1H02 Contractor Review of Personnel Processes

An AAP, to be acceptable, must affirm that the contractor reviews its personnel processes periodically. These processes must provide for the careful, thorough and systematic consideration of the job qualifications of applicants and employees who are known protected veterans for job vacancies either filled by hiring or promotion, and for all training opportunities offered or available. A contractor’s AAP must describe the review, include the date the review was performed, and describe actions taken or changes made as a result of the review.51

a. Use of Appendix C. Though not required, contractors may utilize the procedures described in Appendix C to 41 CFR Part 60-300 to fulfill this requirement. These procedures describe how contractors annotate applications or personnel forms of protected veterans when considering them for employment opportunities.

b. Adequacy of Present Procedures. Contractors may assert that their present personnel procedures are adequate and indicate that modifications to the procedures are unnecessary. COs must determine whether the information received during the desk audit supports that assertion to determine acceptability. COs must request additional information during the desk audit or on-site review if they are unable to make an acceptability determination.

c. Relevancy of Military Records. Contractors must rely only on the portion of a protected veteran’s military record that is relevant to the requirements of the opportunity for which the veteran is being considered. The contractor should confirm compliance with this requirement in the AAP.

d. Adverse Stereotyping. Part of the contractor’s review must be to ensure that its personnel processes are not stereotyping protected veterans in a manner that limits their access to jobs for which they are qualified.