How to Stay OFCCP Compliant in Your Promotion Policy and Hiring Procedure

  To stay OFCCP compliant, be very precise in outlining your company’s Promotion Policy and Hiring Procedure.  A case was handed over to me to investigate when it was stalled by the original Compliance Officer. An Impact Ratio Analysis could not be conducted.  The original CO saw that females were not upper level Job Groups.  The assumption was potential discrimination for females. The company did not have a set procedure to handle promotions.  When a position is posted internally...
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