The Nature Conservancy (TNC) is committed to taking reasonable steps to ensure all persons have meaningful access to and an equal opportunity to participate in our services, activities, programs and other benefits. This includes persons with limited English proficiency (“LEP”) defined as an individual who does not speak English as their primary language and who has a limited ability to read, write, speak or understand the English language. TNC may provide language assistance to such persons in connection with TNC’s services, activities and programs.
Reasonableness Analysis: In accordance with applicable regulations, TNC will look at the totality of the circumstances in determining when to provide language assistance to maximize participation in its services, activities and programs within its resources. The totality of circumstances includes the following four (4) factors: (1) the number or proportion of LEP persons served in the eligible service population; (2) the frequency with which LEP persons come in contact with our services, activities and programs; (3) the nature and importance of the services, activities and programs we provide; and (4) the resources that we have and/or the costs involved. When reasonably required and practicable, as set forth in this procedure, interpreters, translators and other aids needed to comply with this procedure will be provided without cost to the person being served.
Identifying LEP Persons and Their Language
TNC will use reasonable steps to identify the language and communication needs of the LEP person. Among other means, TNC staff may use a language identification card (or “I speak cards,” available online at www.lep.gov) or posters to determine the language. In addition, when records are kept of individual interactions with visitors/clients or family members, the language used to communicate with the LEP person will be included as part of the record.
Oral (Interpretation) Language Assistance
Persons with LEP attending a TNC educational program may request language assistance as follows: for programs open to national audiences (for example, TNC webinars broadcast nationwide), LEP persons should request assistance through the contact us link on TNC’s website; for local programs, LEP persons should contact the applicable TNC BU. All requests for language assistance must be submitted at least 10 full business days before the program. Whether assistance will be provided and the type of assistance provided will be determined by the staff responding to the language assistance request, after taking into consideration the Reasonableness Analysis and practicability.
When TNC determines an interpretation assistance request meets the Reasonableness Analysis, either prior to a program or at a frequently visited public preserve, TNC may:
- Provide oral interpretation, either in person or virtually, through an available bilingual staff member. However, bilingual staff may not be available at the particular TNC location.
- Provide interpretation services through closed captioning (in the context of webinars and virtual meetings) or machine translations (such as Google Translate).
- Provide oral interpretation, either in person or virtually, through an outside interpreter, if bilingual staff is not available or does not speak the needed language; or
- Allow LEP persons to use a family member or friend as an interpreter, with the understanding LEP persons are never required to provide their own interpretation services. Additionally, visitors are free to communicate with one another in other languages without interference from TNC even if this appears to involve translating information provided by TNC.
Questions/Concerns
Any person having issues, complaints or concerns with this procedure may direct them to the Ethics & Compliance Director, North America by calling 1-800-461-9330, by sending an email to compliance@tnc.org or by reporting to TNC’s Ethics & Compliance Helpline.