Recruiting Compliance 101Annette RostaAssociate Director, Recruiting Diversity &Compliance
2© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepen...
3© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepen...
4© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepen...
5© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepen...
6© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepen...
7© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepen...
8© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepen...
9© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepen...
10© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
11© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
12© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
13© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
14© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
15© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
16© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
17© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
18© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
19© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
20© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
21© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
22© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
23© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
24© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
25© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
26© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
27© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
28© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
29© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of indepe...
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Compliance 101 Training for Recruiters

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Part of the Focus on Compliance Webinar Series: May 1–2, 2013, "Compliance 101 Training for Recruiters" will help you learn more about the federal obligations and a recruiter’s role in helping to ensure the company meets the hiring obligations and maintains their status as a federal contractor.

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Compliance 101 Training for Recruiters

  1. 1. Recruiting Compliance 101Annette RostaAssociate Director, Recruiting Diversity &Compliance
  2. 2. 2© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Background:• Twenty years in recruiting function for employers who are Federal Contactors• Nine years as a recruiter for various industry employers and for all level positions,from Administrative Assistants to Executive Leaders with over 1200 personnelrecruited.• Implemented two ATSs and developed Compliance processes from ground up.• Worked through and prepared recruiting documentation for dozens of successfulaudits/reviews.• Educated recruiters enough about Recruiting Compliance that they now hold otherrecruiters accountable.
  3. 3. 3© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.AgendaØ What it means to recruit for a Federal ContractorØ Who are OFCCP and what do they do?Ø What are the expectations of a recruiter when recruiting for a Federal Contractor?Ø What are recruiters’ compliance requirements?•  Equal Employment Opportunity•  Diversity Outreach•  Record Keeping/DocumentationØ Recruiter’s role to ensure complianceØ What are the potential risk to company when compliance expectations are not met?Ø Why else is Recruiting Compliance important?Ø Why is Diversity Recruiting Important for Compliance?
  4. 4. 4© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.What are the Qualifications for being a FederalContractor?Each non-construction contractor/subcontractor with 50 or moreemployees is required to develop a written Affirmative Action Program(AAP) for each of its establishments if it:Has a Federal contract or subcontract of $50,000 or more;Has government bills of lading which in any 12-month period total, orcan reasonably be expected to total, $50,000 or more;Serves as a depository of Federal funds in any amount; orIs a financial institution that is an issuing and paying agent for U.S.savings bonds and savings notes in any amount.
  5. 5. 5© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Who Monitors the Federal Contractors EmploymentPractice?An arm of Department of Labor called: Officeof Federal Contractors CompliancePrograms (O F C C P)
  6. 6. 6© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.What is the OFCCP?The OFCCP an arm of theDepartment of Labor, is responsiblefor ensuring that contractors doingbusiness with the Federalgovernment does not discriminateand take affirmative action.Review the Affirmative Action Programsof Federal Suppliers/ContractorsEnsure Contractors comply with EEOContract clauses.Investigates impact on Hiring,Promotion, Terminations, andCompensation decisions on Females,Minorities, Veterans, and people withdisability.
  7. 7. 7© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Colleagues with Compliance ExpectationsHiringPromotionTerminationsCompensation
  8. 8. 8© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Compliance Expectations of the RecruiterUse recruiting tools and resources to findthe best qualified applicant, includingdiversity outreach tools and resources for adiversified pool of talent.Make sure all candidates are treatedequally.Positions have been posted as appropriate.Process to considering candidates andinterviewing applicants is documented andthe feedback is available.Decisions to move forward with individualsare based on assessment of diverse pool ofqualified applicants and not on “gut”instinct.All job file material clearly supports actionsof selecting individuals.
  9. 9. 9© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.How the OFCCP Monitors Federal Contractors?Selection is made on which Federal Contactor to ReviewCompanies and it’s establishment are selected for evaluation from Federal Contractor Selectionsystem.Scheduling Letter Received - We have an Audit!This is considered the start of the Compliance EvaluationRequest of AAP and supporting data (Applicant data, Job Group Analysis, Outreach Efforts)Evaluation Process
  10. 10. 10© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.What are the stages of Evaluation Process?A compliance evaluation consists of any one or any combination of thefollowing three investigative procedures:■  Desk Audit■  Off-Site Review■  Focused Review/On-Site ReviewImpact on Recruiter during evaluation process:■  Request of applicant flow logs or confirmation /clarification of Applicant Data■  Review of job files and confirmation/clarification of job file material■  Request for additional outreach efforts made for positions where goals identifiedfor positions
  11. 11. 11© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.OFCCP Tasks in Evaluation ProcessOFCCP starts with statisticsMay move to review other materials for evidence of discrimination,especially where statistical significance is foundMay move to review the job file: resumes, job postings, jobdescriptions, interview notes, etc.OFCCP looks for connection between positions where there werehires and the applicants for these positionsHire data during previous AAP yearApplicant data for applicants associated with these hiresNote: Review of Applicant data is a key component of OFCCP audit/investigation
  12. 12. 12© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Red Flags the OFCCP is looking forApplicant to Hire RatioOFCCP is looking for many applicants to correspond to each hireLow ratio can lead to questions … “Going to get Questions!”■  Did the recruiter not track?■  Did the recruiter not consider a diverse pool of applicants?NOTE: Failure to track applicant flow data is a “technical” violationand may lead to allegations of discriminationImpact Ratio Analysis (IRAs): Representation of Females andMinorities in applicant poolOFCCP will look for significant discrepancies between “representation” ofF/M in applicant pool and availability of F/M in recruitment area
  13. 13. 13© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Key Areas the OFCCP Monitors:
  14. 14. 14© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Ensure Equal Employment OpportunityTo ensure a company’s establishment provides equal opportunity to be employed, theOFCCP will review:EEO-1 AnalysisAffirmative Action ProgramsApplicant Flow LogsRecruiter’s role to assist with the analysis of Equal Employment Opportunity:■  Ensuring as an organization the applicant to hire ratio is adequate to assist in illustrating thatthe company is considering a diverse applicant pool■  Ensuring the Applicant Flow Logs data is accurate and consistent with job file and new hirerecord data■  Ensuring the Applicant Flow Logs captures all applicants
  15. 15. 15© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Outreach Effort and RecruitmentWhat outreach efforts can wedemonstrate to recruit individuals inthose groups where we have a goal?Job Posting - Do we make ouropportunities available to allindividuals, including to state andlocal employment agencies?What events or organizations do weparticipate in to reach out toindividuals with diversebackgrounds?What has the recruiter donespecifically to attract a diverse talentpool?
  16. 16. 16© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Why we should outreach and encourage diverseworkforce?Government Requirement: as a recruiter for Federal Contractor it is part of ourdaily responsibilities.Company Responsibility: An increase in productivity, performance, teamwork,ability to attract and retain top talent, improve morale, and align with company valuesAn increase in the company’s ability to understand and appeal to an increasingly diversemarketplaceAn improvement in overall organizational effectiveness and because our clients expect towork with other employers who encourage a diverse workplaceDiverse teams make better decisions than homogeneous ones, are more creative, andhandle complex challenges more effectively. Yet when organizations manage diversity-related conflicts poorly, talented performers flee in search of more welcomingenvironments.We need diversity of thought in the world to face the new challenges. –Tim Berners-Lee
  17. 17. 17© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Record Keeping/DocumentationWhy Records are important• Documents the Selection Process• Supports Decisions• Enables Self-MonitoringFailure to Keep Records• Constitutes noncompliance• May allow a presumption ofdiscrimination or negative inferenceNote: OFCCP said “electronicrecords are easier for auditors”
  18. 18. 18© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Applicant Records and Job File MaterialsJob Files should be retained for allpositions a search was conductedand either filled internally orexternally – cancelled or filled.All Job Files (electronic/hard copy)should contain all accurate andcomplete data relevant to therequisition, the new hire, and allapplicants considered for theposition.OFCCP Rule…Lack of documentationleads to unfavorably conclude theemployer has done wrong and ispotentially with holding information,or knowingly did not keepappropriate records.
  19. 19. 19© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.ü Job Responsibilities and BasicQualificationsü Resume of each candidateconsideredü Evidence of posting to StateWorkforce Agencyü Employment Application (ordocumentation of effort to obtain)ü Evidence of all advertisements, (jobboard posting and print):ü Opportunity to self identify throughthe Affirmative Action Survey onGender and Race/Ethnicityü Evidence of Good Faith/DiversityOutreach Effortsü Interview Evaluation Feedback on allapplicants by all interviewersü Evidence of Internal and ExternalSearch and any DMTs used to searchü Reason for Rejection on applicantswho don’t receive an offerü Documentation of all externalrecruitment sources usedü Copy of all Offer Letters sentThis checklist helps to ensure all job file materials are available for quick referenceand submittal upon request.EEO Job File Checklist:
  20. 20. 20© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Record Keeping GuidelinesPosting Data/Job DescriptionExternal Postings - All regular positions where an external candidate is goingto be considered must be posted to the State Workforce Agency. This is anabsolute requirement.–  Basic Qualifications■  Must be Objective■  Must be non-comparative features of a job seeker■  Must be job-relatedGood Faith Outreach Efforts – Any outreach efforts made to recruitAdditional postings/advertisements - Any postings to industry, niche,major job board and/or any print advertisementsAny external resources used – Documentation of any external resourcesfor example Contingency Search or Retained Search firm.
  21. 21. 21© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Record Keeping Guidelines, ContinuedSearching Data – internal/external searchesInternal and External Searches - contractor must maintain a record of:Specific position for which each search was madeThe substantive search criteria used in the searchDate of the searchEach resume considered as a result of searchData Management Technique - If there are a large number of expressions ofinterest, a contractor may use data management techniques to reduce the numberconsidered.
  22. 22. 22© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Record Keeping Guidelines, continuedApplicant DataResume – of all internal and external candidatesEmployment Application – provide all applicants opportunity to completeInterview Evaluation Feedback – feedback must be completed by eachinterviewer for each applicant, including the recruiter and each member of thehiring team who met with each applicant.Rejection Reason – For every applicant not selected to move forward andbe made an offer, there must be a documented reason why they wererejected.Offer Letters Sent – Must retain all offer letters sent to any applicant,including those who decline the offer.
  23. 23. 23© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Why else do we collect AFLs/Applicant Data and Diversity Initiatives?AFLs and Diversity Initiatives are also used for:■  Federal Audits■  State and Local Audits■  Affirmative Action Program■  RFPs■  Litigation Matters■  “Best X List”■  Recruiting Organization Business Decisions
  24. 24. 24© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.What are the possible outcomes of and audit?Closure Letter – Letter of Compliance - GoodClosure Letter with Minor Violations or Notice ofViolation – Minor violations (such as record keeping violations). - BadConciliation Agreement – Signed agreement to be monitoredmore closely and rectify all sited violations. UglyDebarment – lose ability to retain the government as a client. Worst CaseScenario
  25. 25. 25© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Closure LettersThe Good – Letter of Compliance:■  Opportunity to self monitor and identify areas of self improvement■  We know being Compliance Smart is being business savvy – It’s not just about mitigatingrisk, but about doing the Right thing in the Right way.The Bad – Letter with Minor Violations or Notice of Violation:■  Found to be noncompliant, but while no formal written signed agreement , the OFCCP maymake recommendations on areas to improve or correct.
  26. 26. 26© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.The Ugly – The Conciliation AgreementWhat is a Conciliation Agreement and the potentialoutcomes of having one?Significant alleged violations found such as discrimination, failure to engage ingood faith Affirmative Action effort or Major Record Keeping violations. Asettlement agreement which the federal contractor would sign off on withOFCCP’s proposed remedies for correcting violations.Potential Outcomes of a Conciliation Agreement:■  Loss of Federal Contracts■  Public Humiliation■  Loss of current and future clients and employees because we lack integrity■  Pay out to applicants who were potentially discriminated against■  Financial Remedies■  Revamp of all employment policies/practices and training
  27. 27. 27© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Worst Case Scenario OutcomeDebarmentBan from Current/Future Client ContractsTreatment: The Federal Contractor and its officers, agents, successors,divisions and subsidiaries are ineligible for the award of any contract orsubcontract funded, in whole, or part, with funds from any agency, or for theextension or other modification of existing contracts or subcontracts.Debarment is for an indefinite period of time pending the Federal Contractorscompliance with OFCCP regulations, or for a fixed period of not less than sixmonths. Therefore, the termination date will be listed as the ending date of suchas a fixed period, or as "Indefinite" (Indef.)Organizations that have faced debarment can be found on theExcluded Parties Listing System link based off the OFCCP Home web site.
  28. 28. 28© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Personal Impact of Conciliation AgreementWhat this means for Leadership andthe Recruiter?Company’s Consequences –Leadership would have to signagreement to submit reports to OFCCPon established time basis. Basically,signs agreement that they will beresponsible for the outcome of allinvestigations, analysis of reports, anddata collected on applicants andemployees.Recruiter’s Consequences –• Poor reflection on you• Responsible for providing completedocumentation on each step of eachapplicant of each search in the selectionprocess• Pressure of continuous scrutiny fromOFCCP, Leadership, HR EEO Group
  29. 29. 29© 2012 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independentfirms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority toobligate or bind KPMG International or any other member firm third parties, nor does KPMG International have any such authority toobligate or bind any member firm. All rights reserved.Why do we need to know compliance?To maintain status of a federal contractorTo avoid being part of discrimination statistics and litigationsettlementsTo help ensure our business clients are making the best staffingdecisionsTo mitigate any risk concerning discrimination to your companyTo articulate transactions when asked by HR or Compliance OfficerTo understand our social obligations to all individualsAudit process will be more intense going forward, best to be ready
  30. 30. QUESTIONS?
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