Many organizations struggle with how to strategically approach their Affirmative Action programs. The first thought is often to solve the technical aspect: asking “Do I have all the plan mechanics in place?” and “Has my data been scrubbed?” Personnel may form a checklist in their mind centered on the reports they will generate. However, building a living program requires shared objectives, clearly defined roles, and the leveraging of a simple model. In this article, Mark Nagel, Director of Employee Relations and HR Compliance at EssilorLuxottica and President of the North Texas Industry Liaison Group, reveals three basic building blocks for AAP.
Organizations can overthink their affirmative action plans, with aspirational layers of processes and tasks, many times created in a vacuum without business partners and HR support at the planning table. Conversely, other organizations think entirely too little about their affirmative action plans, making it all about the goal of producing a set of reports that all too often sit unseen in an electronic folder. The end result of either approach is often the same—plans are created that fail to connect, and reflect current business realities and are neither ‘affirmative’ nor ‘action’ oriented. It doesn’t have to be this way. In my experience, affirmative action is only complex when your approach is complex.
In short, it’s time to go back to basics.
Defining a Less Complex Approach
A top-level summary of my approach would be that it’s important to have a shared vision and a shared vocabulary. In that spirit, one of the first things I like to do with any team working on affirmative action is to return to the phrase “affirmative action” itself for inspiration.
When we affirm something, we declare it to be a truth, and to give an affirmative answer is to give a positive answer. So when a team produces an affirmative action plan, can they say that it asserts the truth? And does it bring facts to light in a way that inspires a desire to take positive corrective action?
Thankfully, any organization can easily align itself toward an action-orientated AAP strategy by focusing on three basic building blocks.
- Shared goals
- Clearly-defined roles
- An AAP rhythm for reporting, planning, and taking action
1) Realizing Your AAP Aspirations—Your Current State and Shared Goals
Building an affirmative action plan is a journey. Like any other journey, the route you take depends as much on where you’re starting as it does on where you’re going. The first step you should take is to define your current state and desired state.
Example Current States
While your current state will be unique to your business, the following examples may look familiar to many AAP teams:
- “Our program is primarily audit-centric, and reactive”
- “Our compliance team is focused on audit triage”
- “Our audit process is largely unstructured, and managed by our legal team”
- “Our corporate knowledge and messaging surrounding AAP is currently inconsistent”
- “Our AAP goals are inconsistently communicated and we don’t currently report on them”
- “Our AAP roles currently lack definition”
- “Our SMEs have limited AAP knowledge”
Example Desired States
For every current state you define, you should have a goal to which you aspire. So the following desired states would pair with the current states named above:
- “Our program will be proactive and outreach/behavior-based”
- “Our AAP team will be focused on providing knowledge and tools”
- “Our audit process will be properly structured, simply communicated, and managed by our AAP team”
- “We’ll have solid corporate knowledge of AAP that’s explicitly and meaningfully tied to our company’s business and diversity initiatives”
- “Our AAP business rhythms, reporting, and accountabilities will be solid and consistent”
- “We’ll have defined organizational roles for AAP”
- “Our AAP team will have been trained as SMEs”
Why Is Naming These States Important?
In a previous role, I was responsible for re-launching affirmative action at a major company. Having our current and desired states mapped out in this way was critical in helping us visualize what was required not only within my team, but in the wider business.
Ultimately, our business partners are occupied with running the business. In my case, my partners were providing amazing customers service to tens of thousands customers daily. It was essential that I found ways of keeping our messaging around affirmative action simple. We didn’t need them to be AAP practitioners, but they did need to know what actions to take, what we were working towards, and how our current way of working could be keeping us from reaching those goals.
MORE TO READ ON AFFIRMATIVE ACTION | ‘What Are the 26 Items on the OFCCP’s Scheduling Letter and Itemized Listing?’
2) Defining Clear Roles
Part of helping everyone understand what’s required of them, is helping them understand the role they have in the overall process. It’s also helpful for them to understand the role everyone else has, answering the question of “who’s on the playing field with us?” It’s easier to hold each other accountable if we first understand what each of us are charged with doing. This also helps ensure everyone isn’t stepping on everyone else’s toes. Again with a focus on the simple, provide your organization with a common vocabulary of AAP roles. I typically work with a three-role structure, involving a:
- Plan owner
- Plan coach
- Plan supporter
Let’s look closer at each of these roles.
Plan Owner
What do they do?
For every location, you’ll need someone who takes ownership of the AAP. They should create an action plan around the AAP goals they’re given. This plan would involve a strategy of how to approach outreach into the community while creating development and mentoring programs internally. The plan owner should also be recording these good faith efforts, ensuring that they have proof of what was tried as well as the evolving and ongoing rationales for the activities they conduct. Finally, in the event of an OFCCP audit, they would actively own the response to auditors and coordinate delivery of audit materials.
Who are they?
Plan owners are typically top-of-the-house decision-makers at a given business location. Some typical roles would include (depending on the industry and respective org structures):
- Store managers
- Service center managers
- Distribution center managers
- Corporate VPs
- CEOs
Plan Coach
What do they do?
Plan coaches are a lot like sports coaches—they advise the plan owner on what needs to go into the action plan and they also provide the tools and resources needed to execute the plan.
Critically, the plan coach has an ongoing responsibility to challenge the plan owner on the effectiveness of the action plan and associated strategies. Conversations can be held as frequently as appropriate to the business and speaking points leveraged with progress reports. The coach helps continuously assess the tactics in the plan while providing advice on options to course correct away from behaviors that are not producing the desired results.
Who are they?
Plan coaches will have business development, coaching, and strategic planning roles that have ongoing direct contact with the plan owner. Typically they will be:
- District or regional HR leaders
- HR business partners (HRBPs)
Critically, HRBPs are already coaching leaders on aspects such as promotions, demotions, hirings, and development, so it makes sense to leverage their expertise for AAPs as well.
Plan Supporter
What do they do?
Your plan supporters are your larger group of affirmative action, HR, and DE&I subject matter experts. They support the company’s affirmative action plans and processes within their individual area of responsibility, provide advice and guidance within that same area, and work towards the organization’s affirmative action goals by supporting from their respective point of expertise in the organization.
Who are they?
Supporters are drawn from a wide range of areas that intersect with AAP regulations, requirements, and measurement. This includes employees within the following teams:
- AAP/Compliance
- Talent acquisition
- Compensation
- DE&I
- Legal
- HRIS
It’s critical to have all of these different areas involved and capable of coordinating with each other, because not only will they not be experts across each area, but there may be data issues common to AAP that fall across different lines of responsibility. For example, if a person is shown as terminated in one dataset they may still appear on the roster because of a severance agreement—plan supporters will be able to identify and contextualize such inconsistencies for plan owners (and OFCCP auditors, should the need arise).
LEARN MORE ABOUT AAP DATA INTEGRITY | ‘4 Signs That Your Applicant Data Won’t Pass an OFCCP Audit’
3) Finding a Rhythm and Building a Simple Model
Once we’ve defined what needs to be done, and what everyone is responsible for doing, we need to clearly define when aspects of the plan should happen.
As my example above demonstrates, this rhythm doesn’t need to be especially complex. It’s really a sequence of quarterly tasks, with the only exception being a 30-day checkpoint after the initial annual plan release. Depending on the business or industry the rhythm can be even semi-annually. This quarterly example illustrates:
- A single annual plan release to owners, coaches, and supporters with defined goals and a progress report of prior year goals.
- A 30-day checkpoint after the annual plan release, allowing time for feedback, challenge identification, and refinement ahead of the action plan creation and loading into your resource center
- Quarterly progress reports
- A half-year progress report release, including an action plan report card, a follow-up on the areas of challenge, and a potential realignment of goals
- The cycle repeats annually, allowing for continuous refinement and ensuring the organization can react to market changes
The most important thing is that you find a rhythm that makes sense for your industry and the availability of leadership—a rhythm that keeps people accountable, without demanding too much of their time, and asks the right questions at a time that’s relevant.
The example rhythm is illustrative of a retail model, accounting for the fact that certain quarters are more important than others because of hiring patterns. Specifically, Q3 involves a greater focus on hiring ahead of a busy Q4, so it makes a lot of sense to give more detailed information in the Q3 progress report release helping everyone prepare to make better-informed outreach decisions.
FURTHER THOUGHTS ON AAPS IN THE CONTEXT OF THE WIDER BUSINESS | ‘Getting the Business On Your Side: How to Talk About Affirmative Action Data With Everyone Else’
Bonus Round—Some Common Tools
Organizing the information at the plan level: Historically, one of the most effective tools I’ve had (and one which nowadays we go all-digital for) is an AAP binder. This binder would be sent out to our teams, with tabs for goals, for outreach, and progress reports, providing a ‘home’ for the AAP at the location, all at the fingertips of the plan owner. This was a resource that was available for quick reference, but could also be used as a place to store the documentation of their efforts.
Message from senior leadership: Sometimes, the message won’t get heard unless it’s delivered by the right person. A message from the CEO and senior executives explaining why this work is important remains highly effective—though thankfully these days you won’t have to burn it to a DVD and mail it to every one of your locations! It could be part of your eLearning, for example.
Training: I’ve usually offered a couple courses on the subject: one general-purpose piece helping people understand why AAPs are important, and another that gets more into the mechanics of what’s required.
Don’t be afraid to get creative. While video is engaging, other tools such as gamification are worth a look if your budget stretches that far. At one of my previous roles, we provided a particularly fun piece where learners could build their outreach program in a simple simulation game. This helped illustrate how potential talent pools changed for certain locations.
In Conclusion
Simplifying affirmative action is all about making changes in how you present what needs to be done. For example, you may have noticed a rule of three theme, have you ever tried remembering a multistep list or plan? Usually a rule of three is achievable and can stick in people’s memory.
I’d encourage you to always be on the lookout for opportunities to simplify. By focusing on shared goals, clearly defined roles, and an AAP rhythm that takes business uniqueness into consideration, you can be well on your way. The answer is truly ‘simple’: look for ways to simplify your strategy, your roles, and program message. Challenge yourself to hear the feedback from your organization on the execution of your program. Evolve, simplify, and repeat, and the realization of your organization’s AAP aspirations is sure to follow.
About the Author
Mark Nagel has over 25 years of experience in human resources, operations, organizational development, change management, training, HR compliance, and affirmative action planning. He is currently Director of Employee Relations and HR Compliance at EssilorLuxottica and has previously held roles at Southwest Airlines, Best Buy, and Target Stores. He’s also President of the North Texas Industry Liaison Group, a collaborative forum that promotes workplace equality through education and thought leadership. Follow him on LinkedIn.