Hires and promotions is the correct answer. You should not include demotions. Organizations typically do not show reassignments and lateral transfers as placements. If a reassignment or lateral move constituted some kind of positive change for an employee in terms of pay, future opportunities, and/or increased responsibilities, you might be able to consider that as a placement. However, you would potentially need to explain to OFCCP why you were counting that kind of change as a placement. The safest and best answer is to count only hires and promotions as placements.
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.
