By Julia Mendez Fuentes, PHR, CELS
I am often asked by federal contractors and subcontractors to share my “biggest secret” for a successful affirmative action program (AAP).
Come closer while I whisper the secret in your ear — ACCOUNTABILITY!
The importance of accountability cannot be over emphasized. It’s about building accountability into your AAP, not just with your own personnel but with the recruiters who send you candidates to initiate the hiring process.
In many organizations, only a single person, who is typically designated as the EEO Officer, is responsible for the preparation of the AAP when there may be an entire army of people who do the hiring.
No matter how many EEO Officers you might have in your organization, you must remember that the AAP cannot reach its potential without the assistance of every manager who is responsible for making personnel decisions.
That’s why it’s so important to hold managers and recruiters accountable for the success of the AAP.
Keep in mind, you are required by Executive Order 11246 to develop action-oriented programs that are specific and results oriented. This makes it easier for you to apply objective performance measures to determine the success of your efforts against your placement goals.
As you may know, placement goals are targets that your organization has identified for filling vacancies — in certain job groups, and at a rate set by your organization based on the number of minority and/or female incumbents that would reasonably be expected given the recruitment, hiring, promotion and transfer practices of your organization.
For example, if you have a placement goal related to minorities in the engineering job group, your action-oriented program might be to start an internship program for engineering students from historically black universities. This promotes on-the-job training and familiarity with your organization by potential minority candidates — two things that may make such individuals more likely to apply for job openings with your organization upon graduation.
Keeping with this example, another action-oriented program might be to post job openings in minority-based publications that cater to engineers.
It is not acceptable to merely create an action plan that calls for an increase in recruiting efforts. Such a vague action plan would more than likely form the basis of a technical violation during an OFCCP compliance review — not to mention how much it would complicate your ability to objectively measure the success of your program.
How do you get managers to assist you in reaching your placement goals? …Hold them accountable.
It may not be reasonable to hold managers accountable for progress toward placement goals if they haven’t been properly trained.
Only about half of the participants who attended a recent Webinar sponsored by Peopleclick Authoria reported that managers are held accountable for progress within the AAP.
What does this say about the other half?
It’s critical to hold management meetings at least annually as required by Affirmative Action regulations — not only to educate managers on AAP terminology, but also to guide managers on what they can do to meet goals set by the organization.
Your organization should also perform statistical analyses at the management level. This will help determine how much progress each manager is making and identify gaps where more can be done.
If your office manager, for example, has a goal related to minorities within the clerical job group, that goal must be communicated and the manager held accountable for developing action-oriented steps.
Ask the manager to keep track of things like the internal training given to employees to develop the necessary skills to apply for positions within a particular job as well as efforts related to career fairs, internship programs and any relevant communication programs like an employee referral program. Then formulate a plan for evaluating the effectiveness of these efforts. Perhaps a log of sorts, which tracks the specific effort, such as attending a career fair at XYZ University, and then keeping track of all of the candidates that came from that recruitment effort and the disposition for each candidate (e.g. did not meet qualifications/did not interview, hired, declined job offer, etc.). This process will assist management with assessing which good-faith efforts were most effective.
If minorities are not applying for clerical positions, is it the manager’s fault? If the manager is also responsible for recruiting applicants, then you should certainly investigate possible causes for the absence of qualified candidates.
Start with a review of the availability of minorities within the clerical EEO classification within the recruitment area. Perhaps the 2000 Census EEO File reports a low availability of minorities with skills you are looking for in a particular job group.
In this case, it would make sense to see a low pool of minority applicants. It would be another story if the Census EEO File shows that 60% of the clerical population with requisite skills to be minorities.
As noted earlier, any designated recruiters used by your organization should also be held accountable for meeting placement goals.
Recruiters should not only focus their efforts on targeted sources such as career shows, on-line recruitment services etc., but those sources should also be targeted to filling the specific types of positions in which you are deficient.
It’s not sufficient for a recruiter to attract 100 minorities to apply for a particular position if the applicants are not qualified. The quality of candidates is just as important — if not more so — than the quantity of candidates.
Some 54% of the attendees at a Webinar I recently presented, Beyond the Written AAP, also reported that they hold management meetings once a year to discuss their AAP while 19% said that they have meetings twice a year. Another 14% hold meetings more than twice a year while the remainder of participants didn’t have any management meetings.
How comfortable would you feel about meeting your AAP goals and objectives knowing that managers have not been properly trained on their obligations and don’t even know the goals and objectives for the year? You cannot expect any employee to perform to the best of their ability under such conditions.
Webinar participants were asked if their organization tied management performance evaluations to AAP goals and objectives.
Surprisingly, 6% of participants answered in the affirmative; 79% indicated that they did not incorporate AAP objectives on performance evaluations and 15% did not know.
Without accountability, there is no incentive for managers to assist the EEO Officer in making progress toward the company’s AAP goals and objectives.
Many times, the key to getting buy-in from managers and recruiters is to ensure that top management conveys the importance of meeting placement goals.
Having your CEO, chairman, president and/or business unit manager articulate a commitment to affirmative action is an enormous plus. But there’s no substitute for properly training managers and recruiters on how to interpret the AAP and then holding them accountable for success.
Julia Mendez Fuentes is Director of Workforce Compliance and Diversity Solutions for Peopleclick Research Institute. For the past 15 years, Ms. Fuentes has assisted companies in the areas of compliance equal opportunity and affirmative action laws and regulations as well as assisting with diversity efforts. She leads the Metairie (New Orleans), LA team as well as the Diversity Council for the organization. She has assisted numerous clients in successfully preparing for an OFCCP compliance review. Ms. Fuentes also speaks on various topics related to EEO, affirmative action and diversity and has spoken on numerous occasions at events including local, regional and national conferences, seminars and webinars. For more information regarding upcoming webinars, training offerings, or speaking engagements, email Julia.Fuentes@peopleclickauthoria.com. Ms. Mendez Fuentes is also a member of the AAAA Board of Directors.
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