The contractor must design and implement internal audit and reporting systems that measure the effectiveness of the total AAP. During an on-site review, COs must ask appropriate officials, including management, how the contractor conducts its audits and request documentation of how the contractor reports the results of internal EEO and affirmative action audits. COs must request documentation in the form of copies of reports or copies of minutes of meetings.
Below are several examples of relevant questions COs should ask contractors about their auditing and reporting system.
- How does the contractor audit its personnel activity to ensure the nondiscrimination policy is carried out?
- Who is responsible for conducting the audit?
- What is involved in the audit?
- How frequently does the contractor conduct the audit?
- What is the schedule for the contractor’s report on whether and to what degree EEO and organizational objectives are obtained?
- When and how is the report reviewed by each level of management? Do the CEO and other high ranking officials receive the report?
- What types of recommendations have been made to improve when the report indicates that the total AAP is ineffective?