Internal Dissemination (2)
The simplest yet most overlooked part of Affirmative Action requirements is Internal Dissemination.
Like other requirements, internal dissemination is an ongoing effort and properly done will eliminate the possibility of a standard phone survey leading to a full blown onsite audit.
- Simple steps that you have to make internally are clearly outlined.
- Copy of the updated Equal opportunity/Non-Discrimination Statement(FCCM 1H07) in .pdf or .doc Word (to be put on organization letterhead for distribution internally to all.)
- Including Your name and title, as the Executive who has the Authority and resources to ensure the AAP is put into practice.(E02)
- Explain to Senior Management, if necessary, that you should be given the necessary Authority and Resources to implement.
Your Affirmative Action Plan elements: Title 41, Code of Federal 60-741.44 :(i)
Now as you are the AAO your name and title will go on the copy as the Executive in charge.
b. Section 503 and Section 4212 (or VEVRAA) AAPs. If one or more of the below listed Section 503 and Section 4212 AAP elements is missing, COs automatically consider the submission unacceptable.
- Internal dissemination
- Description of the contractor's audit and reporting system
- Identification of the person(s) responsible for implementation of the AAP
FCCM, Page 52, 1H07 Internal Dissemination of EEO Policy and Outreach.1H07 Internal Dissemination of EEO Policy and Outreach.
The contractor must disseminate its EEO policy internally. An acceptable AAP must address the contractor's internal procedures to foster understanding, acceptance and support of the contractor's obligation to promote equal employment opportunity for individuals with disabilities and protected veterans.
contractors may conduct meetings with executive, managerial and supervisory personnel to explain the intent of the policy and to delineate individual responsibility for its implementation.
......• Designation of Responsibility for the AAP. The contractor's appointment of a person to be responsible for implementing the AAP must be an executive who has the authority and resources to ensure that the AAP is put into practice. COs must obtain a copy of the responsible official's position description to ensure that it includes implementing the AAP. During the interview, the official responsible for the AAP's implementation must describe how the specific provisions of the AAP are implemented. The roles of the interviewed officials in developing and implementing the AAP must be the same as specified in the written AAP. If they are not the same, COs must ask the contractor for an explanation.
Title 41, Code of Federal Regulations,§60-741.44:(i) Responsibility for implementation. An official of the contractor shall be assigned responsibility for implementation of the contractor's affirmative action activities under this part. His or her identity should appear on all internal and external communications regarding the company's affirmative action program. This official shall be given necessary senior management support and staff to manage the implementation of this program.