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I Just Finished My Affirmative Action Plan: Now What? Strategies and Techniques for Implementing Your AAP


Objective

The purpose of this webinar is to provide you with specific strategies and techniques you can incorporate into your human resources and affirmative action efforts, and processes that will allow you to actually put your affirmative action plan into place.


Cindy Karrow, SPHR


“Discrimination is preventable when employers have certain processes in place and see to it that they are followed, that’s why it’s so important for federal contractors to implement their affirmative action programs, keep accurate employment records and commit to ending barriers to fair employment. A proactive strategy is the best way to guarantee that all workers have an equal opportunity to succeed in the workplace. Plus, it’s the law.” – OFCCP Director Patricia A. Shiu


AAP Implementation

Affirmative action implementation includes several components: • Action Oriented Programs and Good Faith Efforts • Communication • Monitoring • Documentation • Workforce Planning


ACTION ORIENTED PROGRAMS AND GOOD FAITH EFFORTS


Action Oriented Programs

 Develop Action Oriented Programs to address problem areas and help achieve goals  Develop partnerships and relationships with recruitment sources that can provide qualified candidates for open positions including women, minorities, Veterans, and the disabled  Devote time, money, and other resources to efforts which are effective and produce measurable results


Action Oriented Programs

 Review job descriptions to ensure they reflect job requirements  Examine the selection process to check for bias in decision making  Train recruiters and managers on nondiscriminatory screening, interviewing techniques, and recordkeeping requirements


Action Oriented Programs

 Implement new hire orientation program to include review of EEO, AA, and harassment policies  Expressly prohibit discrimination and harassment  Review your communications (printed internal and external publications, consumer advertisement, website) to ensure minorities, women, and individuals with disabilities are featured


Action Oriented Programs

 Conduct periodic audits to ensure facilities are not segregated, neither in policy nor use  Ensure minorities, women, Veterans, and individuals with disabilities are provided a full opportunity and encouraged to participate in all company sponsored educational, training, recreational, and social activities  Analyze conditions of employment to ensure no unlawful distinctions in employment opportunities and/or fringe benefits exist


Action Oriented Programs

 Make good faith efforts to carry out these programs  Keep accurate records of these activities including the analysis of their effectiveness


Questions on Action Programs


COMMUNICATION


Communication

It is the responsibility of the Affirmative Action Officer to communicate to all managers, supervisors, and HR staff involved in recruiting, the placement goals for the year.


Communication

Identify Target Audience

Timing & Frequency

• Executives

• Annually

• Human Resources

• Bi-annually • Quarterly

• Managers • Ongoing

Customized Message • Role of audience

• Purpose of message


Communication

1. Highlight reasons the organization creates AAPs Carrot Summarize benefits to the organization -existing contracts

Stick Recent EEOC and OFCCP settlements Review OFCCP results from prior fiscal year


Communication

2. Review plan reports  Present and explain annual or update reports, statistics, and goals  Communicate success 3. Communicate action plan  Potential problem areas  Associated action oriented programs


Communication

 Conduct regular, ongoing affirmative action meetings to communicate the annual plan, update plan, implementation, as well as ongoing progress reports on action orientated programs and results  Provide training in EEO/AA to management and recruiters


Communication

Communicate to employees the company’s commitment to Equal Employment and Affirmative Action:  Communicate HR policies including EEO and antiharassment  Post affirmative action exhibits and ensure required posters are displayed at each location


Questions on Communications


MONITORING


Monitoring

 Identify milestone goals throughout the year to evaluate progress towards annual goals

 Monitor placement of minorities and women monthly or quarterly to allow changes to recruitment strategies as needed  Job groups without goals should maintain a placement rate at or above availability  Review adverse impact on personnel actions throughout the year  Monitor compensation – starting pay and compensation changes


Monitoring

Periodically conduct a self audit of the applicant process to uncover deficiencies such as:  Applications and/or resumes discarded if didn’t meet definition of an applicant  Recruitment folders maintained but with superfluous information in them  Self-ID forms attached to applications


Monitoring - deficiencies

 Inconsistent or no interview questions  Inconsistent or no minimum qualification or criteria for reviewing applicants  Notes written directly on resumes or applications


Questions on Monitoring


DOCUMENTATION


Documentation

As it relates to hiring:  Copies of all employment advertisements and postings, including those posted with the state employment agencies  Interaction with employment recruiting and outreach resources  Records identifying job seekers contacted regarding their interest in a particular position


Documentation

 Employment tests and results, if used for selection  Specific records of searches on résumé databases  Position descriptions and worker specifications are available to all members of management involved in the recruiting, screening, selection, and promotion process


Documentation

As it relates to employment:  All employment records, including applications, interview notes, and performance evaluations  Accommodations made or denied for employees and applicants  Copies of EEO-1, VETS-100, and VETS-100A reports


Documentation

As it relates to your affirmative action plan:  Meeting minutes showing affirmative action on the agenda  Attendance at meetings and affirmative action program activities

 Materials which document activities and efforts  Information on previous OFCCP audits

 Prior year’s affirmative action plan  Copy of purchase order


Documentation

 Policies and procedures which explain your applicant process, selection, employment physicals, required tests, job descriptions, job specifications, job postings, transfers, promotions, seniority systems, and mentor/apprenticeship/internship programs  Formal EEO Policy Statement  Anti-harassment policy and complaint procedure


Questions on Documentation


WORKFORCE PLANNING


Workforce Planning: Selection

Review and update the job analysis:  job duties and requirements  appropriate salary level  basic qualifications  interview questions  selection tests/instruments  applicant appraisal/performance evaluation forms


Workforce Planning: Selection

Write job descriptions to include:  Job title

 Job tasks & responsibilities

 Status

 Job qualifications

 Salary information

 Physical demands

 Reporting relationships

 Working conditions

 Job summary

 ADA and/or OSHA requirements


Workforce Planning: Selection

Develop an applicant policy which addresses:  equal employment opportunity  solicited vs. unsolicited submissions  data management techniques

 a prescribed process of submission  when to solicit race and gender

 how to handle internal applicants  utilization of search firms and other third party vendors


Workforce Planning: Selection

Consider applicant procedures which:  utilize requisition numbers  establish meaningful disposition codes  route all submissions to your website or other electronic avenue  use a reliable electronic applicant tracking tool  ensure everyone involved in the selection process is trained on policies and procedures  include self-audits to ensure compliance  perform adverse impact analysis on each step in the applicant process


Workforce Planning: Selection

Develop:  external recruitment strategies for minorities, women, Veterans, and individuals with disabilities  internal strategies to train and promote minorities, women, Veterans, and individuals with disabilities


Workforce Planning: Selection

Consider various external sources:        

Newspapers Trade Associations Trade Journals Civic or Community Groups Public Agencies Private Agencies Minority Organizations Women’s Groups

 Organizations for the disabled  Veterans Groups  Secondary Schools  Technical Schools  Community Colleges, Colleges and Universities  Mentor/Apprentice/Intern Programs


Workforce Planning: Selection

All job postings should include:  job title and requisition number  location and salary information  job duties and responsibilities  basic qualifications  education  experience  knowledge and skills  instructions on how to apply  equal employment language


Workforce Planning: Selection

You must:  post all jobs with the state employment agency or One Stop Career Center  maintain posting documentation

 maintain records of response  ensure employment tests are valid, job related, and do not have an adverse impact on applicants


Workforce Planning: Selection

Analyze effectiveness:  verify sources are providing qualified candidates  ensure diversity of recruitment sources  develop and maintain relationships with the sources


Workforce Planning: Retain

To retain valuable employees, consider:  conducting compensation analysis to ensure internal equity  developing an effective performance management system  conducting regular performance reviews  developing career paths  providing career counseling


Workforce Planning: Promote

To create opportunities to promote qualified employees, consider:  providing training to ensure an internal pool of well qualified applicants  tuition reimbursement programs  utilizing mentoring programs  developing cross-training programs


Questions on Workforce Planning


AAP Implementation Recap

Affirmative action implementation includes several components: • Action Oriented Programs and Good Faith Efforts • Communication • Monitoring • Documentation • Workforce Planning


Thank You! Questions: webinarquestions@berkshireassociates.com Compliance Support: 800-882-8904 This program, ORG-PROGRAM- 122091, has been approved for 1 (General) recertification credit hours toward PHR, SPHR and GPHR, recertification through the HR Certification Institute. Please be sure to note the program ID number on your recertification application form.

I Just Finished My Affirmative Action Plan: Now What?  

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