The EEOC entered into a three-year, $15 million conciliation agreement with a global technology company to resolve class allegations that the company denied religious and disability accommodation requests under its COVID-19 vaccination policy and terminated employees who refused to get vaccinated.

The agreement requires the company to update its EEO policies, provide annual staff training on religious and disability discrimination, and report accommodation data to the EEOC. The company resolved the matter without admitting liability.

As one of the EEOC’s largest conciliation resolutions to date, this matter signals the agency’s continued focus on employers’ evaluations of vaccine-related accommodation requests under Title VII and the ADA. It highlights the legal and financial risk for employers when they do not conduct individualized assessments, document the interactive process, and substantiate undue hardship determinations.

Members of the Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, can read more here. Employers seeking an in-depth review should consider CWC’s course Navigating the Reasonable Accommodation Process.