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Presented to: Evergreen Packaging April 4, 2007

AAP Resource Group Specializing in Affirmation Action Preparation. Presented by: Adrian Bond President 3249 Winderly Pine Cove Memphis, TN 38125. Presented to: Evergreen Packaging April 4, 2007. Services. AAP Preparation Compliance Review Assistance Consultations Pre-audit Review

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Presented to: Evergreen Packaging April 4, 2007

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  1. AAP Resource GroupSpecializing in Affirmation Action Preparation Presented by: Adrian Bond President 3249 Winderly Pine Cove Memphis, TN 38125 Presented to: Evergreen Packaging April 4, 2007

  2. Services • AAP Preparation • Compliance Review Assistance • Consultations • Pre-audit Review • Adverse Impact Analysis • Applicant Flow Logs • Salary Equity Analysis • EO Surveys • EEO-1 Reports • VETS-100 Report • On-site Audit Support

  3. AAP Preparation We prepare all the requirements for a "full" Affirmative Action Plan, including: • Workforce Analysis • Job Group Analysis • Availability Analysis • Utilization Analysis • Full Census Data Support Documentation • Goal Setting Worksheet • Goal Achievement Worksheet • All Logs (applicant flow, hires, promotions, terminations) • Adverse Impact Analyses (hires, promotions, terminations) • Identification of Problems Areas • Good Faith Effort Narrative Summaries • Religion and National Origin • Establishment of Responsibility • Internal Audit and Reporting Systems • Development and Execution of Action Oriented Programs • Placement Goals • Lines of Progression • Annual Training • Analysis of Staffing Jobs • Entire Census Statistics for Each Facility • Population and Employment Statistics • Salary Code Listing • Pregnancy Related Disability Policy • Family and Medical Leave Policy • Affirmative Action Efforts/Sexual Harassment

  4. Compliance Review Assistance • In the event a government compliance review is initiated for your facility or location, we provide: • Assistance in preparing responses to the desk audit • Audit AAP prior to submission to the OFCCP • Assist in responding to the itemized listing prior to the compliance review • Availability for telephone assistance during the on-site part of the review • Available for on-site assistance during the on-site portion of the review and will provide professional and experienced advice • Assist in any reporting requirements resulting from a compliance review (federal, state or local)

  5. Consultations • We are available for on-going consulting to recommend corrective measures and procedures where our audits identify problem areas. Our fee includes unlimited telephone consulting support as well as unlimited off-site compliance evaluation (audit) support.  Tracking these recommendations and the actions taken can provide appropriate documentation on subsequent Affirmative Action Plans. • We can provide annual training seminars, either teleconference or live sessions to ensure that your staff stays knowledgeable and compliant on all current issues pertaining to the OFCCP and newly issued regulations.

  6. Pre-audit Review • Are you satisfied with completing your own affirmative action plan, but don't feel comfortable reviewing your plan for errors or "red flags" to the government?  We can take your completed plan and provide a detailed review of all areas to identify any potential problem areas.  Let us take the worry away.

  7. Adverse Impact Analysis • Do you understand the importance of conducting an adverse impact analysis?  We can provide you with the peace of mind in knowing whether or not you have adverse impact in any specific job group or within any specific transaction type.  This is a target area for the OFCCP during their initial review.   We can ensure you have all the necessary information needed to deliver your AAP with confidence.

  8. Applicant Flow Logs • Preparation and formatting of the applicant flow log can be a real hassle.  Our seasoned professionals can take your applicant and promotion data and prepare government compliant applicant flow log reports in the appropriate format.  Let us ease the burden of your AAP preparation.

  9. Internet Applicant Definition Four-Prong Rule: • Individual submits an expression of interest in employment through the Internet or related electronic technologies • Employer/Contractor considers the individual for employment in a particular position • Individual’s expression of interest indicates that the individual possesses the basic qualifications for the position • Individual at no point in the employer’s selection process, prior to receiving an offer of employment from the employer, removes him or herself from further consideration or otherwise indicates that he or she is no longer interested in the position

  10. Salary Equity Analysis • The OFCCP is looking for systemic discrimination, particularly in your compensation practices.  Our experts can provide a complete analysis of your compensation by grouping to ensure you are comfortable with your plan before submission.  Our analysis will identify and suggest recommended changes necessary to ensure your compensation is consistent and non-discriminatory.

  11. EEO-1/VETS-100 Reports • EEO-1 Reports • Each year every government contractor must submit their EEO-1 data in a standard format.  Preparation of the EEO-1 report is sometimes a cumbersome task.  Our consultants can take your employee information and provide you with the appropriate reporting for your annual submission.  We are here to help you with your compliance needs. • VETS-100 Reports • Just like the EEO-1, the VETS-100 and VETS-100A, must also be submitted to the OFCCP on an annual basis.  Let us take on your reporting needs and provide your report in an efficient and accurate manner.

  12. On-site Audit Support • When a compliance review escalates into a full-blown audit, the next step is an on-site audit from the OFCCP.  When that time comes, our experts can visit you on-site to help prepare for the audit and provide leadership and guidance during the audit itself.  Our staff of experts will provide valuable insights to help ensure success during the audit process.  We can help you when the questions arise and satisfy the necessary requirements of the auditor.  We become an extension of your company in representing you during the tough, uncomfortable process.  We want to be your partner to ensure a successful audit process.

  13. Client Input • Provide the AAP Resource Group with yearly updates on: • Applicant flow data • Profile data on all hires • Documentation on all promotions including other candidates • List of departmental and facility transfers • Data on all terminations • Report on training undertaken • Employment outreach activities • Community involvement activities

  14. Client Input • We request that all material be sent via e-mail to our secure e-mail address in Microsoft Excel file format. We will send you the spreadsheet each year for your employees to load pertinent employee and candidate information in regards to established reporting requirements for the OFCCP. With each spreadsheet that we send, we will include an explanation guide to assist your employees in the data submission process. There they will find all abbreviations and codes in a clear and intuitive manner.

  15. Termination Log

  16. Applicant Log

  17. Promotion Log

  18. EMPLOYEE DATA: 10/01/00 - 09/30/01 Note: Use salary column for exempt and non-exempt wages and hourly wages for hourly employees. If Salaried employee leave hourly column blank, and if Hourly employee leave salary column blank.

  19. Explanation Guide Here are the formats for the Employees, Applicants, Promotion, Termination Data. We would prefer the data be in excel format. Either attached the files to an Internet e-mail and send to aapresgrp@worldnet.att.net or mail a diskette with the files to: Allie Bond or Adrian Bond 3249 Winderly Pine CV Memphis TN 38125

  20. Employees Data Data formats for: • Employees: • Last Name • First Name • Middle Initial • Sex Code: • F=Female, M=Male • Race Code: • A=Asian, B=Black, H=Hispanic, I=Native American, W=White, N= Native Hawaiian, T=Two or more races • Job Title • JGC/EEO Code: • 1=Mgt, 2=Prof, 3=Tech, 4=Sales, 5=Clerical, 6=Craft Workers, 7-Operatives, 8=Laborers, 9=Service workers • FLSA: • H=Hourly, E=Exempt, N=Non-exempt • Department • Salary and/or Hourly Rate • Date of Hire

  21. Applicants Data Applicants (Should include all hires): • Last Name • First Name • Middle Initial • Sex Code: • F=Female, M=Male • Race Code: • A=Asian, B=Black, H=Hispanic, I=Native American, W=White, N= Native Hawaiian, T=Two or more races • Job Title • JGC/EEO: • 1=Mgt, 2=Prof, 3=Tech, 4=Sales, 5=Clerical, 6=Craft Workers, 7=Operatives, 8=Laborers, 9=Custodial • Dept • Date of Hire (if Hired) • Date of Applicant • Hire Source: • Advertisement, Job Service, Walk-in, Referral, etc. • Disposition: • Hired, Not Selected, Declined offer, etc.

  22. Promotion & Transfers Data Promotions & Transfers (This should also include any candidate not selected): • Last Name • First Name • Middle Initial • Sex Code: • F=Female, M=Male • Race Code: • A=Asian, B=Black, H=Hispanic, I=Native American, W=White, N= Native Hawaiian, T=Two or more races • Old Job title • Old JGC/EEO • Old Department • P Type Code: • P=Promotion, T=Transfer, C=Candidate for promotion • Date of Promotion/Transfer/Candidate • New Job title • New JGC/ EEO code • New Department

  23. Terminations Data Terminations: • Last Name • First Name • Middle Initial • Sex Code: • F=Female, M=Male • Race Code: • A=Asian, B=Black, H=Hispanic, I=Native American, W=White, N= Native Hawaiian, T=Two or more races • Job Title • JGC/EEO Code: • 1=Mgt, 2=Prof, 3=Tech, 4=Sales, 5=Clerical, 6=Craft Workers, 7=Operatives, 8=Laborers, 9=Custodial • Department • Date of Terminations • Termination Reason

  24. Technical and Security Related Issues • All data submission is sent to a secure e-mail address. • No new hardware is needed on your part for this data submission. • Data can be sent to our company 24hrs. a day, 7 days a week. • Client Data is kept on a secure server accessible via secured access by appointed nominated personnel. • Transmitted data files to be password protected and via encrypted. • AAP Resource Group retains a state of the art secured firewall that has 24-hr continuous monitoring and daily sweeps to ensure optimal performance and operation. • Virus protection on all servers. • Data centers are housed in two different locations with daily backup of all client data nightly and regularly rotated to offsite storage. • Backup data can be received within a few hours creating minimal downtime in the event of crisis, usually within four hours. • Company maintains video conferencing capabilities to communicate with clients in a cost effective manner for both parties. • Company retains highly trained and skilled IT and Network professionals to create, edit and test reporting on an on-going basis. • Company has the ability to produce on-demand reporting as well as custom-developed reporting based on clients’ needs.

  25. Federal Contractor Obligations Under Executive Order #11246

  26. Federal Contractor Obligation • Understand the laws & federal contractor obligations

  27. Equal Opportunity Laws • The Civil Rights Act of 1964 • The Civil Rights Act of 1991 • Executive Order 11246 • The Age Discrimination in Employment Act of 1967 • The Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 • The Equal Pay Act of 1963 • The Vietnam Era Veterans Readjustment Assistance Act

  28. Federal Contractor Obligations Under Executive Order #11246 • EEO meetings must be conducted once annually • EEO posters must be posted at each establishment • EEO statement must appear in all advertising • Submission of EEO-1 • EEO clauses must be included in each subcontract • Certification of non-segregated facilities

  29. Federal Contractor Obligations Under Executive Order #11246 (cont’d) • Support Data must be maintained. • Applicant Flow Log • Resumes and employment applications must be maintained for the current plus two previous years. • Candidate assessment forms are to be kept for the same period as the resumes and applications. • The Voluntary Self-Identification form, which is attached to most companies employment application, is maintained in a separate file after completion.

  30. Federal Contractor Obligations Under Executive Order #11246 (cont’d) • Support Data ... • Promotions Flow Log • A record of candidates considered for any open position must be maintained utilizing the same record retention policy for applicants. • The HR professional should strive to make certain there is diversity in candidates for all open positions.

  31. Federal Contractor Obligations Under Executive Order #11246 (cont’d) • Support Data ... • Termination Log • Logs of terminated employees are maintained with job title, race, sex, hire date, termination date, and reason for leaving. • The record retention policy for maintaining the termination dates is the same as for hires and promotions.

  32. Federal Contractor Obligations Under Executive Order #11246 (cont’d) • Support Data ... • I-9's • I-9's must be completed on all employees prior to commencing employment with the company. • They must be maintained in a file separate from the personnel file. • I-9's are to be audited on a periodic basis for accuracy to avoid possible liability as a result of incorrect information.

  33. Federal Contractor Obligations Under Executive Order #11246 (cont’d) • Hiring practices must be analyzed • Adverse Impact analysis must be conducted • Copies of all letters mailed to minority, female, disabled and veterans organizations must be maintained • Documentation of career fairs and other community involvement related to employment must also be kept by the location • Copies of help-wanted ads must contain the Equal Employment Opportunity tag line (EOE M/F/D/V) • The location is expected to maintain a sample copy of various newspaper ads

  34. Vietnam ERA Veterans Readjustment Assistance Act Obligations • VEVRAA Affirmative Action Program must be prepared and made available upon request for review by employees, applicants, customers, and vendors • VEVRAA Affirmative Action clauses must be included in subcontracts • All jobs (external hires) must be listed with the local employment security commission except top management positions, college recruiting positions and those positions expected to last three days or less

  35. Vietnam ERA Veterans Readjustment Assistance Act Obligations (cont’d) • Letters or phone logs verifying conversation with the local Employment Security Commission informing them of our government contractor responsibility of having a diverse workforce, based on availability, must be maintained

  36. Obligations Under Section 503 of the Rehabilitation Act of 1973 • Self-Identification Invitation • Affirmative Action Clauses in Subcontracts • Employee and applicant access to the Affirmative Action Program must be given, and a poster indicating time and location must be posted. • Disability Poster Notices • Union notification • Review of outreach and recruitment practices. • Review of personnel processes to ensure consideration of job qualifications of known disabled applicants and employees.

  37. Compliance Review Results • Compliance reviews can end in either: • Letter of Compliance • Letter of Compliance with a Violation • Conciliation Agreement • Show Cause

  38. Questions • Have a note at the bottom that further questions can be directed to aapresgrp@att.net. Or we can be reached by phone at 901-748-1650 or 901-218-6434.

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