Affirmative Action Policy

Process Owner

Senior Executive of Corporate Human Resources

Purpose

To comply with Executive Order 11246; Section 503 of the Rehabilitation Act of 1973, as amended; and Section 4212 of the Vietnam-Era Veterans’ Readjustment Assistance Act (“VEVRAA”) of 1974, as amended, in order to eliminate current and past discrimination based on any protected class.

Definitions

'Affirmative Action – is a results-oriented program of positive action, undertaken with conviction and effort, to overcome present effects of past practices, policies or barriers to equal employment opportunity and to achieve the full and fair utilization from members of any protected class found to be underutilized in the work force or adversely affected by workplace policies and practices.

Protected Class – Categories of individuals protected against discrimination under Federal, State or local law. Includes, but is not limited to: race, color, sex, religion, age, sexual orientation, gender identity and expression, national origin, marital status, physical or mental disability, or status as a Disabled Veteran, Special Disabled Veteran, Armed Forces Service Medal Veteran, Recently Separated Veteran, Vietnam Era Veteran or Other Protected Veteran, as defined by the Vietnam Era Veterans’ Readjustment Assistance Act (“VEVRAA”) of 1974, or any other characteristic protected by law.

Underutilization – a condition in which there are fewer women and minorities in a given job group than one would reasonably expect based on the computed availability of qualified workers within a particular geographical recruiting area.

Policy

GovC is committed to identify and eliminate discrimination in employment, by taking active steps to promote the employment and advancement of all qualified candidates and employees, without regard to any protected class.

As a federal contractor, GovC is subject to Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, as amended, and the Vietnam Era Veterans’ Readjustment Assistance Act (“VEVRAA”) of 1974, as amended, and must design, implement, and maintain written affirmative action plans. When underutilization occurs, GovC’s affirmative action plans will enable the review of internal practices to ensure that there has been no discrimination in recruitment, selection, training, or promotion. If underutilization occurs, GovC will broaden its external recruitment efforts beyond its regular target areas to achieve the full and fair utilization of these persons at all levels and segments of the work force.

Responsibilities

Corporate Human Resources is responsible for coordinating the Affirmative Action Group (AAG) and the development of Affirmative Action plans. The AAG is composed of representatives from the Human Resources Departments of each Business Unit. Each Affirmative Action Representative is responsible for monitoring the overall status of the affirmative action initiatives, goals and good faith efforts with regard to recruitment, selection, promotion, compensation and terminations of employees in any protected class in their Business Unit. Because of the nature of their duties, each Affirmative Action Representative has direct access to top level management in their Business Unit.

Procedures

GovC’s Human Resources Departments will ensure the effectiveness of the total Affirmative Action program by:

1) Monitoring records of all workforce activity, including referrals, placements, transfers, promotions, terminations, and compensation, at all levels to ensure the nondiscrimination policy is carried out.

2) Developing a workforce that is truly representative of all segments of the population through targeted outreach, recruitment and training of underrepresented groups.

3) Maintaining records to update the Affirmative Action Plan, including revising the available data and establishing annual numerical placement goals.

4) Internally auditing the data on a scheduled basis in order to evaluate systematic results and affirmative action efforts. This will allow GovC to analyze the degree to which equal employment opportunity and organizational objectives are attained.

5) Reviewing reported results with all levels of management and;

6) Advising top management of the program effectiveness and submission of recommendations to attain goals.