“We don’t need to update our AAP.”

“Being a federal contractor is a privilege.” –OFCCP Director Patricia Shiu, March 22, 2012  “We’re going to skip this year.  We didn’t really hire anyone and we didn’t fire anyone, so we don’t need an AAP this year.” From time to time we hear this reasonable-sounding excuse for not performing the annual update to the…
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FedEx Expresses Conciliation

“Under this agreement, FedEx will have to really examine and revamp its hiring practices across the entire company. The American people ought to have confidence that one of our nation’s most trusted brands will not tolerate discrimination.” –OFCCP Director Patricia Shiu, March 22, 2012 Yesterday, we’d barely finished the post we published this morning when…
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The High Cost of Low Priority

One of the hardest jobs we have here is getting buy-in that compliance is a high priority not only due to ethical considerations but also financial ones.  Why companies continue to under-staff or de-prioritize various HR functions—including and especially those involving compliance—is puzzling. Case in point:  NCS Pearson just signed a conciliation agreement with the…
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The USDA in DOL territory?

This news is a few days old at the moment, but we’d like to comment on it. The US Department of Agriculture recently withdrew a proposed rule that would have affected contractors in the jurisdiction of both the USDA and the OFCCP.  It would have required contractors for the USDA to verify that they “were…
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Why Can’t Companies Keep Proper Hiring Records?

How would your organization rank if its employment records were audited right now? Would you find that records are kept as required by law? Do you know what those legal requirements are? It really appears that companies fall apart—especially the recidivists—on primarily two pieces of record keeping:  1) Defining an Applicant and 2) Disposition. This…
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