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I understand from your question that you will use a single job seeker pool from which to fill three identical (or virtually identical) vacant positions. If my understanding is correct a single job listing is sufficient, although if it is possible to include in the listing that you expect to fill three openings for the position that would make it perfectly clear to job seekers. The regulatory requirement ensures that covered veterans are made aware of employment opportunities with government contractors through the local ESDS process because that process provides certain preferences and priorities in ITS employment services to covered veterans. Your single job listing accomplishes that communication and, in fact, it would be very cumbersome to have three different simultaneous job postings and three different applicant pools for multiple vacancies occurring simultaneously. One caveat: at the very least the basic qualifications (and any others advertised, e.g. “preferred qualifications”) for the three opportunities must be the same AND the openings must occur/jobs be available at the same time. In fact, if it is practical to do so I suggest that ALL the persons you “consider” for “Engineering Job” compete for all three vacancies. That is, that each qualified/better qualified person has an equal chance to be selected for any one of the three vacancies contemplated by the job listing. “Batch hiring” from a single advertisement is not always possible, but it makes for the easiest record keeping and simplest analysis. NOTE: I know you didn’t ask – or at least I assume you didn’t – about the legitimacy of using a single ESDS job posting when there was no actual vacancy or to suffice as affirmative recruitment for potential/expected future additional openings. But I want to emphasize that my answer would be different if the objective was to set up a sort of “pipeline” for some number of vacancies that you expect to occur, serially, over time. “Pipelines” are typically VERY problematic in both the keeping of required records and in their analysis and hence, decidedly problematic when being reviewed and/or challenged by the OFCCP. Prudent contractors use them, if at all, only following careful investigation to determine that they are both necessary and DEMONSTRABLY beneficial to the contractor in filling jobs with well qualified people in a reasonable period of time AND accompanied by demonstrated good faith recruitment efforts in compliance with all affirmative action rules that are enforced by the OFCCP. In my experience, “pipelines” typically were designed with the expectation that they would ease the pressure on recruiters and/or to facilitate productivity improvement among Talent Acquisition staff. There’s nothing at all wrong or illegal with either objective but the contractor really ought to KNOW whether – and to what extent – pipelines have accomplished at least the latter objective. Further, it’s important to know whether any such proven benefits of “pipelines” to the CONTRACTOR (not just to the TA team) have been consciously weighed against compliance concerns, for example, are significant improvements in record keeping systems needed (especially documentation of specific reason(s) for non-selection for EACH vacancy for which an individual’s qualifications were assessed)? The compliance objective – and legal obligation – is that the contractor has audited this particular “employment process” to ensure that it does not unlawfully discriminate and that, consequently, it KNOWS it is prepared to defend against what might be an increased risk of statistical indicators of unlawful discrimination.
You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.