Read the "Hooters' Image and Grooming Standards" excerpt from the Hooters restaurant employee handbook. After you have read the selection, write a memorandum to me in which you complete the following tasks:

A. Create and write an IRAC analysis that explains whether the Hooters appearance policy unlawfully discriminates under the Civil Rights Act of 1964.

B. Explain how the personal appearance policy benefits Hooters' business operations and how it may hinder Hooters' operations.

C. Recommend changes to the Hooters personal appearance policy in order to align the policy with the values and priorities of Hooters' key stakeholders and better securing business potential.

Your introductory status as an employee does not change the fact that you are an at- will employee of The Company. Further, employees who continue with The Company after the expiration of their introductory period remain at-will employees. Hooters' Image and Grooming Standards (the \"LOOK\"): Our employees come in contact with our guests, as well as with each other in the course of their duties. It is essential that standards of dress, grooming, and personal hygiene be established. Proper care of your- self and constant attention to teeth, nails, hair, body, and uniform is recommended for maintaining good health, appearance. and safe food- handling practices. The essence of Hooters is the Hooters Girl. Because it is essential to our success that the Hooters Girl image is always properly maintained, failure to comply with these Image and Grooming Standards may result in discipline up to and including termination. Your General Manager has the nal authority on all matters involving dress, acces- sory, and grooming requirements for the staff. HOOTERS GIRL ON THE FLOOR HOOTERS AT THE BAR Customers can go to many places for wings and beer, but it is our 1 Hooters Girls who make our concept unique. Hooters offers its cus- tomers the look of the f'All American Cheerleader, Surfer, Girl Next Door." The essence of the Hooters Concept is entertainment through female sex appeal, of which the LOOK is a key part. When you are in the Hooters Girl Uniform you are literally playing a role; having been cast for that role, you must comply with the Image and Grooming Standards that the role requires. Hair is to be styled at all times. No ponytails or pigtails are to be worn. The image to be projected is one of glamour. No bizarre hair cuts. styles, or colors are acceptable. No hats or headbands are to be worn. No large hair clips or scrunchies. Make-up is to be worn always to best accentuate your features. Hooters Girls are to be camera-ready at all times. This is show busi- ness, just like the modeling industry. Make-up is not to be too extreme, nor too minimal. 4 . . . lptlrnlru no ha ha mln;mnl II to run! In A-n... -u-...i U Jewelry is be be minimal. It is not to draw attention away from the Hooters Girl or her uniform. Our LOOK is wholesome, yet sexy, and the uniform is athletic by design. Two earrings per ear maximum. Two rings per hand maximum. ONE NECKLACE MAXIMUM, and it is not to be too wide, long or heavy. NO CHOKERS, BEADS, 0R SIMILAR NECKLACES. Two bracelets maximum. No other body piercing is to show. Tongue piercing is not allowed. Fingernails are to be well-maintained & clean at all times. If false nails are worn, they are to be maintained. if polish is worn, the colors are not to be extreme. no black. gold, silver. purple. blue, green, yellows. etc. All nails are to be painted the same color. No jewelry in the nails, nor nail art allowed. Excessively long nails distract from the whole- some look and will not be allowed. Tattoos are not allowed to show. The Hooters Girl uniform must cover all tattoos. The Hooters Girl uniform shirt is a choice of a tank top tucked in to the Hooters Girl shorts, (NO MIDRIFF IS TO SHOW) and the shirt must meet the Hooters Girl shorts. No portion of the bra is to show. A white or nude-colored bra must be worn. Shirts are not to be cut or altered, faded or have any strains or tears. A long sleeve shirt may be worn when weather conditions dictate and at man- ager's discretion. All shirts must be sized to t, N0 BAGGINESS. Only approved Orange Hooters Girl Shorts are to be worn, sized to t, and should NOT BE SO TIGHT THAT THE BUTTOCKS SHOW. Brown Hooters Ticket Pouches are to be worn either with the white Hooters bandannas or attached pouch belts. No buttons or pins are to be worn on any pan of the Hooters Girl uniform, unless it is an approved promotional button worn for a specic event or promotion- al period. which your manager will mandate- Pantyhose are a required pan of the uniform and are to be worn any time the Hooters Girl uniform is worn. Pantyhose are to be worn at all promotions. The only color to be worn is Suntan. You may go a shade darker if your skin color is darker than the Suntan pantyhose color. You may not wear a shade lighter than Suntan. Tights or other forms of leggings are not to be worn. 5 lt'the pantyhose run orsnag, they mist be immediately replaced with a new pair for you to continue your shift. Socks are to be the all white \"slouch\" socks. Tennis shoes are to be 100% WHITE IN COLOR to include the shoe laces. The shoes are to be leather or faux leather 314 or hi-tops. Canvas or mesh is not allowed. Shoes must be clean at all times and replaced as needed. Hooters Logo tennis shoes are acceptable. Hooters Girl uniforms must be clean at all times and replaced as needed. Approved name tags are to be worn at all times on the left side of the Hooters Girl uniform. No provocative nicknames allowed. SMILE!!! A big smile is an important part of the Hooters Girl LOOK and your stage appearance!!! When entering and leaving the store. make sure that your uniform is completely covered. Unless you are working at a Hooters-sponsored event, under no circumstances should the Hooters Girl uniform be worn outside of the store. In addition, please be aware that we do not allow the sale of any portion of the uniform to anyone not employed by Homers. Failure to comply with Image or Grooming Standards may result in discipline up to and including termination. HOST/ STAFF / SERVICE BARTENDER Hair is to be styled at all times. no ponytails or pigtails are to be worn. No bizarre hair cu Ls. Styles 0r colors are acceptable. No hats or headbands are to be worn. No large hair clips or scrunchies are to be worn. Males are to wear hair collar length or shorter. Facial hair is to be neatly trimmed. Make-Up for females is to be worn to best accentuate facial features. Make-up is not to be too extreme. nor too minimal. Males are not to wear make-up. Jewelry is to be minimal. Two earrings per ear maximum. TWO rings per hand maximum. One necklace maximum and it is not to be too wide, 6 long or heavy. No choker-s. beads. or similar necklaces. two bracelets maximum. No other body piercing is to show. Tongue pier-sing is not allowed. Males are not to wear any earrings and otherwise must amply with above criteria. Fingemails are to be well maintained 8: clean at all times. If false nails are worn, they are to be'maintained. If polish is worn. the colors are not to be too extreme. No black, gold. silver, purple, blue. green. yellow, etc. No jewelry in the nails: no nail art allowed. Excessively long nails are distracting and are not allowed. Males are to keep nails short and groomed. Males are not to wear polish. Tattoos are not allowed to show. Any tattoos must be covered by uniform. The uniform shirt consists of: Host - the white Hooters approved polo shirt tucked into shorts: Staff and Service Bartender - the original white - Hooters logo short-sleeved t-shirt tucked into the shorts. Females must wear white bras. which are not to Show. Males may wear white under- garment tshirts. - Only Hooters approved white or khaki shorts are to be worn. With the khaki shorts with beltloops, a brown or black belt must be worn. For males the shorts must be above the knee and should be no more than 3- 4\" above the lmee. For females, the length must be appropriate as dictat- ed by management. They must be hemmed and have no rips or tears. It is recommended that. the female Host, Staffer Service Bartender wear the white shorts and the male Host, Staff or Service Bartender wear the khaki shorts. Pantyhose are-a required part of the uniform for females, and are to be worn anytime the uniform is worn. including promodons. The approved color is Suntan. A darker shade may be worn if the employees skin color is darker than the Suntan hose. Lighter shades may not be worn. Tights or other forms of leggings may not be worn. If the pantyhose run or snag. they must be replaced with a new pair. Males may not wear pantyhose. Socks are to be worn and should be all white. Tennis shoes are to be 100% white in color, all leather (no canvas or mesh), 3/ \" or high top in style. Shoes must be replaced when they no longer can be cleaned to white. The Hooters logo shoe is acceptable. 7 ApprOved engraved name tags are to be worn on the left srde ot the'uni- form. No provocative nicknames allowed. No buttons are to be worn unless they are for approved promotional purposes. SMILEll A big smile is important! When entering and leaving the store, make sure that your uniform is completely covered. Unless you are working at a Hooters-sponsored event, under no circumstances should the Hooters Girl uniform be worn outside of the store. In addition. please be aware that we do not allow the sale of any portion of the uniform to anyone not employed by Hooters. '. Failure to comply with Image or Grooming Standards may result in discipline up to and including lamination. KITCHEN STAFF Hair is to be put under a hat at all times. No bizarre hair styles or colors are to show. Hats must be worn at all times. The employee may choose a hat of their choice, preferably a Hooters logo hat. No profanity or illegal ref- erences are to be on hats, no safety violations allowed. No other head- gear is allowed including-bandannas. Facial hair is to be maintained to an acceptable level. Male cooks must shave prior to their shifts, including shaving around musraches and beards. Your manager has the discretion to approve facial hair and hair length and styles. Excessive jewelry is net permitted in the kitchen. No body piercing is allowed to show, including earrings. No tongue rings. Pierced jewelry must be removed. not covered with tape or bandages. Fingernails are to be well maintained & clean at all times. Males are to keep nails short and groomed. Nail polish is not permitted to be worn by kitchen workers. Profane or inappropriate tattoos must be covered. 8 The uniform shirt consists of the original approved black Hooters logo short-sleeved t-shirt tucked into pants. Females must wear a bra, which should not show outside the uniform. A brown or black belt muSt be worn with belt loops. Shorts or long pants may be worn. They must be hemmed and have no rips or tears. Shorts must be above the knee but show beneath the bottom of the apron. The only approved material is dark denim. An approved Hooters apron must be worn and changed when needed. Socks are to be worn. Non-skid safety shoes are to be worn. No canvas or mesh shoes. No holes in shoes. Approved engraved nametags may be worn on the left side of the uniform. No provocative nicknames allowed. No buttons are to be worn unless they are for approved promotional purposes. Approved food handling gloves must be worn according to specied procedure. SMILEl! A big smile is important! Failure to comply with Image or Grooming Standards may result in discipline up to and including termination. ACKNOWLEDGEMENT-HOOTERSGIRL l hereby acknowledge and afnn that I have read and understand 'Ihe Company's Non-Harassment Policy. that Hooters forbids harassment of any kind, and that 1 agree to immediately notify company officials of any harassment complaints which I might have or of any discrimination or harassment by any employee that! become aware of. I hereby acknowledge and afrm that ( I) my job duties require I wear the designated Hooters Girl uniform; (2) my job duties require that l interact with and entertain the customers: and {3) the Hooters concept is based on female sex appeal and the work environment is one in which joking and innuendo based on female sex appeal is com- monplace. I also expressly acknowledge and afrm I do not nd my job duties. uniform require- ments. or work environment to be offensive. intimidating, hostile or unwelcome. I expressly acknowledge that l have been made aware that there are written job descriptions for my position at my location and upon reguest I am entitled to receive a copy of such job description from my management staff. Further. I expressly acknowledge that l have reviewed my job description with my management staff. HOOTERS GIRL ON THE FLOOR 1 acknowledge that the gender eligibility requirements of the position of Hooters Girl on the Floor has been established consistent with the terms of the Consent Decree and Findings of Fact and Conclusions of Law entered in that litigation styled In re: Hooters Gender Discrimination litigation. Consolidated Case No. 93C7709 in the United States District Court for the Nonh District of Illinois (the \"Court\"). The Court has continuing jurisdiction over terms of the entered Consent Decree and Findings of Fact and Conclusions of Law. HOOTERS GIRL AT THE BAR I acknowledge that the gender eligibility requirements of the position of Hooters Girl at the Bar has been established consistent with the terms of the Consent Decree and ndings of Fact and Conclusions of Law entered in that litigation styled In re: Hooters Gender Discrimination Litigation. Consolidated Case No. 93(27709 in the United States District Court for the North District of Illinois (the \"Com't"). 1he Court has continuing jurisdiction over terms of the entered Consent Decree and Findings of Fact and Conclusions of Law. Employee Signature Date Witness (Manager) Date Company Name 45