As with any review, a prime source of information will be interviews of both management and employees. Consistent with the guidance in Chapter 2, contractor representatives, including internal or external attorneys or external consultants, may be present during interviews of management and supervisory employees.279 However, if a CO is interviewing a management or supervisory employee who is also a complainant or potential complainant, or is being interviewed in his or her capacity as an employee rather than a management official, the CO must conduct the interview in private. The determination of whether the management employee is a potential complainant or victim and whether the contractor’s representative can be present is fact-specific. Therefore, COs should consult with the RSOL and the national office prior to engaging in these types of interviews.
As always, there will be some common questions. In addition, COs should tailor interviews to the specific areas of concern being investigated. Likewise, a CO must take care to select individuals for interviews who have knowledge or experience in the relevant areas of concern. In all cases, a CO should start with key corporate personnel and human resources officials to discuss and develop an understanding of corporate policies and practices in the following major areas:
- The contractor’s middle and senior-level management positions and how the contractor fills them;280
- The use of outside hiring to fill middle and senior management positions and how the contractor locates and screens candidates;281
- The use of internal hiring for these positions;
- The “pool” or pools for these positions;282
- The mechanisms the contractor uses to identify and develop candidates for those positions, both at corporate headquarters and at subordinate establishments;283 and
- The reward systems, both monetary and nonmonetary, the contractor uses to retain key personnel.284
The CO should also ask for all documentation, whether written or electronic, of policies and practices relevant to these areas that the contractor has not already provided. This includes any personnel and human resource manuals, supervisory and employee handbooks, and any other internal publications that might be relevant.
279. FCCM 2F – Interviews.
280. FCCM 4D00 – Analysis of Nonfavored Groups’ Management Level Participation.
281. FCCM 4H01 – External Hires.
282. FCCM 4D01 – Functional Areas; Subsection 5H02- Internal Development.
283. FCCM 4H04 – Internal Development.
284. FCCM 4I – Onsite: Retention.