The following elements should be in place before an OFCCP Compliance Evaluation:
- Organizational Profile can be display or workforce analysis – must show for each unit: total number of males, females, minorities, and the job title, gender, race & ethnicity of the supervisor.
- Job Group Analysis groups every job title into a group with other job titles which have similar duties, salary, promotional opportunities, etc. Companies with fewer than 150 employees may use EEO-1 categories (1.1-9) as job groups. State the percentage of minorities and women in each job group.
- Availability Analysis for each job group, an estimate of the number of qualified minority & women candidates available in a reasonable recruiting area (external) and a separate determination of those within your company who are promotable, transferable, or trainable (internal).
- Utilization Analysis – a comparison of the percentage of minorities and women currently employed in each job group with those available externally and internally. This will identify any job groups in which you might be underutilized (i.e. have significantly fewer minorities or women than are available).
- Placement Goals set when the percentage of minorities or women currently employed in any job group is less than you would expect based on the availability rates.
- Designation of the person responsible for your Affirmative Action Program.
- Problem Areas identified in review of utilization analysis, personnel activity, compensation systems, etc.
- Action Oriented Programs specific programs designed to meet placement goals or correct problem areas.
- Periodic Internal Audits measure effectiveness of your AAP. We recommend quarterly reviews of all personnel activity.
- Documentation to demonstrate compliance.
- Post jobs with appropriate employment service delivery system except senior management positions. Appropriate systems include local employment service offices and state workforce agency job banks.
- Contact local minority, women, disabled, and veteran associations
- EEO-1 Reports (3 years) and VETS-4212 (1 year)
- Accessibility for individuals with disabilities: parking and entrance, restrooms, application computers/kiosks
- Review EEO policy with all employees
- Set up two files (work & personal) for all employees
- Post EEO Policy statements
- Applicant Flow Logs
- EEO clause on purchase orders and subcontracts
- Salary Analysis
- Executive Order 13496 poster (if applicable)
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