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Best Ways to Display Good Faith Efforts in Affirmative Action Compliance

Posted on February 7, 2014
Connie ManiscalcoWritten by Connie Maniscalco | Email author

As a Practice Leader here at Helios I have an opportunity to work with many government contractors grappling with the record keeping requirements of maintaining their Affirmative Action Plans.  Commonly referred to as an AAP, the plan is subject to scrutiny by the Office of Federal Contracting Compliance Programs (OFCCP) if they are selected for a compliance audit.  As a government contractor your company must demonstrate the application of good faith efforts to increase the pool of qualified minority, female, veteran and disabled candidates when recruiting for open positions.

So how do you demonstrate your good faith efforts as a company?  Everyone involved in the recruiting process has a part to play from the recruiter all the way up to the President and CEO.  To help navigate the compliance waters take a minute to review the list of responsibilities listed below for the functional groups within your organization.

Affirmative Action Compliance Review:

Recruiting:

  • Document the recruitment process and communicate to the Hiring Managers
  • Post all open positions on minority, disability, veteran and female recruiting sources and be sure to indicate a hiring requisition number on all postings for applicant flow tracking
  • Post all open positions with the local unemployment offices in the states where the opening is located
  • Post all positions internally
  • All postings must include EOE, M/F, D/V in the footer of all postings identifying your company  as an Equal Opportunity Employer
  • Ensure the company website indicates the company is an Equal Opportunity Employer
  • Track applicants for all open positions via an Applicant Tracking System or by using an excel spreadsheet and offer all applicants the opportunity to self-identify race, gender and ethnicity when expressing an interest in open positions
  • Track the disposition of all applicants and include the disposition on the Applicant Flow Log for record-keeping purposes
  • Maintain electronic copies of all job postings to be included in the Exhibits section of the current year AAP
  • Ensure that position titles posted for are the same titles to be used internally or create a mapping tool which cross references posting titles to internal titles
  • Support the display of good faith efforts within all employment aspects

Hiring Managers:

  • Identify openings and obtain approval to recruit for open positions
  • Document position requirements including the necessary knowledge, skills and abilities (KSA’s) for communication to the Recruiting staff
  • Ensure EEO and AAP compliant interviews are being conducted
  • Support the display of good faith efforts within all employment aspects

Human Resources:

  • HR assumes the role of Plan Administrator for the AAP
  • Ensure the AAP is completed each year and progress to goals are communicated to management on an annual basis
  • Maintain all information to be housed in the AAP
  • Ensure AAP notifications are being printed on purchase orders, check vouchers, and included in contract language
  • Ensure the company’s EEO policy statement is signed and posted in a common area for all employees with instructions on how to request a copy of the current year AAP and post it with the other EEO/labor posters such as a 5-in-1 poster
  • Track all employees that take maternity leave
  • Maintain a list of all disabled employees and any accommodations that have been made for these employees
  • Invite all employees to self-identify their race, gender, ethnicity and veteran status pre-hire
  • File EEO1 and Vets 100 reports annually and maintain copies of current year plus 2 years
  • Assist in providing interviewing skills training to Hiring Managers to ensure compliance with EEO and AAP regulations
  • Document community outreach activities
  • Monitor the employee relations environment
  • Track terminations by Voluntary or In-Voluntary status and the reason for the termination such as “resignation” for example
  • Track all new hires, promotions, terminations and transfers each plan year
  • Maintain complete job descriptions for each job title
  • Support the display of good faith efforts within all employment aspects

Senior Leadership:

  • CEO/COO assumes the role of Plan Signer for the AAP
  • Ensures annual AAP updates including goals progress are provided to the organization with oversight from HR
  • Support the display of good faith efforts within all employment aspects

How does your company stack up?  If you answered yes we are doing this to each of the bulleted items, congratulations!  If not, now is the time to act.  Rally your team and get on the right track.

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