Transcript Affirmative Action Planning

P.O. Box 1584
Apple Valley, CA 92307
760-247-3303
www.erma.com
Why Affirmative Action Plans?
Mandated by Executive Order 11246 of
1965 for women and minorities
 Mandated by Vietnam Veterans’
Readjustment Assistance Act of 1971 for
disabled veterans and Vietnam Era
Veterans and Rehabilitation Act of 1973 for
persons with disabilities
 OFCCP – Office of Federal Contract
Compliance Programs – Division of DOL
responsible for oversight of affirmative
action

Purposes of Affirmative Action
Plan for Women and Minorities
Protect Women and Minorities from
unlawful discrimination - both intentional
and impactful
 Audit HR practices
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 recruitment, selection, promotion,
compensation, discipline, termination, etc.
Demonstrate “Good Faith Efforts”
 Develop Actions/Timetables to resolve
discrepancies

Enforcement Methods
Compliance Audit (Desk)
 Off-Site review of Records

Compliance Audit (On-site)
 Focused Review / Non Focused Review
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Penalties for non Compliance

Conciliation Agreements

Fines

Debarment from Government Contracts
Glossary
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Adverse Impact Analysis - Analysis of personnel actions to determine the
existence of impactful discrimination
Applicant – a person submitting an application or resume for a posted position
who meets the minimum requirements for that position.
Availability - the percentage of minorities and females available to the
contractor for employment in a given job or job group
Availability Factor Analysis - deriving the availability for a job or job group by
considering persons available in the reasonable recruitment area and within the
facility
Goal - A rate of recruitment, selection or promotion to remedy underutilization.
Not a quota!
Good Faith Effort - the means by which the contractor plans to achieve a goal
Job Group - A family of jobs whose incumbents have similar compensation,
advancement potential and levels of responsibility
Organizational Profile - A snapshot of the organization at a point in time
consisting either of an Organizational Display or a Workforce Analysis
Organizational Display - A tabular or graphic representation of the workforce
Protected Class - Racial Minorities, Religions, Females, Persons over 40,
persons with disabilities, veterans
Reasonable Recruitment Area - the geographical area from which the
company can be expected to recruit the majority of outside applicants
Underutilization - having proportionally fewer women or minorities in the
workforce than could reasonably be expected given the availability in the labor
area
Underrepresentation - having proportionally fewer women or minorities in a job
group or organizational unit than are present in the workforce
Workforce Analysis - A listing of the job titles in each organizational unit, from
the lowest to the highest paid including the race and sex of all incumbents
Affirmative Action Process
Workforce Analysis
Goals
Adverse Impact
Analysis
Utilization
Analysis
Good
Faith
Efforts
Job Group
Analysis
Availability
Analysis
Workforce Analysis
Listing of job titles in the organization
classified into organizational units or
work groups
 may include compensation data on each
job title
 Can be done with a simple
organizational chart
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Job Group Analysis
Lists each job title in the organization in
terms of job groups
 identifies the number of female and
minority incumbents in each job group

Availability Analysis
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Determines the availability of women
and minorities by considering two
factors:
1. Reasonable Recruitment Area
2. Promotions possible in the
organization
Utilization Analysis
Compares incumbent women and
minorities with available women and
minorities
 Identifies areas of underutilization
 Common methods
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 Any Difference
 80/20 Rule
 Two Standard Deviations
 Fisher’s Exact
Adverse Impact Analysis
Determines the statistical indication of
adverse (disparate) impact against a
protected class
 Analyzes the HR flow in all aspects
 Statistical Method Used

 80/20
 Two Standard Deviations
 Fisher’s Exact
Adverse Impact Analysis
Promotion
Selection
Termination
Results
Good Faith Efforts

Affirmative Actions that will remedy
underutilization/underrepresentation,
adverse impact
 sourcing/recruitment
 selection
 promotion
 training
Goals
Placement Goals
for targeted groups
 Avoid reverse
discrimination and
quotas
 Audit progress
toward goals midyear
 OFCCP Audits
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HR’S Role
Ensure fairness in hiring, promotion,
compensation and termination
 Train all supervising managers on
responsibilities for harassment free
workplace
 Ensure accuracy of data
 Identify deficiencies and take remedial
action
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Is just good business!