4D00 Analysis of Nonfavored Groups’ Management Level Participation

A CO should determine whether there is a marked decline in the participation of specific groups of individuals. This section covers conducting an analysis and determining the participation rates for nonfavored groups in top and middle management.

As a general rule, a corporation selected for a CMCE should be large enough to have job groups extending beyond the standard EEO-1 categories. Therefore, the top management level may be immediately evident from a scan of the job group analysis. When this is not the case, actual job titles, in conjunction with reporting relationship to the CEO, are usually reliable indicators of the top management level.

Typical titles at top levels include Executive Vice-President, Senior Vice-President, Comptroller, Chief Financial Officer and Vice-President. Reporting relationships are usually reflected in the corporation’s organizational charts. The very top level consists of individuals reporting directly to the CEO; the second level consists of those individuals who report directly to the top-level managers. While the number of reporting levels regarded as “top management” varies with the size and structure of the particular corporation, more than three levels down at the headquarters establishment is usually considered middle management. People at that middle corporate level may, in turn, be top management at subordinate establishments.

Middle management is different. Again, the job group analysis may be the easiest way of determining what positions large corporations classify as middle management. However, when that is not the case, salary may be a more reliable determinant than title. It may be best for COs to use salary level, range or grade as reflected in the workforce analysis or organizational display to identify where nonfavored group participation declines.

When management levels are still unclear, COs must obtain more information before proceeding by contacting corporate human resources and making a request for clarification. Assuming management levels are defined, COs would move to their analysis of nonfavored group participation at these levels.

a. Analyzing Nonfavored Group Participation. In addition to analyzing and utilizing the normal EEO trend data, COs must conduct a breakout analysis specifically of the O&M categories. COs should total the number of O&M jobs by grade, race, ethnicity, sex and disability status across department lines. In doing so, they must keep track of the departments in order to examine the functional distribution of jobs at a later stage. FCCM 4D01, Functional Areas, may be a useful supplement to this discussion.

b. Identify Marked Decline. COs must identify whether there is a level at which there is a marked decline in any group’s participation. A marked decline is the highest level with proportionately fewer nonfavored group members than the level immediately below but, except in rare cases, not the level without any nonfavored group members. There may be a single level at which there is a marked decline for one or more nonfavored groups, or there may be multiple levels at which a marked decline exists for different groups (e.g., there may be one level at which there is a marked decline of the participation of Hispanics, another level where there is a sharp decline in the participation of females, and a third at which there is a marked decline of individuals with disabilities). Marked declines also may differ by various functional areas.

The determination that there is a marked decline in nonfavored group member management participation will focus further CMCE investigation in two areas:

  • At and above the grade or level where nonfavored group participation declines. At this level, the focus should be on whether the incumbent nonfavored group members are treated in a nondiscriminatory manner in all aspects of their employment.
  • Below the grade or level where nonfavored group participation declines. At this level, the focus will be on why nonfavored group members have not advanced further. Specifically, areas to explore or questions to ask are:
    • Whether unlawful discrimination kept group members from advancing beyond that grade, either because of discrimination in the selection practice itself or because of discrimination in employee development practices, or in assignment to career paths or feeder pools for higher-graded positions.
    • Whether the contractor identified and removed any impediments to EEO in selection procedures for higher-level positions. Such impediments might include management review procedures or contractor actions regarding formal or informal career paths and feeder pools.