AAP Education for Managers
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This document outlines an affirmative action plan for managers at a company. It discusses who is covered under the plan, including contractors over $10,000 and organizations subject to civil rights requirements. It also outlines requirements to develop a written affirmative action program within 120 days and conduct internal audits. The plan discusses monitoring compliance through reviews and checks of practices and records. It also states that an employer should not override an individual's self-identified race, gender or ethnicity.
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AAP Education for Managers
- 1. Affirmative Action Plan Education for Managers Gabriela Rosas Human Resource Vice President
- 2. Overview • Who is Covered • Requirements • Monitoring • Overriding Self Identification • Compliance Assistance
- 3. Who is Covered • All contractors and subcontractor who hold a Federal or federally-assisted construction contract in excess of $10,000 • Any organization that is subject to civil rights requirements enforced by OFCCP • Businesses or organizations that do not hold government contracts/subcontracts that may still be covered under laws enforced by OFCCP if they are considered a “single entity”
- 4. Requirements • Under EO 11246 if we have more than 50 employees we are required to develop a written Affirmative Action Program for each it the establishments within 120 days from the start of the contract • It is suggested that employers create and follow an internal audit and reporting system to make necessary changes, improvements and maintain compliance • Posting of EEO posters, this is in accordance with the laws administered by OFCCP • Posted prominently where it can be readily seen by employees and applicants • EX. Breakroom, officers, bulleting boards
- 5. Monitoring • Compliance Evaluation is a combination of four investigative procedures: • Compliance Review • Comprehensive analysis of practices • Begins with desk audit (review of AAP) • Off-Site Review • Review of records that could consist of a full desk audit • Focused Review • On site review restricted to one or more components or organizations practices • Compliance Check • Determining if contractor has maintained consistent records
- 6. Overriding Self Identification • Q: May an employer override an individual’s self-identification of race, gender or ethnicity based on the employer’s visual observation? • A: NO! OFCCP’s policy is that deference should be give to an individual’s self-identification and it SHOULD NOT be questioned or overridden by an employer
- 7. Compliance Assistance • Additional OFCCP requirement education can be obtained by visiting local OFCCP and register for seminars or visit: • http://www.dol.gov/ofccp/regs/compliance/faqs/emprfaqs.ht m#Q26
- 8. Conclusion • Who is Covered • Requirements • Monitoring • Overriding Self Identification • Compliance Assistance
Editor's Notes
- Good afternoon management! I wanted to take a moment and give you a baseline for our AAP program. As managers it is very important we understand the legalities around this program. Let’s get started.
- Here is an overview of the topics we will cover today.
- Let’s start off by discussing who is covered by this. Any organization or business that is subject to the civil rights requirements that the OFCCP enforces, are included, as well as, any organization or business that can be considered a single entity.
- Now as management staff is it important to understand what is required from all of us. Under Executive Order 11246 we are required to maintain an Affirmative Action Program. Additionally we are also required to post all EEO posters where employees and applicants can readily see them. Lastly. It comes highly recommended that we develop an internal auditing system to make sure we are always within compliance standards. There is currently not a guide created by the OFCCP but they are working on one as are we.
- Going along with the recommendation for self audits lets discuss some of the ways we are monitored by OFCCP. A compliance evaluation is a combination of four investigative procedure that include: compliance review, off site review, focused review and a compliance check. Each of these involve the review of employee records in some form of another and also a review of our AAP. For these reasons it is important to conduct self audits and maintain situational awareness on the status of our processes and practices
- Now a frequent question that comes up surrounding this topic is “May an employer override an individuals self identification of race, gender or ethnicity based on the employer’s visual observation?” Before answering that question let’s take a moment to think about it and when ready click next. The answer is NO. OFCCP’s policy is that deference should be give to an individual’s self-identification and it SHOULD NOT be questioned or overridden by an employer. Bottom line.
- Now while I may be able to provide you with a baseline for the AAP please take advantage of all the other resources available to you. Our local OFCCP office provides seminars on how to maintain compliance and much more. Please feel free to check them out. You might even see me at one! The website is also provided to allow you to explore more about this topic and other FAQ.
- These are the topics we discussed today, pending any questions this concludes my presentation. Thank you.