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Developing an Effective OFCCP Compliance Programfor Job Posting and Distribution14th Annual Compliance Conference - Phoenix, AZ - November 15, 2011Rathin SinhaPresident, America’s Job ExchangeAmerica’s Job Exchange400 Minuteman Road, Andover, MA 01810www.americasjobexchange.com
Agenda Compliance Regulations Contractor Obligations Implementation Challenges The Case for Third Party Vendors The AJE Advantage Q&APage 2Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
OFCCP Regulations – The Broad ViewThe OFCCP mandates that companies doing business with the Federal government mustcomply with the following set of regulations in their recruitment practices. Executive Order 11246Prohibits Federal contractors from discriminating in employment decisionsbased on race, color, religion, sex or national origin. Section 503 of the Rehabilitation Act of 1973Requires Federal contractors to take affirmative action to hire, retain andpromote individuals with disabilities. Vietnam Era Veteran’s Readjustment Act, as amended inconjunction with Jobs for Veterans Act (VEVRA/JVA)Requires Federal contractors to take affirmative action to hire, retain andpromote veterans.Page 3Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
OFCCP Regulations – The Spirit of the LawCompanies must take measures to ensure that job vacancy announcements reach jobseekers who are veterans, minorities, women and persons with disabilities. Executive Order 11246Post job vacancy announcements to expose them to a large number ofminorities, women, and underrepresented groups. Section 503 of the Rehabilitation Act of 1973Reach out to persons with disabilities and provide information about jobvacancy announcements. Vietnam Era Veteran’s Readjustment Act (VEVRAA/JVA)List all employment opportunities with the appropriate employment deliverysystem in the state where the job is located.Page 4Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
OFCCP Regulations – The Letter of the LawThe regulations are very specific as they relate to job posting requirements for VEVRAA/JVA What are the new job listing requirements under the Jobs for Veterans Act?The Jobs for Veterans Act (JVA) and the regulation implementing the JVA at 41 CFR 60-300.5 require that contractorslist job openings with the appropriate employment service delivery system. What type of agency is considered part of the local employment service delivery system?The employment service delivery system means the public employment offices established under the Wagner-PeyserAct, and known as the Employment Service, that provide a variety of labor exchange services including, but not limited to,job search assistance, job referral, placement assistance, re-employment services and recruitment services. Is there a particular way contractors must list employment openings with the appropriateemployment delivery system?A contractor may satisfy the mandatory job listing requirement by using any means that is permitted by the appropriateemployment delivery system for listing employment openings, which may include mail, facsimile (FAX), electronicmail, or other electronic postings. The vast majority of the state workforce agency job banks accept job listings via theInternet. Contractors may use third parties, such as private or non-profit sector job banks, Internet gateway and portalsites, and recruiting services and directories, to assist them with the transmission of job listings to the appropriateemployment service delivery system. However, a contractor remains responsible for complying with OFCCP's joblisting requirements.Source: aqs.htm#Q11Page 5Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
Contractor ObligationsThe law obligates contractors to be accountable for a set of activities, whether performinginternally or using a third party vendor, and to be ready to show proof, if audited. Post Jobs in National Job SitesPost job listings in job sites that reach large number of seekers includingminorities, women, veterans and the disabled. Post Jobs in Niche Job SitesPost jobs in niche job sites that are specifically targeted to minorities, women,veterans and people with disabilities. Send Jobs to State Employment Delivery SystemsSend job listings to the public employment offices by mail, fax, email or otherelectronic means, or to the state job banks.Page 6Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
Implementation ChallengesFor most contractors performing these tasks internally and maintaining proper records islabor intensive and incurs a significant expense. Major Job Sites are ExpensiveA single job posting for a specific location costs approximately 400. Niche Job Sites are ExpensiveA single job posting costs approximately 175, and costs rise fast whenposting in multiple sites to reach different audiences. Cost to Send Jobs to State Systems is HighState job banks are free, but manually posting to them is labor intensive as issending jobs to employment offices by mail, fax or email. Administrative Costs of Maintaining Records is SignificantKeeping detailed records can create a lot of work for internal employees, aswell as maintaining consistency of content.Page 7Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
A Better AlternativeFor a fraction of this cost, Federal contractors can obtain solutions from third party vendorssuch as America’s Job Exchange (AJE), a leader in recruitment compliance. Job Postings on AJE and the AJE Network of Job SitesListings that reach a million job seekers per month with a largeconcentration of minorities, women, veterans and the disabled. Job Postings to Niche Diversity Partner WebsitesListings that reach job seeker audiences in targeted communities ofminorities, women, veterans and people with disabilities. Job Delivery to the Appropriate State Employment SystemsAutomated job delivery to State Workforce centers, Career One StopCenters, LVERs and DVOPs, and CBO organizations. On-Demand Audit Reporting with Custom Report DownloadsShows record of job posting and delivery, related links and job description,time and date stamps, and delivery confirmation.Page 8Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
Efficiency DriversThird party vendors such as AJE achieve efficiency through a combination of automatedtechnology, partnerships, domain expertise and scale economics. Automated TechnologyState-of-the-art web platform, job distribution technology, dataexchange mechanism, and search methodologies. PartnershipsLarge network of partnerships with niche job sites, communityorganizations, states, associations and employment agencies. Domain ExpertiseAs developer and operators of the America’s Job Bank program, AJEhas more than 15 years of experience in this area. Scale EconomicsAJE serves more than 500 of the leading enterprises for compliancesolution and derives efficiency from repetitive processes.Page 9Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
Additional BenefitsSolutions from a third party vendor such as AJE also provide additional products to bolsterROI of your recruitment media and advertising program for diversity and inclusion. Traffic GenerationGet traffic to your jobs as well as to your career website throughsearch engine optimization (SEO) and search marketing (SEM). Recruitment Brand DevelopmentA full suite of media products for recruitment sourcing, corporatebranding, diversity branding and advertising. Recruitment Technology ServicesA full suite of technology services including data feed preparation,career site development and hosting. Audit Support and Document ManagementLive customer service and assistance in the event of an auditincluding consultation, and retrieval of past documents.Page 10Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
Third Party Vendor Selection CriteriaContractors should consider the following criteria when selecting a third party vendor.What’s ImportantWhat’s Not Important Completeness/Customizability Irrelevant ProductsDoes the solution address the regulation fully and is itcustomizable for your business?Don’t get sidetracked by products that are not related tocompliance requirements. Breadth of Distribution EndorsementsDoes the provider maintain a large network of partners forjob distribution?Remember that endorsements are nothing but PAID salespitches! Reporting and Support Marketing GimmicksDoes the solution provide easy access to reports andexpert support if your company is audited?Beware of aggressive sales/marketing talk. Stay focused onwhat you need. Reputation and Track Record Exaggerated PromisesHow long has the vendor been providing these services andhow satisfied are their customers?Don’t fall for over-promises by vendors exaggerating theeffectiveness of the solution.Page 11Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
America’s Job Exchange – A Brief OverviewAmerica’s Job Exchange is one of the fastest growing companies in the industry and aleading provider of recruitment media, advertising and compliance solutions provider. Legacy of America’s Job BankAJE launched on the same technology platform with the same peoplewho developed and operated the DOL program. Backed by a Fortune 500 CompanyAJE is a wholly owned subsidiary of Time Warner Cable with thefinancial and technology resources to drive product innovation. Fast GrowingAJE is one of the fastest growing job boards with an expandingproduct line, customer base and partnerships. Customer CentricAJE products are packaged and optimized to meet the needs of small,medium and large businesses across industry verticals.Page 12Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
America’s Job Exchange - Solution SummarySeveral AJE products and servicesare bundled to form the industry’smost complete Job Listing andDistribution SolutionIndustry leading tools, technologiesand live assistance are combined tooffer an unparalleled customerexperiencePage 13Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
The AJE DifferenceThe solution from America’s Job Exchange is well differentiated from others. Completeness of SolutionBundles several distinct products and services to satisfy the broadrange of tasks required by the regulators.REPUTATION Customizability of SolutionThe AJE solution is customizable and priced based on your businessneeds with variables such as size, hiring forecast and budget.TRACK RECORD Breadth of Distribution NetworkBroad network of partners and affiliates including recruitment mediaagencies, technology provider, associations and states. Subsidiary of Publicly Traded CompanyAJE is not a membership-based non-profit association but part of acustomer centric, publicly traded organization you can trust.Page 14Visit www.americasjobexchange.com/employer or Call 1-866-923-6284CLIENTELE
ConclusionThird parties such as America’s Job Exchange are a significant resource available toFederal contractors who must meet the OFCCP compliance regulations in recruitment. ComprehensiveUtilize a turnkey set of products and services to fulfill current requirementsand stay abreast of changing regulations with updates and new products. Cost EffectiveThe cost of services is significantly lower than companies doing the samework internally or using an agency to do in pieces. ExpertiseCompliance services being the core offering, third party vendors provide deepexpertise and domain experience to help contractors navigate the regulations.Page 15Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
Thank YouFor more information, please contact:Rathin Sinharsinha@americasjobexchange.comPage 16Visit www.americasjobexchange.com/employer or Call 1-866-923-6284
Developing an Effective OFCCP Compliance Program for Job Posting and Distribution 14th Annual Compliance Conference - Phoenix, AZ - November 15, 2011 Rathin Sinha President, America's Job Exchange. . The OFCCP mandates that companies doing business with the Federal government must
