Internet outreach for diversity recruitment and ofccp compliance

America’s Job Exchange
400 Minuteman Road, Andover, MA 01810
www.americasjobexchange.com
American Association for Affirmative Action
2013 National Conference and Annual Meeting
May 7-10, 2013 | San Antonio, TX
Rathin Sinha
President, America’s Job Exchange

Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
Disclaimer
Not legal advice. The presentation is intended only to stimulate discussions among
practitioners and industry participants relating to affirmative action and OFCCP
compliance in internet recruitment and workforce development.

We live in communities that are increasingly more diverse, including
Veterans, individuals with Dis-ABILITY, Ethnicity, Race, Color, Gender, Age and
more
Diversity in our Communities

 Proactively reach and attract
candidates from these diverse
communities for your job openings
 Hire and retain these employees in
an environment that free of
discrimination by backgrounds
 Ensure career growth and pursuit of
excellence in an environment that
provides equal opportunities
Diversity at the Workplace
Our workplace should resemble the diverse communities we represent

Proactively leverage diversity
and equal employment
principles to make diversity a
competitive advantage for
your business
Step 2:
Proactive Diversity
Develop and manage
programs to ensure that both
the letters and spirits of
affirmative action and related
laws are complied to
Step 1:
Regulatory Compliance
The road to diversity excellence can be broken in two steps
Leveraging Diversity

 Represents the benefits of job seekers and employees
• EO11246 – Equal Employment
• Section 503 - Americans with Disabilities
• VEVRAA/Section 4212 - Protected Veterans
 Audits federal contractors and imposes corrective
actions if deficient
• Scheduling Letter, Information Request
• Desk Audits, On-Site Audits,
• Conciliation Agreement, Penalties, Debarment
The OFCCP enforces regulations relating equal employment & affirmative action in
companies that do business with the Federal government
Role of OFCCP

 Executive Order 11246
Prohibits Federal contractors from discriminating in
employment decisions based on race, color, religion, sex or
national origin.
 Section 503 of the Rehabilitation Act of 1973
Requires Federal contractors to take affirmative action to
hire, retain and promote individuals with disabilities.
 Vietnam Era Veteran’s Readjustment Act, as amended in
conjunction with Jobs for Veterans Act (VEVRA/JVA)
Requires Federal contractors to take affirmative action to
hire, retain and promote veterans.
It mandates that Federal contractors must comply with a set of regulations in their
recruitment practices.
Key Regulations

 Increased Prominence
• New leadership
• Budget increase
• Staff Increase
 Heightened Enforcement
• Higher incidents of audits
• Aggressive litigation
• Larger penalties
The OFCCP has been very engaged and active during the terms of the Obama administration
An Engaged OFCCP
Sources 1 Video speech at the National ILG Conference in Hawaii, 2012; http://www.dol.gov/ofccp/addresses/Director_address_NILG_Aug302012.htm
“Under the Obama administration, OFCCP
compliance officers have reviewed more
than 15,000 companies that do business
with the U.S. Government. During that
period, we've recovered $38 million in back
wages and more than 8,000 potential job
offers for nearly 80,000 workers...”
-Patricia Shiu, Director, OFCCP1

Strengthening Regulations
It has also proposed new regulations and changes to current regulations
 To improve employment opportunities for veterans and
protected veterans
 To improve employment opportunities for individuals with
disabilities
 To improve employment opportunities for women and
minorities in the construction industries
 To combat pay discrimination and develop new
compensation data collection tool
 To evaluate revisions to the guidelines on sex
discrimination
 To emphasize data collection, analysis , and data-driven
review to track progress

 Requires Specific Recruitment Efforts
• Must engage in certain number of outreach and recruitment programs
• Send job listings to the local employment service offices e.g. 1-stop centers
• Develop and maintain ongoing relationship with local Veterans Representatives
• Enter linkage agreement with listed organizations for recruitment and training
• Consult with Employer Resources Section of the National Resource Directory
 Requires Enhanced Data Tracking
• Initiate requests to have candidates self identify prior to job offer and collect data
• Track number of referrals from the state employment service delivery systems
• Track ratio of protected veteran referrals to total referrals & maintain data for 5 years
• Establish annual hiring benchmark and conduct annual review of recruitment efforts
Proposed Changes: Protected Veterans

 Requires Specific Recruitment Efforts
• Must engage in a minimum number of outreach and recruitment programs
• Send job listings to the local employment One-Stop Career Center
• Maintain ongoing relationship with local State Vocational Rehabilitation Agency
• Enter linkage agreement with listed organizations for recruitment and training
• Consult with Employer Resources Section of the National Resource Directory
 Requires Enhanced Data Tracking
• Initiate requests to have candidates self identify prior to job offer and collect data
• Track number of referrals from the state employment service delivery systems
• Track ratio of disability referrals to total referrals & maintain data for 5 years
• Establish 7% as a hiring goal for this group and conduct annual review of progress
Proposed Changes: Individuals with Disabilities

 Mandatory Job Posting Outreach
• Mandates specific methods of internet job postings and distribution
• Mandates additional outreach with community based organizations
 Data Collection and Tracking
• Pre-employment data collection for protected groups
• Effectiveness of recruitment efforts by source of candidates
 Data Analytics
• Analysis of candidate availability and actual hiring, compensation
• Annual review of recruitment efforts relative to goals and benchmarks
Proposed changes related to recruitment can be grouped in three areas:
Essence of Regulatory Changes

Pace of Implementation
While pace of actual implementation has been relatively slow, it is expected to
accelerate during the second term with continuity in purpose and leadership
 Major focus to improve employment opportunities for
the veterans and individuals with disabilities
 Strict enforcement of compensation parity and
possible development of compensation tool
 Implementation of new scheduling letter with
itemized information and expanded data tracking
 Detailed adverse impact analysis, new compliance
manual, focus on construction
 Aggressive enforcement and audits with expanded
coverage for first time contractors and SMB

 Changes in Systems and Processes
Career Site, ATS, HRIS, AAP/EEO-1/VETS-100 Submittals
 Cost of Expanded Outreach
Direct cost and adminsitrative burden of job postings
 Data Collection and Tracking
Collect, manage expanded set of data; protect for privacy
 Complexity/Inconsistency of Enforcement
Individual interpretation of regulations
Federal contractors are already feeling the challenge of compliance related activities; -the
proposed changes impose additional burdens
Impact on Contractors

 Automated Technology
State-of-the-art web platform, job distribution technology,
data exchange mechanism, and data tracking methodologies
 Breadth of Partnerships
Large network of partnerships with niche job sites, community
organizations, states, associations and employment agencies.
 Audit Assistance
Expertise and assistance on your side in the event of an audit
including consultation, and retrieval and analysis of data
 Brand Development
Efficient and effective access to media, advertising, technology to
attract, hire and retain a diverse set of candidates
Third party vendors such as AJE are increasingly considered as effective alternative to in-
house only programs
The Role of Third Party Vendors

 Successor to America’s Job Bank
Launched on the heels of termination of the AJB
program of DOL
 Destination for Job Seekers/Employers to
Connect
Specializes in the recruitment of diversity candidates
and non-executive jobs
 Specialists in online Diversity Recruitment
and OFCCP Compliance
Specializes in veterans and disability recruitment
outreach and mandatory job listing online
AJE is a leading provider of recruitment advertising and compliance solutions
America’s Job Exchange

Job listing is imported via an automatic
feed for FTP, XML or direct scraping, or
using online interactive posting
Job Posting as Outreach Media
Your
Job

The imported job is posted on the AJE
national and state specific websites
Job Posting Outreach : Step 1
Your
Job
Your
Job

The job listing is then automatically
posted on the AJE Mobile App.
Your
Job
Your
Job

And then posted on the AJE Facebook
App as part of Social Job Initiative
Your
Job
Your
Job

The job opening is posted in the AJE
network of Diversity Job Exchanges e.g.
Veterans, Disability and much more.
Job Posting Outreach: Step 4
Your
Job
Your
Job

The job is included in relevant job alert
emails sent to subscribed job seekers
Job Posting Outreach : Step5
Your
Job
Your
Job

The job opening is sent to aggregator sites
to reach a broader audience
 Indeed
 Simply Hired
 Glassdoor
 Juju
 Carrerjet
 TopUSAjobs
 Oodle
Your
Job
Your
Job

It is then sent for distribution and posting
to our partner sites e.g.
 Veteran Job Boards
www.VeteranJobs.Net
www.Jofdav.com
www.allveteranjobs.com
 Disability Job Boards
www.disabilityjobs.net
www.disabledperson.com
 Diversity Job Boards
www.asianhires.com
www.africanamericanhires.com
www.alllgbtjobs.com
www.allhispanicjobs.com
www.diversityjobs.com
Your
Job
Your
Job

The job posting is now sent to community
based organizations (CBO) via emails
 Goodwill
Local chapters
 Easter Seals
Local chapters
 The Arc
Local chapters serving persons with intellectual disabilities
 Department of Rehabilitation
Local state offices
 U.S. Department of Veterans Affairs
www.va.gov
Your
Job
Your
Job

It is then sent to the relevant state
employment delivery systems e.g.
1-Stops, DVOPs, LVERs via emails.
Your
Job
Your
Job

Finally the job posting is sent to the state
job bank by direct feed or online posting
Your
Job
Your
Job

Comprehensive 10 Step Outreach Program
Job
OpeningYour
Job

Making it Easy : Job Seeker User Experience
Outreach is step one – but making it easy for the job seekers to apply and get hired
is key for a successful online diversity recruitment program

 Storage
Posting and distribution details saved for proof to auditors
 Reporting
Easy to understand online reports – 24x7 access
 Retrieval
Quick turnaround report retrieval going back 2-5 years
 Analytics
Views and applies by source
Comprehensive and easy to use data analytics capabilities are key to measure
effectiveness and drive continuous improvement
Data Analytics

Job and Distribution Details
Create reports for the company
as a whole or for specific
locations or subsidiaries.
Reports can be saved and
exported to PDF and Excel.
Detailed outreach and distribution
information, including delivery
method and date and time stamp.

Individual Job Records
Links to job descriptions on AJE exchange
sites along with links to outreach partner sites.
Individual job records provide the details on
distribution to our network partners and the states.

Individual Job Records
Links to emails and CSV files as evidence of
distribution to community partners and state
one-stop offices.
Jobs manually posted to the states include the
state confirmation ID in your report.

Account Dashboard
Job traffic results are available
in total or by source for all of
AJE’s traffic sources.

Job Manager
Job posting history is easily
accessible and up to date.
Track your posting patterns to
determine future needs.

Batch Feed Monitor
Monitor batch feeds to manage
performance and ensure your
job imports are successfully
received and processed.

The AJE solution is used by hundreds of leading brands for diversity hiring and recruitment
compliance
Total Solution from AJE

Satisfied Customers

For more information, please contact:
Thank You
Rathin Sinha
rsinha@americasjobexchange.com

Internet outreach for diversity recruitment and ofccp compliance

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