a. Employers should review key personnel policies (i.e., work rules, certain benefit enrollment forms, etc.) to determine if they are understood by their work force and if they may need to be translated into the employee’s own language.
i. The Employer may be liable if the employee later claims he/she did not understand documents he/she was being asked to sign.
b. Employers should consider policies where they agree to maintain a list of available translators to assist their non-English or Limited English Proficiency (LEP) employees with issues which may arise at the work place.
i. These could include the ability of an employee to file a harassment claim or assist the Employer in the investigation of such claims or in employment-related litigation.
e. Bilingual employees with “dual training” may have responsibilities in their primary employed role and, when needed, to interpret conversations or to translate documents. Competencies for each role must be identified, met, and maintained according to written policies.