How to make sure your fabrication shop recruitment is OFCCP-compliant

By ensuring recruiting processes are nondiscriminatory, your company not only achieves compliance with the OFCCP, but an HR team can also improve the quality of hires and increase retention rates for top talent.

It’s easy to consider the Office of Federal Contract Compliance Programs (OFCCP) as a nuisance, but the truth is that complying with the OFCCP doesn’t just help you avoid hefty fines, it can actually make your organization stronger.

The OFCCP exists to ensure that federal contractors do not discriminate against workers based on race, religion, sex, sexual orientation, disability, or status as a protected veteran (among other factors). If your shop sells goods or services to the federal government directly or to other companies that sell goods or services to the federal government, you must take certain steps during the recruiting process to ensure compliance with the OFCCP.

Taking these steps puts your company in a better position to succeed by opening the doors to a wider pool of quality candidates and by fostering a more inclusive workplace. Research shows that companies rated in the top 25 percent for racial and ethnic diversity are 35 percent more likely to have financial returns above their respective national industry averages. By ensuring recruiting processes are nondiscriminatory, your company not only achieves compliance with the OFCCP, but an HR team can also improve the quality of hires and increase retention rates for top talent.

Here’s how a proper recruiting process can help keep a metal fabrication company OFCCP-compliant.

Document, document, document

If a company follows OFCCP regulations but doesn’t have any records of it, is it OFCCP-compliant?

No, it is not. Documentation is key to compliance. In fact, recordkeeping is listed as the No. 1 OFCCP violation, so it’s essential your company documents every step of the hiring process — from affirmative action plans and interview procedures to candidate demographics and all rejected and accepted offers.

As part of your recruitment process, your company should document:

• The job websites and offline sources where all your job listings are posted.
• Applicant identities and demographics. Who applied for the position? Who received interviews? Were certain populations under- or overrepresented among applicants or interviewees?
• Accommodations. Did applicants ask for any accommodations during the recruitment process? How were these accommodation requests processed?
• Dispositions. Why were applicants dispositioned from the hiring process?

These are just a few of the many details that need to be documented throughout the recruitment process. Whether you document this manually or through an applicant tracking system or recruiting software, make sure your records are easy to access and present to an auditor when needed. There’s a lot of information to track, so look for ways to automate pieces of the process, such as posting open jobs across compliant websites, or tracking the timeline for each candidate’s interview process, to make your job easier.

Create an Affirmative Action Plan

To pass your OFCCP audit, your company must have (and be able to show) an affirmative action plan (AAP). There’s no need to reinvent the wheel, though. The OFCCP provides sample AAPs on its website, which serves as a good starting point.

With an AAP in place, your company will develop recruitment goals and a plan to meet those goals. You can use the data you track across your hiring process to identify where to target your recruitment efforts. An AAP will also help you track where your recruitment efforts are hitting the mark and where they need to be improved.

Once a year return to your AAP and assess how successful your company was at meeting its affirmative action goals. Then update the AAP (and your recruitment efforts) accordingly. Reassessing annually will not only make it easier to show the OFCCP that you’re in compliance, but will also elevate your recruiting efforts over time as you’re able to track and measure your goals to attract quality candidates.

Develop recruiting relationships

With your AAP as a guide, consider how you can find women, minorities, protected veterans, and people with disabilities to work at your company. Which industry groups can you partner with? Can colleges, trade schools, and career development programs link you to the type of candidates you’re seeking? Could an employee referral program prompt your staff to find qualified candidates? Spend time developing personal relationships with recruiting sources that will help you find diverse candidates.

In addition to ensuring your own recruitment efforts meet your affirmative action and equal opportunity obligations, make sure any third-party recruiters track affirmative action information. Notify union officials of your AAP and inform them of their compliance obligations.

Document the effectiveness of your outreach. Which recruiting sources are providing you high-quality candidates, and which ones are not? Are there certain types of candidates you still struggle to reach?

Make OFCCP compliance part of your routine

Being able to show that you have strong relationships with recruiting sources, a documented AAP, and organized recordkeeping across your entire hiring process will help you avoid the most common OFCCP violations. This already puts you in a strong position during an audit.

Even better, if you regularly monitor and improve your hiring and recruiting processes internally, an audit from the OFCCP will start to feel like a walk in the park. Perform internal check-ins on at least an annual basis to see what’s working and to update your processes to comply with any new OFCCP regulations.

Check back on Thursday when we analyze three common OFCCP violations.