Outreach requirements from the FCCM:
1F04 PLACEMENT GOALS
Regardless of the method employed to determine underutilization, the contractor must establish a placement goal for those job groups where minorities or women, or both, are underutilized. The placement goal established must be at least equal to the availability percentage of the underutilized minorities and women for the specific job group. If a contractor establishes a goal higher than required under the Executive Order, failure to meet this higher goal does not constitute noncompliance. Placement goals are not rigid and are not quotas.
In the event of a substantial disparity in the utilization of a particular minority group or in the utilization of men or women of a particular minority group, the contractor may be required to establish separate goals for those groups. We refer you to 41 CFR 60-2.16(d) for additional information.
1H06 EXTERNAL DISSEMINATION OF EEO POLICY AND OUTREACH
An acceptable AAP must affirm that the contractor periodically reviews its employment practices, and that the contractor undertakes appropriate outreach and positive recruitment activities when indicated by the findings of such reviews. The AAP may also describe in some detail the steps taken by the contractor in its review of employment practices and the resulting outreach and recruitment activities.
2E02 EVALUATION OF GOOD FAITH EFFORTS
See also Chapter 1, Section L – Analysis of E0 11246 AAP: Goals Progress and Good Faith Efforts.
a. Good Faith Efforts – Internal Placements. For internal placements through actions like hiring and promoting current employees, good faith may include the contractor's efforts to address barriers to opportunities for women, minorities, people with disabilities, and protected veterans. Possible areas of inquiry on this point are listed below.
• Providing Counseling and Encouraging Minority and Female Employees to Apply for Internal Openings. How does this occur? How often? What does the counseling or encouragement consist of? Does the contractor periodically assess whether its efforts are successful? Is counseling and encouragement available for caregivers?
2F00 AAP(S) AND SUPPORT DATA SUBMISSIONS
f. Disseminate EEO Policy Externally and Perform Outreach and Positive Recruitment. COs must verify during the onsite review that the contractor engaged in outreach and positive recruitment activities. To do this, COs must conduct interviews with contractor officials and third party organizations regarding outreach and recruitment efforts. Interviews with applicants and employees may also provide information regarding these efforts.
Outreach and positive recruitment may also include linkage agreements.79 COs must be prepared to refer the contractor to groups that serve individuals with disabilities, including disabled and otherwise protected veterans.
2G00 CONTRACTOR POLICY AND IMPLEMENTATION
COs must verify that the contractor communicated the nondiscrimination policy to contractor officials, human resources personnel, employees and applicants, and that procedures implementing the policy are in place. A CO will also verify that the contractor has participated in recruitment and outreach efforts…..COs must obtain documentation regarding recruitment and outreach, and other affirmative action efforts.
4E DESK AUDIT: AAP AND EMPLOYMENT ACTIVITY INFORMATION DURING A REVIEW OF SELECTION PROCESSES AND DEVELOPMENTAL PROGRAMS
The absence of outreach efforts designed to improve access to management positions for nonfavored group members could also be a problem.
8F NOTICE OF VIOLATION
b. NOV for Other Violations. An NOV is issued when a CO identifies other violations, that are not pattern or practice issues, during the review. Examples of other violations include individual discrimination, lack of recordkeeping and lack of outreach and recruitment.
2E02 EVALUATION OF GOOD FAITH EFFORTS
b. Good Faith Efforts – External Placements. For external placement opportunities, evaluation of the contractor's good faith efforts may include exploring the below areas.
- Using the Media. How are job openings advertised? Does the contractor advertise in publications or other media that are targeted to minorities and women? If so, which ones?
Resolution of Noncompliance, page 285
Actions, policies and procedures to which a contractor commits itself that are designed to achieve equal employment opportunity. Affirmative action obligations entail thorough, systematic efforts to prevent discrimination from occurring and to detect it and eliminate it as promptly as possible. Affirmative Action obligations also require contractors to ensure equal opportunity in their recruitment and outreach efforts.