Objective 1: Ensure federal contractor’s HR Processes are compliant, discourage discrimination, are properly documented, and applied consistently

HudsonMann’s requirements to meet objectives:

  • Consult with Federal Contractor AA program manager and specific HR functional managers on compliant:

o   Applicant Tracking processes and recordkeeping

o   Hiring, Promotion, and Termination processes and recordkeeping

o   Compensation Programs

Federal Contractor’s requirements to meet objective:

  • Manage implementation and periodically monitor above HR Processes for compliance and AA best practices
  • Ensure proper documentation of HR processes through training and internal audits

Result: Federal Contractor HR processes will be AA compliant and defensible

 

Objective 2: Have all affirmative action plans complete and updated within 60 days of start of plan year

Federal Contractor’s requirements to meet objective:

  • Have complete and accurate HRIS data to HudsonMann within 30 days of start of plan year
  • Coordinate flow of employee data from HRIS to HudsonMann
  • Coordinate flow of applicant data from applicant tracking system to HudsonMann

HudsonMann requirements to meet objective:

  • Process employee data and applicant data for all locations
  • Provide all required affirmative action reporting via iPlans within 30 days of receipt of employee and applicant data

Result: Federal Contractor affirmative action plans are complete with all required reports in a timely manner

 

Objective 3: Disseminate affirmative action plans and create action oriented programs to control risk and increase diversity

HudsonMann requirements to meet objective:

  • Provide reporting that summarizes adverse impact, lack of applicant pools, and unmet affirmative action goals
  • Consult with Federal Contractor AA program manager on action oriented programs and proper documentation to address potential risk and good faith efforts

Federal Contractor’s requirements to meet objective:

  • Work with local HR managers to review problem areas and implement action oriented programs
  • Ensure HR Managers have responded to areas of risk within plans

Result: Affirmative action plans have been disseminated companywide and areas of potential liability have been addressed.

 

Objective 4: Analyze compensation programs yearly for internal equity and make adjustments as necessary

HudsonMann requirements to meet objective:

  • Consult with Federal Contractor AA program manager on internal equity compensation analyses best practices

Federal Contractor requirements to meet objective:

Implement compensation analyses and consult on corrective actions

Result: Federal Contractor meets OFFCP requirements of yearly compensation analyses and is prepared for OFCCP compensation reviews.

 

Objective 5: Provide AA training for HR managers and frontline managers

HudsonMann requirements to meet objective:

  • Provide yearly web based AA training for HR managers
  • Provide content for frontline manager AA training

Federal Contractor requirements to meet objective:

  • Coordinate HudsonMann webinars for HR Manager AA training
  • Coordinate implementation of AA training module into Federal Contractor’s Learning Management System

Result: Federal Contractor’s HR and frontline managers are aware of affirmative action policies and procedures.

 

Objective 6: Ensure EEO-1 reporting is aligned with OFCCP AA reporting

Requirements to meet objective:

  • Ensure that EEO-1 reports are accurate and that each establishment listed with 50 or more employees has an AAP.

Result: Federal Contractor AAPs will be aligned with EEO-1 reporting which is the OFCCP window to the Federal Contractor organization.

 

OTHER OFFCP REQUIREMENTS TO IMPLEMENT AND MONITOR:

  • State job postings for all non-senior level positions
  • Veteran and Disabled specific recruiting efforts for each AA location
  • EEO Postings at each AA location
  • Disabled Access at each AA location
  • EO Clause on Subcontracts and Purchase Orders

 

Results

By meeting these objectives the Federal Contractor will have an affirmative action program that complies with OFCCP regulations and meets the spirit of Executive Order 11246, Section 503 of the Rehabilitation Act, and the Vietnam Era Veterans Readjustment Assistance Act. Federal Contractor would expect a very high success rate in OFCCP compliance reviews. Potential financial liability and loss of any federal contracts would be minimized. Affirmative action compliance on state and municipal level would be enhanced. Federal Contractor attempts at future federal, state, and municipal contracts that require AAPs would be made easier.