In case you missed last month’s BCGi webinar on Understanding & Preparing an Effective AAP Narrative, we have put together the following key takeaways.
Depending on the amount of federal contract, federal contractors are required to develop three (3) Affirmative Action Plans (AAP): 1) AAP for Women and Minorities; 2) AAP for Individuals with Disabilities; and 3) AAP for Protected Veterans (please see OFCCP’s infographic for the contract threshold). The Narrative is the written portion of the Affirmative Action Plan (AAP) that discusses your Company’s non-discrimination policies and activities to address AAP goals and comply with some of the following regulatory requirements.
- Must include your Company’s policy statement and commitment to uphold Affirmative Action and Equal Employment Opportunity for all. The policy statement must have the support and signature of your company’s top U.S. executive and should be posted prominently, together with your other Federal postings, where it may be viewed by employees and applicants.
- State the responsibilities of the appropriate company officials responsible for the implementation of the AAP. Review/update the list of responsibilities for each designated officer as necessary.
- Ensure to include “good faith efforts”Ā¯ that both have been made and that are in progress during the Plan Year to show any positive recruitment and other outreach efforts towards women, minorities, protected veterans, and/or individuals with disabilities in the Action-Oriented Programs section of the narrative.
- Periodically review your compensation policies to make sure that the salary (and, if appropriate, other pay) of your employees and offered to your applicants will not be reduced because of any disability income, pension, or other benefit that they receive from another source.
- Describe your Company’s internal auditing system used to measure the affirmative action program’s effectiveness.
- Periodically review the physical and mental qualifications of the jobs in your Company to ensure that the qualifications are job related and consistent with business necessity and do not unfairly exclude otherwise qualified individuals with disabilities and protected veterans.
- Ensure that your commitment to equal employment opportunities and affirmative action are clearly communicated both internally and externally.
Following are some examples of best practices for an effective narrative that addresses not only the requirements of the regulations but also help in an effective AAP development process and in a smooth OFCCP compliance review:
- This is the Company’s chance to put their best foot forward. Put all the “good things” that the company provides to its applicants, employees, and to the community.
- Required sections of the narratives for Individuals with Disabilities and Protected Veterans are very similar to one another. Hence, you may combine the two (2) narratives into one.
- Instead of including the results of the analyses in the narrative, you may refer to those results via appendices (e.g., see placement goals summary as appendix A).
- Proofs of job listing and/or outreach and recruitment efforts may be compiled in a separate and easily accessible binder. There is no need to put all these in the same compiled AAPs.
If you have Platinum membership, the recorded version of the webinar is available on the BCGi’s website.Ā If you do not have Platinum membership, please also visit BCGi’s website to learn more about the benefits of becoming a member.Ā You may contact us via email staff@biddle.com or call 800.999.0438 for any questions.
Contributing Author: Oscar Martinez, EEO/AA Analyst I at Biddle Consulting Group, Inc.
