THEINSIDEVIEW
ments. AAP regulations require federal contractors
to provide all U.S. citizens with a non-discriminatory
equal-employment opportunity, and they do so in
a formalistic, technical and legalistic manner. This
involves well-established procedures that every AAP
compliance office must follow, including developing the
required affirmative-action plans for Blacks, Latinos,
Asians, American Indians, women, individuals with
disabilities and covered veterans; statistically compar-
ing current “utilization” with labor force “availability”;
creating numerical “goals” for improving representation
where there is “statistically significant” underutiliza-
tion; and conducting “adverse impact analyses” of
various personnel activities, such as hires, promotions
and terminations, to identify and facilitate elimination
of barriers to equal opportunity. Affirmative-action
plans typically include a description of specific reme-
dial measures directed at improving representation of
underrepresented groups. Many companies regard AAP
compliance in minimalist fashion, doing the minimum
required by regulation to minimize corporate legal li-
ability. Their efforts are strictly compliance and are not
intended, as in the case of D&I, to be creative or expan-
sive in maximizing corporate marketplace success.
The AAP compliance function requires strict procedural
adherence to regulations and 50 years of precedent.
The D&I function is helping to achieve the business case for diversity
as a corporate imperative and must utilize new and creative thinking
to address a dynamic demographic and economic environment
to help the company succeed in the marketplace. {
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With companies that have both D&I and AAP compliance functions, an overlap can exist be- cause both are seeking to improve underutilized groups’ representation. The AAP compliance function requires strict procedural adherence to regulations and 50 years of precedent. The D&I
function is helping to achieve the business case for diversity as a corporate
imperative and must utilize new and creative thinking to address a dynamic
demographic and economic environment to help the company succeed in
the marketplace. The potential for conflict is obvious, given the extremely
different objectives, methods and historical context, as well as the practical
differences of corporate “silos,” where D&I and AAP compliance are usually managed independently and neither collaborates nor coordinates their
activities. All these circumstances can lead to problematic disconnects—for
example, the D&I and AAP teams having differing workforce representation
objectives (e.g., hiring goals), and remedial versus action plans.
;Areas for Collaboration
Consider the following hypo-
thetical situation: The CDO of a
certain company has analyzed the
workforce and has determined
that Latinos are underrepresented
at the senior-manager level. The
reality-based representation-gap
analysis and basis for the CDO’s
determination might include
studies of market-research trends,
customer demands, low current
Latino representation, availability
of Latino senior managers, the
company’s strategic-planning
objectives, relationships with
Latino organizations, and other
real factors—all appropriate, but far
beyond the formalistic “utilization
vs. availability” analysis required
by the AAP regulations. The CDO
appropriately communicates the
goals, objectives and methodologies
to the CEO, HR and senior manage-
ment, and they are included in
the performance objectives of key
leadership. At the same time, AAP
compliance has used the OFCCP
utilization methodology and has
concluded that there is no Latino
underrepresentation (based on
the minimalist methodology and
applicable national, not local,
availability statistics) requiring the
setting of a lower goal, but there is
female underrepresentation using
the same standard. The AAP group
To learn more about effective diversity-management practices, visit
www.DiversityIncBestPractices.com
