Part 2: Before You Certify, Verify

A Pragmatic Compliance Framework for Federal Contractors The IBM and Deloitte settlements do not mean that contractors should stop conducting outreach, reviewing workforce data, or working to ensure equal employment opportunity. They demonstrate the importance of distinguishing between two very different activities: Using workforce data to identify and remove possible barriers; and Using protected characteristics…
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Part 3: Best Practices for Federal Contractors and Private Employers

Organizations seeking to reduce Title VII, Executive Order, and FCA risk should consider adopting a prevention-based compliance strategy. Conduct Periodic Workforce Diagnostic Reviews At least annually, evaluate: Applicant flow data Hiring outcomes Promotions Terminations Compensation decisions Performance ratings The objective is to identify potential indicators requiring further review. Validate Job-Related Decision Criteria Ensure hiring, promotion,…
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