AAP job groups are a subdivision of EEO Categories that more narrowly group jobs that require similar skills, have similar promotional opportunities, and pay similar wages. Your company determines its own job groups. The job group code can be letters, numbers, or a combination of both. If there are fewer than 150 employees in your […]
All posts by Tamara Seiler
How do I understand AAP reports?
Adverse Impact Analysis: These reports are used by OFCCP to determine if discrimination has occurred. The percentage of hires, promotions, terminations and transfers are compared by race and gender using the two standard deviation analysis. If adverse impact is indicated you should conduct an analysis to determine if your personnel practices result in discrimination. Many […]
Sample EEO Policy and EO Clause Language
It is a best practice to update your EEO Policy Statement annually and post it on your career page, on company bulletin boards and where applicants and employees can see it. Federal affirmative action regulations mandate that Federal contractors include an Equal Opportunity (EO) clause in all contracts, subcontracts and purchase orders. The intent is […]
Am I required to notify our subcontractors and vendors that we are an affirmative action employer?
Affirmative action contractors are required to send written notification of the company’s EEO/AA policy to subcontractors, vendors and suppliers to request their cooperation in affirmative action efforts. These notifications should be sent to all subcontractors, vendors and suppliers once and then to any new subcontractors, vendors and suppliers that are added.
If my company falls under AAP regulations but my business unit or location does not have any federal contracts do I still need an AAP for that location?
A separate business or organization without Government contracts may be covered under the laws enforced by OFCCP based on an integrated relationship or “single entity” status with a Government contractor. OFCCP uses a five-factor test for determining whether such a relationship exists. The test requires OFCCP to consider whether: the entities have common ownership; the […]
What are affirmative action good faith efforts?
Good faith efforts can be described as goal-setting efforts to eradicate and prevent discrimination in the hiring process. One way of accomplishing this is through outreach. This entails developing targeted, meaningful relationships with different organizations that can assist in getting job openings in front of a diverse applicant pool. We have provided a couple of tools to […]
How do I document outreach?
If it isn’t documented, it didn’t happen. That is the short answer as to why it is important to document all outreach efforts. Outreach logs will also allow us to perform analytics to more closely understand which of your outreach efforts is providing qualified applicants and which ones are not.
What forms do I need for applicants to self-id?
Affirmative action employers are required to give all applicants who meet the OFCCP’s definition of applicant the opportunity to self identify race, gender, veteran, and disability status. If an applicant chooses not to self identify any or all of these categories the employer has still met their tracking obligations and needs to do nothing further. […]
What are best practices in affirmative action recruiting and hiring?
To have a successful recruiting strategy, we must create a clearly defined Recruitment and Hiring Process utilizing a multi-step process. Steps may include: Advertising our open positions to attract a diverse candidate pool, including: The appropriate Employment Service Delivery System (ESDS). Professional Organizations Publications Associations representing diversity groups Job Fairs Utilizing our professional networks Evaluate […]
What is the OFCCP definition of an internet applicant?
Office of Federal Contract Compliance Programs (OFCCP) regulations require covered federal contractors and subcontractors to collect information about the gender, race, and ethnicity of each “applicant” for employment. The final rule modifies OFCCP applicant recordkeeping requirements to address challenges presented by the use of the Internet and electronic data technologies in contractors’ recruiting and hiring […]