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Organizations typically distinguish “Diversity Management” from “Affirmative Action.” The perception is that an affirmative action program consists of “compliance in order to conduct business with the federal government,” whereas diversity management “aims to provide tangible benefits.” I think the Office of Federal Contract Compliance Programs (OFCCP) would be surprised to learn that federal contractors are developing separate diversity plans to achieve inclusivity in the workplace, and conducting analyses and developing affirmative action plans (AAPs) for the exclusive purpose of fulfilling compliance obligations. The whole point of having an affirmative action plan is to use it, right? After all, isn’t it a “plan”?

The federal regulations do not preclude contractors from integrating a diversity plan into their affirmative action document. In fact, they would likely welcome the development of a plan tailored to the unique character of the organization. For the most part, diversity plans use the same data that federal contractor affirmative action plans use, and conduct analyses very similar to those required by the regulations.

Diversity metrics examine recruiting, selections, promotions, and retention (the inverse of terminations). These analyses are also included in a federal contractor’s affirmative action plan.

Diversity plans are primarily concerned with achieving a diverse workforce. For example, a diversity plan might incorporate the following goals and objectives, which are based on a comparison of the employer’s workforce to the area in which it is located.

Goal 1: Build a diverse, high-performing workforce that reflects all segments of society.

  • Objective 1: Eliminate barriers to Equal Employment Opportunity (EEO) at all levels and in all occupations.
  • Objective 2: Achieve diversity in the broadest context throughout the workforce.

Goal 2: Cultivate a flexible, collaborative, and inclusive work environment that leverages diversity and empowers all contributors.

  • Objective 1: Leverage workforce diversity and empower diverse perspectives throughout the organization through career/leadership development.
  • Objective 2: Cultivate a flexible, collaborative, and inclusive organizational culture for all employees.
bq lquo Procedures without effort to make them work are meaningless; and effort, undirected by specific and meaningful procedures, is inadequate. bq rquo

Likewise, a federal contractor’s affirmative action plan will include a utilization analysis to identify areas of underrepresentation and the goals established as a result of the analyses. In fact, 41 CFR 60-2.10(a) states the purpose of the AAP as follows:

An affirmative action program is a set of specific and result-oriented procedures to which a contractor commits itself to apply every good faith effort. The objective of those procedures plus such efforts is equal employment opportunity. Procedures without effort to make them work are meaningless; and effort, undirected by specific and meaningful procedures, is inadequate. An acceptable affirmative action program must include an analysis of areas within which the contractor is deficient in the utilization of minority groups and women, and further, goals and timetables to which the contractor’s good faith efforts must be directed to correct the deficiencies and, thus to achieve prompt and full utilization of minorities and women, at all levels and in all segments of its work force where deficiencies exist.

Some diversity plans call for a type of climate and/or engagement survey. These surveys inform Diversity Officers as to areas in which more attention is needed. A failure to address them could result in complaints of discrimination, hostile work environment, constructive discharge (when an employee feels compelled to quit), and other related adverse conditions. Though such surveys are not required by OFCCP, the results should be used to determine practices and procedures that may need additional attention.

An organization’s affirmative action plan should incorporate all aspects of a diversity plan. Make the plan work for your organization – not the other way around. The analyses conducted for the AAP play a key role in developing a strategy for further diversifying the organization. And if you really want to know the “climate” of your organization – just ask the folks who conduct complaint investigations.



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