqurs
To: Ashley Jordan
1256 West 97th Place
Chicago, lL 60643From: Chicago District Office
230 S. Dearborn
Suite 1866
Ghicago, lL 60604
On behalf of person(s) aggrieved whose ifultity is
vONFIDE|UTIAL (29
EEOC Charge No.
440-2019-04195EEOC Representativre
Sergio Maldondo,
!nvestigatorTelephone No.
(3121872-9729
THE EEOCrtln
fl
E
E
EIS CLOSTNG ITS FILE ON THIS CHARGE FOR THE FOI-LOWING REASON:
The facts alleged in the charge fail to state a ctairn under any of the statutes enforced by the EEOC.
your allegations did not involve a disability as defined by the Anrrericans With Disabilities Act.
The Respondent employs less than the required number of employees or is not otheruuise covered by the statutes.
your charge was not timely filed with EEOC; in other words, you waited too long after the date(s) of the alleged
discrimination to file Your charge
The EEOC issues the following determinationr: Based upon its investigation, the EEOC is unable to conclude that the
information obtained establishes violations of lfre statutes. This does not certify that the respondent is in compliance with
the statutes. No finding is made as to any other issues that migftrt be construed as having been raised by this charge.
The EEOC has adopted the findings of the stab or local fair employment practices agency that investigated this charge.
Olher (briefly state)
. NOTIGE OF SUIT RIGi{TS .
(See the additional information attacked to this form')
Title Vll, the Americans with Disabilities Act, the Genetic lnformation Nondiscrimination Act, or the Age
Discrimination in Employment Act: This will be the only notice of dismissal and of your right to sue that we will send you.
you may file a lawsuit against the respondent(s) under- fuderal law based on this charge in fecleral or state court. Your
lawsuit nnust be titea w'irulu go oRVs of your recei{rt of this notice; or your right to sue based on this charge will be
lost. (The time limit tor iitlngreuit based on a claim under state law may be different.)
Equal pay Act (EpA): EpA suits must be filed in federal or state court within 2 liears (3 years for willful violations) of the
alleged EFA underpayment. This means that backpay due for any violations that occurred more than 2 vears (3 vears)
before you file suit may not be collectible.
i/
.,1." j','i r') ! I rk6 ,":-r-uf , i:/
-/ loate Ma'ited) Enclosures(s)
Cc: HONEYWELL FM&T
c/o John Ricciardelli
President
14520 Botts Road
Kansas CitY, MO 64147On.6ehalf of the
./ t sfS,uof.t
Julianne)n
Case 4:20-cv-00823-RK Document 1 Filed 11/01/19 Page 5 of 8
EEOC Form 5 (1 1/09)
Cunnog or DtscRtMtNATIoN
This forrn is affected by the Privacy Act of 1 974. See enclosed Pravacy Act
Statement and other information before completing this form.Charge Presented To:
[ rcnn
f, rrocAgency(ies) Charge No(s):
440-2019-04195
and EEOC Kansas City, MO - Human Relations Department
State or local Aqencv, if any
Name (lndlcafe Mr., Atls., Mrs )
Ashley JordanHome Phone find. Area Code)
(952) {$a-2176Date of Birth
1 988
Street Address City, State and ZIP Code
1256 West 97th Place, Ghicago, lL 60643
Named is the Employer, Labor Organization, Employment Agency, Apprenticeship Committee, or State or Local Gouernment Agency That I Believe
Discriminated Against Me or Others. (lf more than two, list under PARflCUTARS below.)
Name
HONEYWELL FM&TNo Employees" ilgflbers
500 or MorePhone No. (lnclude Area Code)
(816)488-2000
Street Address
14520 Botts Road,Kansas City, MO 64147City, State and zlP Code
ffiff#pnzro--*-"
Name I n" e,oiv5"$:t*lrt"gg
| ,4U0tr 8r,,,,,fPtif,n8 ruo (tndude ) rea Code)
Street Address City, State and ZIP Code
cFt/c,4 G0 Dl!.rfi tcT 0r. Fli):
DISCRIMINATION BASED ON (Check appropriate box(es).)
l-il *o", [l co'o* I-l ..*
iX *rro.,o,,o* i-l oot f
| | oruen (specrry)[-l *.t'o,o, l---l NAT.NAL oRrGrN
DrsABrLrry i*_l ot*.r,c tNFoRMArtot'lDATE(S} DISORIMINA I ION TOOK PLACE,
Earliest Latest
08-16-2019
Ja-l .o*r,n,t.i rNG AcrroN
THE PARTICULARS ARE (tf additional paper is needed, attach extra sheet(s))'
I began my employment with Respondent on or about July 17, 2017. My most recent position was
Senior HR Generaiist. During my emptoyment, I was subjected to sexual hanassment and racial
discrimination. Furthermore, I led workplace investigations for my business units and reported
adverse irnpact toward people of color and I tried enforcing the business corde of conduct and the
other related State and Federal Laws ( EEOC, FLSA, FMLA, etc..) . I was alser subjected to harassment
and micro aggression, I complained to Respondent to no avai!. Subsequen8ly, I was discharged
Respondent continues to provide negative referrals to potential employers.
I believe I am being discriminated against because of my race, Black, and irn retaliation for engaging
in protected activity, in violation of Title Vll of the Civil Rights Act of 1964, as amended.
I wantthis charge filed with both the EEOC and the State or local Agency, if any-
will advise the agencies if I change my address r:r phone number and lwill
cooperate iuiiy lvith them in the processing oi rriy chaige in accurciancc ,riiit 'thei;
I declare under penalty of perjury that the above is true and correct
Ch arging P a rly Sign atu re*$ -tb" ?tp{.tG*"rIo, ,tfirrn tf,"t f n.* t"*'d,h" ,b.* .n*q" *O that it is true to
the best of my knowledge, information and belief.
SIGNATURE OF COMPLAINANT
SUBSCRIBEO AND SWORN TO IBEFORE ME THIS DATE
(month, day. year)
Case 4:20-cv-00823-RK Document 1 Filed 11/01/19 Page 6 of 8
T{'TL{NG STIIT IN {-OURT OF' UOMPETENT .' URTSDICTXON
Pzuvate Sr'lr Rtcrns
The issuance of this Notice of Rigttt to Sue or'Disnissol ottd Notice of Rights ends the EEOC process n.ith
respec[ to your Charge. You may file a larvsuit againsf the Respondent rvithin 90 days from the date I'ou
,r.Lir" this Notice. iherefore, you should keep a record of the date. Once the 90 day period is over, your
right to sue is lost. If you intend to consult an aftorney, you should do so as soon as possible. Furthermore, in
or-der to avoid any question that you did nof acl in a timely mamer, if you intend to sue on your olvn behalf;
1,our suit should be fited rvell in advance of the expiration of the 90 day peiiod.
you rnay file your Iarvsuit in a court of competent jurisdidion. Filing this Notice is not suflicient. A court
complaint must contain a short Statement of the facts of your case rvhich shotr;s that you are entitled to retrieL
Generally, suits are brought in the State rvhere the alleged unlarvful practice occurred, but in some cases can
be brought *'here relevant employment records are kept, u'here the employment it'ould have been, or rv'here
the Respondent has its main office'
you may contact the EEOC if you have any questions about your rights, including advice on w'hich cottrt can
hear 1,our case, or if y'ou need to inspect and copy information contained in the case file.
IFTIIE FIRSTTHREECIL.te\crERsoFyouREEocc[t{RGENU;\IBERARE"2lB"A,\-DYoLIRCtLrncew'.rs
I\\'Esrrcj\TED By rHE ILLINoIs DEp,TRTIIIENT oF Hultr ir Rrcttrs (IDHR), REQtrEsr FoR REl'IE\t'INC .\ND
COP}'INC DOCU}IENTS FRO}I YOUR FTLE IVTUST BE DIRECTED TO IDIIR.
A Iarv'suit against a priv'ate emplol;er is generallyfiled in the U.S' DistrictCourt.
AlarvsuittrnderTitleViioftheCivit RightsActof lg64,asamended,againstaStateagencyorapolitical
subdivision of the State is also generally filed in the U.S, DistrictCourt.
I{og.eyer, a law.suit under the Age Discrimination in Employment of the American rvith Disabilities Act or."
probably, the EqualPayAct againsta State instntmentaliry'(an a1eacy directll'funded and controlled by the
Siate) can un[y' be fii.ci in a Siatc cuurl,
A law.suit under the Age Discrimination in Employment Actor the American rvith Disabilities Act or the
Equal payAct againsta politicalsubdivision of a State, such as mtrnicipaliliesand counties, may be filed ir*
the U.S. District Court.
For a Iistof the U.S. District Courts, please see the rel'erse side'
Arro tu\EY Re pRtsstrr\TroN
If y.ou cannot afford an altorney, or have been unable to obtain an altomey to represenl y'ou, the court lraving
jLriisdiction in your case ma),assist you in obtaining a Iatv1'er. If you plan to ask the court to help you obtaini
a lair1'er, ),ou must make this request of the court in the form attd manner it requires. Your request to the
court should be made rvellin advarce of the 90 day period mentioned above. A request for representation
does not relieve you of the obligation to file a larvsuit rvithin the 90-da.v period.
DESTRUCTIoN OF FILE
If 1.ou fi[e suit, ],ou ory.curattcrney shcutd fo'r,r'arC a ecpy of y6rrcourtcomplaint to this office. Your ftle
rvilI then be preserved. Unless you have notified us that you have flled suit, your Charge file could be
destrol,ed as early as six months after the date of the Notice of Right to Sue.
lr You FILE SUIT, yOU OR !'OUR ATTORIiEY SI(OULD NOTIFI',THIS OFFICE \\'FIEli THE LAWSI-II IS RESOI,\'ED;.
Case 4:20-cv-00823-RK Document 1 Filed 11/01/19 Page 7 of 8
U"E. ^tLC/[JA! -[J].Y-!.-f,ilr[-,-E lYjl-!]ll'! \JL l'{-/itn urrx4 ! vvrY
Chicago District Office
JCK Federal Building
230 S. Dearbom
Suite I 866 (Enforcement, State and Local & Hearings)
Suite 2920 (Legal & ADR)
Chicago, iL 60604
lntake Infonnntion Group: (E00) 6694000
lntalie 'nfomtation Group fiY; (800) 669'6820
Chicago Direct Dial: (112) 812-9717
Administration Fat: (3 l2) 538-1255
En forcementrTile Di sclosure Frv: (3 I 2) 588- I 260
Federal Sector Fat: (312) 588'1265
Intalie Fax; ( 312) 588'1286
Legal Fax: (312) 588-1494
N'tediaiion Far: (312) 588-1498
lVebsite: l$$v.g.Su.Cgl
;;;;?;; t"'f-Eril iba -fiGoor sentvia email to s],[email protected] (please chose only one method,
r . r- -..... -... -. -------L --
no duplicate requests). -8e sittclude
willt votrr reouesl.
ufiNGTECE #F EISCLOSURE RTGHTS
parties to an EEOC cliarge are entitled to revielv ancl obtain coPies of doeuments _contained in their
investigative file. Requert, *urt be made in ivriting tc Sylvia_Bustos and either mailed to the address
If you are the charging Parfy and a zucHT TO SUE has been isstted, you may be granted access to your
file:
* Before {ilins a larysuit, but rvithin 90 days of your receipt of the Right to Sue, or
* Aftervourlarvsuithasbeenfiled. Ifmorethang0dayshaveelapsedsinceyourreceiptoftheRightto
Sue, include rritt y**equest a copy of the entire cou-ri complaint (rvith court stamped docket
nurnber) o. .nough pages to determine rvhether it rvas filed based on the EEOC charge'
If you are the Respotrr{eutyou may be granted access to the fi[e onlv after a larvsuit has been fi[ed' Include
rvith your request ,.ofriti," ent-ire court complaint that includis an official court stamped docket number'
pursuant to federal starutes, certain docunrents, such as those rvhich reflect the agency's deliberative
process, rvil[ not be disclosed to either parfy'
you must sign an Agreement of Nondisclostrre before you are granted access to the file, rvhich rvill be sent
to-yo, after receipt*of yoy rvritten request. (Statutei enforced by the EEOC proiribit the agency from
making investigative information public')
The process for access to the fiie rviltbegin no later than ten (.l0) days following receipt of your request'
When the file becomes available for revierv, you rviil be contacted. You may revierv' the file in our offices
and/or request that a copy of the fite be sent to you. Files may not be removed from the office'
your file rvill be copied by Aloha print Group. You are responsible for the copying costs and must sign
;r";*;;;;^,"a-olr,;.Jr" costs before the fite rvill be sent to the copy service. Therefore, !!-!g-- :r ^-.. ^^^i-,{oto determine rvhat documents, if any, you want copied'
itofthepagescontainedinit.Ifyouchoosenottorevierv
you, nt., it rvill b" sent in its eniiqetv to the copy service, ar.rd vqu rvill be responsible for the cost'
irayment'must be made direetly to Aloha Print Group, which charges 15 cents per page,
(Revised 0520/19, previous copies obsolete)
Case 4:20-cv-00823-RK Document 1 Filed 11/01/19 Page 8 of 8