An affirmative action plan, in essence, is a part of the human resource (HR) protocol adopted by organizations, especially those who are federal contractors and subcontractors, that aims to eliminate discrimination in hiring and provide equal employment opportunities to all irrespective of race, religion, sex, and other factors.
Objectives of Affirmative Action Plan
Below are the major objectives of implementing an affirmative action plan:
To identify and correct any past or current discrimination in the employment process of an organization by analyzing the root cause and implementing corrective actions.
To ensure that equal employment opportunity (EEO) is guaranteed when it comes to hiring practices. There should be no discrimination on account of an applicant’s race, color, gender, sexual orientation, disability, and other similar factors.
To hold those who have engaged in or promoted discriminatory practices and actions accountable.
To create awareness and establish fair employment practices within organizations through required training and workshop.
Who Requires an Affirmative Action Plan?
While any organization can choose to develop and implement an affirmative action plan, the AAP is only compulsory for federal contractors and subcontractors. The Office of Federal Contract Compliance Programs (OFCCP) provides samples of AAPs on their website and outlines the federal regulations that need to be complied with when crafting an AAP. These regulations apply to all federal contractors and subcontractors who are engaged in non-construction-related projects.
Specifically, this includes those:
Who employ fifty employees or more.
Who are within 120 days or less of the commencement of a federal contract.
Whose account has a record of a minimum of $50,000 worth of government bills of lading in a 12-month timeline.
Who have a minimum of $50,000 worth of federal contract or subcontract.
Who are working as financial agents for U.S. saving bonds and notes and carry out the issuance and payments of such instruments.
Can work as a federal funds depository for any amount.
Make sure you check with the OFCCP compliance to meet the conditions of a federal contractor or subcontractor for acquiring an AAP.
What Elements Make up an Affirmative Action Plan?
You need to incorporate certain things in an acceptable and compliant Affirmative Action Plan. Let’s find out those required elements are;
1. Policy Statement
The agency head will sign a consolidated policy statement covering the equal rights of employees, including equal employment opportunity, nondiscrimination, steps to be taken against sexual harassment, work opportunities for those with disabilities, etc.
2. Organizational Chart
An organizational chart should be prepared by the federal contractor laying out all the related departments within the organization, including all employees based on work unit, job title, gender, and race.
There should be a record of the total number of male and female candidates divided into further categories of Blacks, Asians, Native Americans, Hispanics, and Whites other than Hispanics.
3. Roles and Responsibilities
The contractor must create a record of all individuals who are taking significant roles and responsibilities in the Affirmative Action Plan. Their inclusion in the record must contain their identification and necessary documents.
4. Grievance Procedures
AAP grievance procedures provide an informal structure to resolve unlawful discrimination within an organization. It covers the options of filing complaints for taking legal action against any discriminatory acts.
5. Statement of Problem Identification
Many times, the problems lie within the organization's policies and/or the implementation thereof. Those are the things that cause discriminatory outcomes. Thus, an AAP should contain a statement covering the mechanism that will be used to identify problems with the organization and correct such problems.
6. Action Plan Statement
This statement covers the steps that are to be taken to identify the root cause of discrimination while setting out the necessary measures that will be taken to resolve such issues and ensure the advancement of the best interests of the workforce as a whole.
7. Objectives and Timeline
Specific objectives should be created for the purpose of recruiting and advancing protected group members based on EEO (equal employment opportunity) criteria. Working on these objectives should rectify the past discriminatory acts and consequences.
How to Prepare an Affirmative Action Plan?
As mentioned earlier, the OFCCP website shares several AAP samples that you can take ideas from. Moreover, you can take inspiration from the APP documents of other reputed institutions such as the Connecticut Community Colleges.
Contractors must assign internal audit schedules and reporting systems based on OFCCP regulations. The purpose of the audits and the reports should be to monitor the following:
Employee demographic information.
Analysis of the effectiveness of the Affirmative Action Plan (if any).
Monitor anti-discrimination initiatives.
Besides, the reports must contain the following information:
The demographic information is collected voluntarily from employees as well as applicants during recruitment with an Applicant Flow Log
However, you should note that an APP isn’t simply a process to audit and report on certain metrics. It’s a codification of the organization’s policies and plans to eliminate discrimination and promote equal employment opportunities for all.