Minorities & Women
A written Affirmative Action Program for Minorities and Women (AAP) should satisfy equal employment opportunity/affirmative action (EEO/AA) obligations under Executive Order 11246, as amended, and the implementing rules and regulations of that Order under the Secretary of Labor. Contractors are required to annually update AAPs with new workforce data, typically using a snapshot of the U.S. payroll population taken on the first day of the AAP year. The main elements of the statistical analyses include:
- An organizational profile or workforce analysis depicting the staffing pattern within an AAP establishment, with most contractors using the workforce analysis format. This array of the Company’s workforce may be used by the OFCCP to identify organizational units where minorities and women are “under-represented or concentrated.”
- A job group analysis which attempts to group jobs in such a way that they can ultimately be compared to external census data. The analysis provides a horizontal view of similar jobs across department lines.
- An availability analysis which estimates the number of minorities or women in the internal workforce and in the external recruitment area with the skills required for the jobs in a specific job group. Two availability estimates are established for each job group — one for minorities and one for women.
- A comparison of availability estimates (availability) to the number of minorities and women actually employed in each job group (incumbency).
- The establishment of placement rate goals wherever the difference between estimated availability and incumbency rates cannot be reasonably attributed to chance. The purpose of establishing placement goals in an affirmative action program is to provide contractors with concrete targets against which progress can be measured — they are not quotas.
Regulations also require a contractor analyze its total employment process to determine whether and where impediments to equal employment opportunity might exist. This narrative analysis must include Identification of Problem Areas and Action-Oriented Programs covering, at a minimum:
- An evaluation of the workforce (by organizational unit and job group). This typically includes a summary of the results from the workforce and job group analysis, as well as a written, qualitative review of those results.
- An analysis of personnel activity, including but not necessarily limited to: applicants, hires, promotions, demotions, transfers, and terminations of any kind. In addition to a narrative summary and analysis of relevant polices, data analysis completed outside of the written AAP, but related to this section, might include: calculation of change in the employee population; analysis of progress against prior year placement goals; summary of employment activity data transactions by race/ethnicity, gender, and job group; a comparison of applicant flow rates to estimated availability rates by job group; and disparate impact analysis of competitive selections such as hires, promotions, and reduction-in-force terminations.
- A review of compensation policies, procedures, and practices. Additionally, an analysis of compensation by race/ethnicity, gender, and job title generally accompanies, but is conducted outside of, the written AAP.
- An evaluation of employment systems and procedures, including a summary of relevant policies, how they are disseminated throughout the organization, and a discussion of evaluation methods.