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Some best practices advocated for employers in order to avoid claims of discriminationon the basis of gender identity or transgender status include:• Update nondiscrimination policies to expressly include LGBT bias;• Provide training on LGBT bias to all employees and managers;• Provide equal employee benefits to same-sex couples, potentiallyincluding coverage of gender reassignment surgery;• Form diversity and inclusiveness committees and implementdiversity and inclusiveness initiatives;• Permit and encourage LGBT workers to form workplace affinitygroups;• Ensure that nondiscrimination policies provide best practices forworkers who are transitioning from male to female or vice versa,including policies regarding name changes, restroom use, anddress codes;• Ensure that manager performance is linked to LGBT diversitymetrics;• Have employee data collection include voluntary self-disclosure ofLGBT status;• Actively recruit LGBT workers;12

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