Complying with EEO Requirements

For the past few days, we have been discussing the basic EEO requirements for small Government contractors.  It is important for contractors to be aware of the requirements and to implement policies, procedures, and practices that will reduce the risk of noncompliance. There are a number of actions a contractor might take to ensure that its employment practices are not limiting the employment opportunities of the members of any gender, race, or ethnic group. Here are two such practices.

Recruit to Attract Qualified Candidates. Government contractors must ensure that its recruiting efforts reach all qualified applicants. To do this, companies need to identify as many "recruitment sources" as possible, especially those for women and minorities. After identifying these sources, call or send letters telling them about job openings and invite them to send qualified applicants your way. Then, monitor those sources to determine whether they, in fact, sent any applicants for your job opening(s).

Audit your Employment Practices to Prevent Discrimination. Employers that periodically perform self-audits of their employment practices are much better able to avoid employment barriers and ensure that they are providing equal opportunity for applicants and employees. There are three kinds of self-audits that small Government contractors can perform:

1. Self-audit before or shortly after you make an employment decision, such as a firing or promotion decision. This audit focuses on employment qualifications or standards used in making various employment decisions and how women and minorities fared in those decisions. This generally involves a comparison of applicants or employees who are competing for a particular job or promotion or to retain a particular job.
2. Self-audit where female and minority workers are or are not within your organization. Review where the female and minority employees work within your organizational structure. A helpful way to do this is to identify the gender, race, and ethnicity of each employee for each job within each department on an organizational chart. Look for concentrations of female or minority employees, especially in lower-paying jobs. Similarly, look for areas where female and minority employees seem to be absent or poorly represented, especially in higher-paying jobs. Also, look at the ways employees are promoted from lower ranking jobs to the higher-ranking jobs.
3. Self-audit the way your personnel decisions, like hiring, have affected women and minorities over a longer period of time (e.g., a quarter or year). This audit uses statistics and works well when you are reviewing a number of employment decisions made over a period of time.