SAMPLE AFFIRMATIVE ACTION PROGRAM (AAP)

The following sample AAP is for illustrative purposes only and does not represent the only styles and formats that meet regulatory requirements. While this sample has been constructed around a company with less than 150 employees, thereby allowing the AAP job groups to be formulated according to OFCCP occupational categories as authorized by 41 CFR 60-2.12(e), it may be used as a guide for larger employers.  

When preparing an AAP, it should be customized to reflect an employer’s organizational structure, policies, practices, programs, and data. Usually a separate AAP is required for each establishment. In appropriate circumstances, an establishment may include several facilities located at two or more sites if the facilities are in the same labor market or recruiting area.

In addition to the records an employer is required to compile and maintain to support the AAP [41 CFR 60-1.12 and 60-2.17(d)], the employer should also keep materials evidencing its affirmative action efforts. This may include items such as copies of collective bargaining agreements and other documents that indicate employment policies and practices; copies of letters sent to suppliers and vendors stating the EEO/affirmative action policy; copies of letters sent to recruitment sources and community organizations; and copies of contract language incorporating the regulatory EEO clause [41 CFR 60-1.4].  

FEDERAL CONTRACTOR, INC. (FCI)
EXECUTIVE ORDER 11246
SAMPLE AFFIRMATIVE ACTION PROGRAM

Title 41 CFR Section

Organizational Profile 60-2.11

Job Group Analysis 60-2.12

Utilization Analysis

Placement of Incumbents in Job Groups 60-2.13

Determining Availability 60-2.14

Comparing Incumbency to Availability 60-2.15

Placement Goals 60-2.16

Additional Required Elements 60-2.17

Designation of Responsibility for Implementation 60-2.17(a)

Identification of Problem Areas 60-2.17(b)

Action-Oriented Programs 60-2.17(c)

Internal Audit and Reporting System 60-2.17(d)

Support Data 60-2.17(b) and 60-3

General Requirement (optional inclusion in AAP)

Guidelines on Discrimination because of Religion or National Origin 60-50

Organizational Display

The Organizational Display is a detailed chart of the contractor’s organizational structure. For each organizational unit, the display must indicate the following: 

• The name of the unit and the job title, race and gender of the unit supervisor

• The total number of male and female incumbents and the total number of male and female incumbents in each of the following groups: Blacks, American Indians, Asians, Hispanics, and whites other than Hispanics.

Federal Contractor, Inc. (FCI)

Note that the organizational display shows each department, the race/sex of the supervisor(s) and employees within each department, and how all of the departments relate to each other.

Workforce Analysis  

Workforce Analysis 

Workforce Analysis 

Workforce Analysis 

Workforce Analysis 

Job Group Analysis:
Listing of Job Titles

Job Group Analysis:
Listing of Job Titles
 

Utilization Analysis:

Placement of Incumbents in Job Groups

Utilization Analysis:

Determining Availability

Utilization Analysis:

Comparing Incumbency to Availability
and
Establishing Placement Goals

*The 80% rule of thumb was followed in declaring underutilization and establishing goals when the actual employment of minorities or females is less than 80% of their availability. If the female/minority incumbency percent (%) is less than the female/minority availability percent (%) and the ratio of incumbency to availability is less than 80%, a placement goal should be included in the appropriate “If Yes” column.

Designation of Responsibility for Implementation

Responsibilities of the Equal Employment Opportunity Manager:

The Personnel Manager has the responsibility for designing and ensuring the effective implementation of Federal Contractor, Inc’s. (FCI’s) Affirmative Action Program (AAP). These responsibilities include, but are not limited to, the following:

1. Developing Equal Employment Opportunity (EEO) policy statements, affirmative action programs and internal and external communication procedures;

2. Assisting in the identification of AAP/EEO problem areas;

3. Assisting management in arriving at effective solutions to AAP/EEO problems;

4. Designing and implementing an internal audit and reporting system that:

a. Measures the effectiveness of FCI’s program;

b. Determines the degree to which AAP goals and objectives are met; and

c. Identifies the need for remedial action;

5. Keeping FCI’s General Manager informed of equal opportunity progress and reporting potential
   problem areas within the company through quarterly reports;
   

6. Reviewing the company’s AAP for qualified minorities and women with all managers and supervisors at all levels to ensure that the policy is understood and is followed in all personnel activities;

7. Auditing the contents of the company’s bulletin board to ensure compliance information is posted and up-to-date; and

8. Serving as liaison between FCI and enforcement agencies.

Responsibilities of Managers and Supervisors:

It is the responsibility of all managerial and supervisory staff to implement FCI’s AAP. These responsibilities include, but are not limited to:

1. Assisting in the identification of problem areas, formulating solutions, and establishing departmental goals and objectives when necessary;

2. Reviewing the qualifications of all applicants and employees to ensure qualified individuals are treated in a nondiscriminatory manner when hiring, promotion, transfer, and termination actions occur; and

3. Reviewing the job performance of each employee to assess whether personnel actions are justified based on the employee’s performance of his or her duties and responsibilities.

Identification of Problem Areas  

Action-Oriented Programs

FCI has instituted action programs to eliminate identified problem areas and to help achieve specific affirmative action goals. These programs include:

1. Conducting annual analyses of job descriptions to ensure they accurately reflect job functions;

2. Reviewing job descriptions by department and job title using job performance criteria;

3. Making job descriptions available to recruiting sources and available to all members of management involved in the recruiting, screening, selection and promotion processes;

4. Evaluating the total selection process to ensure freedom from bias through:

a. Reviewing job applications and other pre-employment forms to ensure information requested is job-related;

b. Evaluating selection methods that may have a disparate impact to ensure that they are job-related and consistent with business necessity;

c. Training personnel and management staff on proper interview techniques; and

d. Training in EEO for management and supervisory staff;

5. Using techniques to improve recruitment and increase the flow of minority and female applicants. FCI presently undertakes the following actions:

a. Include the phrase "Equal Opportunity/Affirmative Action Employer" in all printed employment advertisements;

b. Place help wanted advertisement, when appropriate, in local minority news media and women's interest media;

c. Disseminate information on job opportunities to organizations representing minorities, women and employment development agencies when job opportunities occur;

d. Encourage all employees to refer qualified applicants;

e. Actively recruit at secondary schools, junior colleges, colleges and universities with predominantly minority or female enrollments; and

f. Request employment agencies to refer qualified minorities and women;

6. Hiring a statistical consultant to help FCI perform a self-audit of its compensation practices; and

7. Ensuring that all employees are given equal opportunity for promotion. This is achieved by:

a. Posting promotional opportunities;

b. Offering counseling to assist employees in identifying promotional opportunities, training and educational programs to enhance promotions and opportunities for job rotation or transfer; and

c. Evaluating job requirements for promotion.

Internal Audit and Reporting System

The Personnel Manager has the responsibility for developing and preparing the formal documents of the AAP. The Personnel Manager is responsible for the effective implementation of the AAP; however, responsibility is likewise vested with each department manager and supervisor. FCI’s audit and reporting system is designed to:

• Measure the effectiveness of the AAP/EEO program;

• Document personnel activities;

• Identify problem areas where remedial action is needed; and

• Determine the degree to which FCI’s AAP goals and objectives have been obtained.

The following personnel activities are reviewed to ensure nondiscrimination and equal employment opportunity for all individuals without regard to their race, color, gender, religion, or national origin:

• Recruitment, advertising, and job application procedures;

• Hiring, promotion, upgrading, award of tenure, layoff, recall from layoff;

• Rates of pay and any other forms of compensation including fringe benefits;

• Job assignments, job classifications, job descriptions, and seniority lists;

• Sick leave, leaves or absence, or any other leave;

• Training, apprenticeships, attendance at professional meetings and conferences; and

• Any other term, condition, or privilege of employment.

The following documents are maintained as a component of FCI’s internal audit process:

1. An applicant flow log showing the name, race, sex, date of application, job title, interview status and the action taken for all individuals applying for job opportunities;

2. Summary data of external job offers and hires, promotions, resignations, terminations, and layoffs by job group and by sex and minority group identification;

3. Summary data of applicant flow by identifying, at least, total applicants, total minority applicants, and total female applicants for each position;

4. Maintenance of employment applications (not to exceed one year); and

5. Records pertaining to FCI’s compensation system.

FCI’s audit system includes a quarterly report documenting FCI’s efforts to achieve its EEO/AAP responsibilities. Managers and supervisors are asked to report any current or foreseeable EEO problem areas and are asked to outline their suggestions/recommendations for solutions. If problem areas arise, the manager or supervisor is to report problem areas immediately to the Personnel Manager. During quarterly reporting, the following occurs:

1. The Personnel Manager will discuss any problems relating to significant rejection ratios, EEO charges, etc., with the General Manager; and

2. The Personnel Manager will report the status of the FCI’s AAP goals and objectives to the General Manager. The Personnel Manager will recommend remedial actions for the effective implementation of the AAP.

Support Data:

Personnel Activity

Support Data:

Personnel Activity

Support Data:

Personnel Activity

Support Data:

Personnel Activity

Support Data:

Personnel Activity

Support Data:

Personnel Activity

Support Data:

Personnel Activity