HomeMy WebLinkAboutAFFIRMATIVE ACTION PLAN FOR VETERANS AND INDIVIDUALS WITH DISABILITIES EEO OFFICE JANUANRY 1 2008- DECEMBER 31, 2008
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AFFIRMA TIVE ACTION PLAN
FOR VETERANS AND
INDIVIDUALS WITH DISABILITIES
Equal Employment Opportunity (EEO) Office
Augusta-Richmond County Government
January 1,2008 - December 31, 2008
, The Mayor, the Augusta Richmond County Commission and the City Administrator
Diana Darris, MJPS
EEO Coordinator
Designated Affirmative Action Plan Manager
TABLE OF CONTENTS
Preface................................................................................................................. .3
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Statement of Policy. .................. .1..................................................... ~..................... .....4
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Definitions..............................!......................................................................... ......5
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Responsibility for Implementation.. J.. ... ............... ...... ....... ........... ........... .......... ... ......... ..7
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Request for Self-Identification....... ~........................................................................... ....8
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Review of Personnel Processes. . . . . . ! . . . . . . . . . . . . . . . . . . . .. . . . . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . .. . . . . .. . . . . . . . .. . .... . .9
Review of Physical and Mental Job Requirements..................................................... .... .......11
Reasonable Accommodations....................................................................... ............. ...12
Compensation. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . ... . . . . . . . . . . . ...14
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Outreach, Positive Recruitment, andlExternal Dissemination of Policy. ...... ....... ......... ... .......... ...15
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Internal Dissemination of Policy. ..... . . ..... . .. . .. . . . . .. . .. . .. . .. . .. ... . .. . .. . .. . . . ... . . . . .. . .. . .. . ........ .. .. . . ..17
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Development and Execution of AAPs. . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . ... . .18
Internal Review Procedure....... ................ ...... ...... ... ... ............... ... ......... ...... ............. ....19
Monitoring and Reporting Systems..... ............... ... ... ...... ...... ... ......... ......... ...... ... .......... ..20
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Training. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . .22
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Harassment. . . . . . . . . . . .. . . . . . . . .. . . . . . . . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . .. . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . . ... . .. . . . . . ..26
Exhibits
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PREFACE
Augusta Richmond County is committed to the concept and practice of equal opportunity and
affirmative action. In the preparation of this Affirmative Action Plan (AAP), Augusta-Richmond
County has been guided by Section 503 of the Rehabilitation Act of 1973 (as amended) (29 V.S.C.
Section 793) and its implementing OFCCP regulations (41 C.F.R. Part 60-741), and the Vietnam Era
Veterans' Readjustment Assistance Act of 1974 (as amended) (38 V.S.C. Sections 4211 and 4212) and
its implementing OFCCP regulations (41 C.F.R. Parts 60-250 and 300). Nothing contained in this AAP
or its supporting data should be construed as an admission by Augusta-Richmond County, in whole or in
part, that it has contravened any federal, state, or local employment laws or regulations.
In developing and implementing this AAP, Augusta Richmond County relied on its established policy of
providing equal employment opportunity. Nothing herein is intended to sanction the discriminatory
treatment of any person or group. This AAP has been developed in strict compliance with the
Guidelines on Affirmative Action issued by the Equal Employment Opportunity Commission (EEOC)
(29 C.F.R. Part 1608) and other applicable law.
While Augusta-Richmond County firmly believes in wide dissemination of its affirmative action
policies and equal employment opportunity practices, certain data generated in accordance with this
AAP contains private data and proprietary information relating to the organization's business that is
subject to protection.
This AAP and its support data are to be disclosed with the following requirements:
1. Information submitted to the Office of Federal Contract Compliance Programs (OFCCP)
pursuant to this AAP and applicable laws and regulations, it is to be considered confidential and
not subject to public disclosure by the OFCCP without notifying Augusta-Richmond County of
the agency's decision to disclose and providing Augusta-Richmond County with ample time to
contest the disclosure.
2. If this information is supplied to a government contractor, EEOC representative, or any other
person who is given access to the AAP, it is not to be copied, reproduced, or disclosed without
prior notification to Augusta-Richmond County.
3. No information contained in the AAP is to be copied, removed from the premises, or released to
other individuals without a prior notification to Augusta-Richmond County.
4. Subject to the limitations contained herein, this AAP shall be accessible for open review by
Augusta- Richmond County employees and the public and shall be posted in conspicuous places
at Augusta-Richmond County.
All monitoring system reports as required by federal regulations and laws have been completed in
preparation of creating this AAP.
This AAP does not constitute an express or implied contract between Augusta-Richmond County, its
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officers, employees or agents, nor does it change in any way the at-will employment relationship that all
Augusta-Richmond County employees have with Augusta-Richmond County. Nothing in this AAP
creates a private right of action on behalf of any individual or group against Augusta-Richmond County.
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STATEMENT OF POLICY
41 C.F.R. 60-741.44(a), - 250.1, -300.44(a)
It is the policy of Augusta Richmond County not to discriminate on the basis of a physical or mental
disability or an individual's status as a Covered Veteran with regard to recruitment or recruitment
advertising, hiring, training, promotion, and other terms and conditions of employment, provided the
individual is qualified, with or without reasonable accommodations, to perform the essential functions of
the job. Augusta-Richmond County does and will take affirmative action to employ, advance in
employment, and otherwise treat qualified individuals with disabilities and Covered Veterans without
discrimination based upon their physical or mental disability, or veterans' status, in all employment
practices as follows:
Employment decisions at Augusta-Richmond County are based only on job-related criteria. All
personnel actions or programs that affect qualified individuals with disabilities or Covered Veterans,
such as employment, upgrading, demotion or transfer, recruitment, advertising, termination, rate of pay
or other forms of compensation, and selection for training, will be made without discrimination based
upon the individual's physical or mental disability or veterans' status.
Augusta-Richmond County makes, and will continue to make, reasonable accommodations to promote
the employment of qualified individuals with disabilities and disabled veterans, unless such
accommodations would impose an undue hardship on Augusta-Richmond County.
The EEO Coordinator for Augusta-Richmond County, will manage Augusta Richmond County's AAP
for individuals with disabilities and Covered Veterans. The AAP includes an audit and reporting
system, which, among other things, measures the effectiveness of the AAP. Managers and supervisors
will take an active part in Augusta-Richmond County's AAP to ensure that all qualified employees with
disabilities and Covered Veterans and prospective employees are considered and treated in a non-
discriminatory manner with respect to all employment decisions. Furthermore, Augusta Richmond
County will solicit the cooperation and support of employees for Augusta-Richmond County's policy
and AAP. The EEO Coordinator has been assigned responsibility for periodically reviewing progress in
the compliance and implementation of the policy of affirmative action for individuals with disabilities
and Covered Veterans. The EEO Coordinator's identity should appear on all internal and external
communications regarding Augusta-Richmond County's affirmative action program. In accordance with
public law, Augusta-Richmond County's plan of affirmative action for individuals with disabilities and
Covered Veterans is available for inspection in the Human Resources Department during regular
business hours upon request.
In addition, employees and applicants will not be subjected to unlawful harassment, intimidation,
threats, coercion, or discrimination because they have engaged in, or may have engaged in, legally
protected activities which could include filing a complaint, assisting or participating in an investigation,
compliance review or hearing, or opposing any act or practice made unlawful, or exercising any other
right protected by Section 503 of the Rehabilitation Act of 1973, as amended or the Vietnam Era
Veterans Readjustment Assistance Act of 1974, as amended.
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DEFINITIONS
"SPECIAL DISABLED VETERAN" means a veteran ofthe V.S. military, ground, naval or air service
who is entitled to disability compensation (or who but for the receipt of military retired pay would be
entitled to compensation) under laws administered by the Department of V eterans Affairs for disability
rated at 30 percent or more, or rated at 10 to 20 percent in the case of a veteran determined under 38
V.S.C. 3106 to have a serious employment handicap, or a person whose discharge or release from active
duty was for a service-connected disability.
"DISABLED VETERAN" is (1) A veteran of the U.S. military, ground, naval or air service who is entitled to
compensation (or who but for the receipt of military retired pay would be entitled to compensation) under laws
administered by the Secretary of Veterans Affairs, or (2) A person who was discharged or released from active
duty because of a service-connected disability.
"QUALIFIED DISABLED VETERAN" means a special disabled veteran or disabled veteran as defined above
who satisfies the requisite skill, experience, education, and other job-related requirements of a particular job and
is capable of performing the essential functions with or without reasonable accommodations made for his or her
disability .
"VETERAN OF THE VIETNAM ERA" means a person who (i) served on active duty in the U.S. military,
ground, naval or air service for a period of more than 180 days, in the republic of Vietnam between February 28,
1961 and May 7, 1975, and was discharged or released there from with other than a dishonorable discharge, or (ii)
served on active duty in the U.S. military, ground, naval, or air service for a period of more than 180 days, any
part of which occurred between August 5, 1964 and May 7, 1975, and was discharged or released there from with
other than a dishonorable discharge, or (iii) was discharged or released from active duty in the U.S. military,
ground, naval or air service for a service-connected disability if any part of such active duty was performed in the
Republic of Vietnam between February 28, 1961 and May 7, 1975, or in another place between August 5, 1964
and May 7, 1975.
"ARMED FORCES SERVICE MEDAL VETERAN" is any veteran who, while serving on active duty in the U.S.
military, ground, naval or air service, participated in a United States military operation for which an Armed
Forces service medal was awarded pursuant to Executive Order 12985.
"OTHER PROTECTED VETERAN" means a veteran who served on active duty in the U.S. military, ground,
naval or air service during a war or in a campaign or expedition for which a campaign badge has been authorized,
under the laws administered by the Department of Defense.
"RECENTLY SEP ARA TED VETERAN - ONE YEAR" means any veteran during the one-year period beginning
on the date of the veteran's discharge or release from active duty.
"RECENTLY SEPARATED VETERAN - THREE YEARS" means any veteran during the three-year period
beginning on the date of such veteran's discharge or release from active duty in the U.S. military, ground, naval or
aIr servIce.
"COVERED VETERANS" means special disabled veterans, disabled veterans, veterans of the Vietnam Era,
Armed Forces service medal veterans, other protected veterans, recently separated veterans-one year, and recently
separated veterans-three years.
"INDIVIDUAL WITH A DISABILITY" means a person who, generally, (i) has a physical or mental impairment
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that substantially limits one or more of his or her major life activities, (ii) has a record of such impairment, or (iii)
is regarded as having such an impairment.
For the purposes of this Plan, an individual with a disability is "substantially limited" ifhe or she is unable to
perform a major life activity that the average person in the general population can perform, or is significantly
restricted as to the condition, manner, or duration under which a person can perform a particular major life
activity as compared to the condition, manner, or duration under which the average person could perform that
same activity.
"A QUALIFIED INDIVIDUAL WITH A DISABILITY" means an individual with a disability as defined above
who meets the requisite skill, experience, education, and other job-related requirements for a particular job and is
capable of performing that job, with or without reasonable accommodation for his or her disability.
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RESPONSIBILITY FOR IMPLEMENTATION
41 C.F.R. 60-741.44(i), 41 C.F.R. 60-250.44(i), -300.44(i)
Affirmative action for individuals with disabilities and Covered Veterans is the responsibility of every
employee at Augusta Richmond County. Augusta-Richmond County's EEO Coordinator is responsible
for the implementation and monitoring ofthis AAP at Augusta-Richmond County. The EEO
Coordinator has the support and staff to manage the implementation ofthis Plan. In carrying out this
responsibility, the EEO Coordinator and designated staffwill:
o Develop AAP policy statements, and internal and external modes of communication,
o Coordinate with officers, managers, supervisors, and employees to ensure that Augusta-
Richmond County's AAP is followed;
o Encourage supervisors to demonstrate a commitment to affirmative action efforts and results, as
well as working to prevent harassment of employees placed through affirmative action efforts;
o Identify, in conjunction with Department Directors and other management, known employees
with disabilities and Covered Veterans and coordinate solutions in implementing this AAP,
including possible modes of accommodation;
o Design and implement internal audit and reporting systems that measure the effectiveness of this
AAP, indentify the need for remedial action, determine the degree to which Augusta-Richmond
County's AAP objectives have been attained, ensure that, from an implementation perspective,
Augusta-Richmond County is in compliance with applicable laws and regulations relating to this
AAp.1
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o Serve as liaison between Augusta-Richmond County and enforcement agencies, and between
Augusta-Richmond County and organizations of and for persons with disabilities,2 and
encourage active involvement by Augusta-Richmond County representatives in the community
service programs of local organizations of and for individuals with disabilities and Covered
Veterans;
o Keep officers and employees of Augusta-Richmond County informed of the latest AAP
developments;
o In conjunction with Human Resources and Department Directors, arrange for career counseling
for known employees with disabilities and Covered Veterans, where appropriate.
1 Nothing in this section is intended to preclude Augusta-Richmond County from obtaining legal advice and representation
related to any aspect of this AAP.
2 In the event of any conflict or legal dispute arising out of or relating to this AAP, nothing in this section is intended to
preclude Augusta-Richmond County's legal representatives from communicating with enforcement agencies or any person or
organization challenging any aspect of this AAP.
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REQUEST FOR SELF-IDENTIFICATION
41 c.F.R. 60-741.42, 41 C.F.R. 60-250.42, -300.42
Following an offer of employment but prior to an individual beginning other employment duties,
Augusta Richmond County invites job applicants, who are individuals with disabilities or Covered
Veterans and believe themselves covered by the Rehabilitation Act of 1973, as amended, or the Vietnam
Era Veterans' Readjustment Assistance Act of 1974, as amended, to identify themselves in order to
receive the benefits ofthis AAP (see Exhibit A). If an individual identifies himself or herself as an
individual with a disability or a disabled veteran, Augusta-Richmond County seeks the advice of the
individual concerning any necessary accommodations to allow the individual to perform his/her job.
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REVIEW OF PERSONNEL PROCESSES
41 C.F.R. 60-741.44(b), 41 C.F.R. 60-250.44(b), -300.44(b)
Augusta Richmond County is committed to reviewing its personnel procedures to ensure the careful,
thorough, and systematic consideration of individuals with disabilities or Covered Veterans for job
vacancies, promotions, and/or educational or training opportunities and to assure that the personnel
processes facilitates the implementation of Augusta-Richmond County's affirmative action obligations.
Augusta-Richmond County job vacancies are advertised as open to any interested person meeting the
job requirements and applications are accepted from any interested person meeting the job requirements.
Augusta Richmond County's employment application includes a full non-discrimination statement to
further assure applicants of Augusta-Richmond County's policy of equal employment. All non-
executive positions that Augusta-Richmond County does not expect to fill from within will be referred
to the State Department of Employment and Training, as well as other recruiting sources.
Except as otherwise indicated herein, the disability or veteran status of any otherwise qualified
individual who applies for any job vacancy, promotion, transfer, or training opportunity will not be a
factor in these employment decisions. Augusta-Richmond County periodically reviews the physical and
mental job qualifications to ensure that they do not tend to screen out individuals with disabilities or
Covered Veterans for reasons that are not job-related or consistent with business necessity, nor
consistent with the safe performance of the essential functions of the job. Thus, subject to these
limitations, individuals with disabilities and Covered Veterans who meet job qualifications will be
considered on an equal basis with all other applicants. Moreover, Augusta-Richmond County considers
military experience only to the extent that it increases the veteran's qualification for the job. Finally,
Augusta-Richmond County ensures that its personnel processes do not impermissibly stereotype
individuals with disabilities or Covered Veterans.
Consistent with the applicable laws and regulations, Augusta-Richmond County has instituted the
following procedures to further assure the careful, thorough, and systematic consideration of the job
qualifications of employees or job applicants, who are known individuals with disabilities or Covered
Veterans for job vacancies, promotions, and/or educational or training opportunities and to assure that its
personnel practices facilitate the implementation of Augusta-Richmond County's affirmative action
obligations:
1. To the extent that individuals covered under this AAP apply for positions within Augusta-
Richmond County and disclose their disabilities and/or veterans status, their personnel forms will
be annotated to identify each vacancy for which they were considered.
2. The personnel records of each known covered individual will include (i) the identification of
each promotion for which the person was considered, and (ii) the identification of each training
program for which the person was considered.
3. In each case where a covered individual is rejected for employment, training, or promotion, a
statement of the reasons will be appended to the file. This statement will include a comparison
of the qualifications of the covered individual and the person(s) selected.
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4. Where applicants or employees are selected for hire, promotion, or training and Augusta-
Richmond County undertakes any accommodation which makes it possible to place a person
covered under this AAP in the job, Augusta-Richmond County will keep a record of the
accommodation in a confidential medical file.
Subject to the limitations under law, this information will be available for review by government
officials and Augusta-Richmond County's personnel officials for use in investigations and compliance
activities.
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REVIEW OF PHYSICAL AND MENTAL JOB REQUIREMENTS
41 C.F.R. 60-741.44(c), 41 C.F.R. 60-250.44(c), -300.44(c)
Augusta Richmond County reviews physical and mental job qualification requirements as job
qualification requirements are established or revised to ensure that qualification requirements do not
screen out qualified individuals with disabilities or qualified disabled veterans for reasons that are not
job-related, consistent with business necessity and the safe performance of the essential functions of the
job.
To the extent that any physical or mental job qualification measurements tend to screen out qualified
individuals with disabilities or qualified disabled veterans in the selection of employees or applicants for
employment, promotion or training, Augusta Richmond County will take the necessary steps to ensure
that the requirements are related to the specific job(s) for which the individual is being considered and
are consistent with business necessity and the safe performance ofthe job.
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ACCOMMODATIONS
41 C.F.R. 60-741.44(d), 41 C.F.R. 60-250.44(d), -300.44(d)
Augusta Richmond County has made and will continue to make reasonable accommodations, which do
not impose undue hardships on it, to accommodate the known physical and mental limitations of
otherwise qualified employees and job applicants.
Included among the specific accommodations for individuals with disabilities and disabled veterans that
have been implemented are the following:
1. Short- and long-term disability programs that provide pay for eligible employees absent due to
disability.
2. A personal leave policy that enables eligible employees to accumulate paid time off to be used
for medical appointments, personal illness, or other disability related reasons.
3. A medical leave of absence is available to an employee who provides medical documentation of
disability.
4. Should reasonable accommodations be necessary to facilitate access to work areas by employees
or applicants who are qualified individuals with disabilities or qualified disabled veterans,
Augusta-Richmond County will take any reasonable steps to provide such accommodations.
5. If necessary to accommodate a disability, Augusta-Richmond County will redesign jobs to
eliminate nonessential functions unless the redesign creates an undue hardship.
6. For employees covered under this AAP, Augusta-Richmond County will arrange suitable work
hours for employees returning from sick leave, approved medical leave of absence, and long-
term disability, where such scheduling accommodations are reasonable.
7. For employees covered under this AAP, Augusta-Richmond County will accommodate
employees with disabilities by allowing a reasonable amount of time off for physicians' visits.
8. Special parking for individuals with disabilities or disabled veterans is available at Augusta
Richmond County.
If an individual has a disability or is a disabled veteran, he or she is encouraged to tell us about (i) any
special methods, skills, and procedures which qualify him or her for positions which he or she might not
otherwise be able to do so that he or she will be considered for any position ofthat kind, and (ii) the
accommodations which would enable him or her to perform the job properly and safely, including
special equipment, changes in the physical layout of the job, elimination of certain duties related to the
job, provision of personal assistance services, or other accommodations. These individuals may contact
the Human Resources Department or the EEO Office.
Where an employee who is known to be an individual with a disability or a disabled veteran is having
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significant difficulty performing his/her job and Augusta-Richmond County reasonably concludes that
the performance issues may be related to the known disability, Augusta-Richmond County will notify
the employee of the performance problem and confidentially inquire whether the problem is related to
the employee's disability. If the employee indicates that his/her disability is impacting his/her
performance, Augusta-Richmond County will engage in confidential discussions with the employee
regarding reasonable accommodations to improve performance.
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COMPENSATION
41 c.F.R. 60-741.21(i), 41 C.F.R. 60-250.21(i), -300.21(i)
In offering employment or promotions, Augusta Richmond County does not reduce the amount of
compensation offered to individuals with disabilities or Covered Veterans because of any disability
income, pension, or other benefit that the employee receives from another source.
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OUTREACH, POSITIVE RECRUITMENT AND
EXTERNAL DISSEMINATION OF POLICY
41 C.F.R. 60-741.44(f), 41 C.F.R. 60-250.44(f), -300.44(f)
Augusta Richmond County has reviewed its employment practices to determine whether personnel
programs provide the required affirmative action for employment and advancement of qualified
individuals with disabilities and qualified Covered Veterans.
While Augusta-Richmond County believes that there are no deficiencies in its current employment
practices with respect to these employees, it has planned the following outreach, positive recruitment,
and external dissemination programs to augment its existing affirmative efforts:
1. Commissioners, management officials, supervisors, and other employees of Augusta-Richmond
County will be encouraged to assist in the effort to disseminate Augusta Richmond County's
policy of affirmative action to individuals who are not employees of Augusta-Richmond County.
2. Augusta-Richmond County will inform recruiting sources of Augusta Richmond County's policy
of affirmative action for individuals with disabilities and Covered Veterans. Recruiting sources
will be requested to actively recruit and refer qualified individuals with disabilities and qualified
Covered Veterans for all positions.
3. Augusta Richmond County will enlist the assistance and support of local recruiting sources,
social service agencies, and organizations especially knowledgeable about the availability of
individuals with disabilities and Covered Veterans.
These sources will be informed of Augusta-Richmond County's AAP and will be requested to
refer qualified individuals with disabilities and qualified Covered Veterans for employment
consideration, including those not currently in the workforce who have requisite skills.
4. Augusta Richmond County will incorporate the affirmative action clause for individuals with
disabilities in purchase orders, leases, and contracts made by Augusta-Richmond County which
are covered by the Rehabilitation Act of 1973, as amended, and its implementing regulations.
The affirmative action clause for Covered Veterans will be incorporated in purchase orders,
leases, and contracts made by Augusta-Richmond County that are covered by the Vietnam Era
Veterans' Readjustment Assistance Act of 1974, as amended, and its implementing regulations.
5. Augusta Richmond County will notify local organizations, community agencies, secondary
schools, and colleges known to specialize in assisting individuals with disabilities and Covered
Veterans about this AAP and request their advice, assistance, and referrals of potential
employees, including those who are not currently in the work-force but who have requisite skills.
6. Augusta Richmond County will make an effort to include disabled individuals and/or Covered
Veterans when employees are pictured in consumer and personnel recruitment advertising.
7. Augusta Richmond County will make reasonable accommodations for qualified individuals with
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disabilities and qualified disabled veterans.
8. Augusta Richmond County will take positive steps to attract qualified individuals with
disabilities and Covered Veterans not currently in the work-force who have requisite skills and
can be recruited through affirmative action measures.
9. Augusta Richmond County will review the employment records of its known employees with
disabilities or Covered Veterans to determine the availability of promotable, qualified individuals
with disabilities, and to determine whether present and potential skills are being fully utilized or
developed.
10. For all contractors, subcontractors, vendors, and suppliers requesting appropriate action on their
part, Augusta-Richmond County will notify them, in writing, of this AAP.
11. When Augusta Richmond County advertises in newspapers for prospective employees, the
advertisement will include the EEO solicitation statements such as "Equal Opportunity Employer
M/F/DN" or a relevant abbreviation.
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INTERNAL DISSEMINATION OF POLICY
41 C.F.R. 60-741.44(g), 41 c.F.R. 60-250.44(g), -300.44(g)
Augusta-Richmond County recognizes that, however strong its outreach program, internal support from
supervisory management and other employees is necessary to ensure maximum effectiveness of its AAP
for individuals with disabilities and Covered Veterans so that employees awareness of the needs of
individuals with disabilities and Covered Veterans can be increased. Accordingly, Augusta-Richmond
County will utilize the following procedures to maximize the internal implementation and dissemination
of its policy:
1. Augusta Richmond County will invite employees who are individuals with disabilities or
Covered Veterans to participate in the AAP.
2. Augusta-Richmond County will communicate to employees its obligation to take affirmative
action to employ qualified individuals with disabilities and qualified Covered Veterans and will
encourage employee referral of covered applicants.
3. Augusta Richmond County's policy on affirmative action for veterans and individuals with
disabilities is posted on Augusta-Richmond County bulletin boards. The posting includes a
statement that employees and applicants are protected from unlawful coercion, intimidation, and
interference or discrimination for filing a complaint or assisting in an investigation under the
Rehabilitation Act of 1973, as amended, or the Vietnam Era Veterans' Readjustment Assistance
Act of 1974, as amended.
4. Meetings with Department Directors and supervisory personnel will be conducted at least
annually to review Augusta-Richmond County's policy of affirmative action and to impart to
these personnel their role in making the AAP a success.
5. Meetings with all employees of Augusta-Richmond County will be conducted by Department
Directors to inform the employees of Augusta Richmond County's policy of affirmative action
and to explain the employees' responsibility to comply with the policy.
6. An invitation to participate in Augusta Richmond County's policy of affirmative action will be
disseminated to each applicant following the time that Augusta-Richmond County has extended
a job offer, but prior to the applicant's first day of employment.
7. For any Augusta-Richmond County sites subject to a collective bargaining agreement, union
officials will be notified of this AAP.
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DEVELOPMENT AND EXECUTION OF AFFIRMATIVE ACTION PROGRAMS
In addition to the affirmative action programs previously mentioned, Augusta-Richmond County is
developing and executing the following programs:
1. Augusta-Richmond County will continue to review all physical or mental job qualifications.
2. Augusta-Richmond County will continue to review and evaluate its entire personnel selection
process, including training and promotion, to ascertain whether the process permits the
stereotyping of individuals with disabilities or Covered Veterans in a manner that limits their
access to jobs for which they are qualified.
3. All personnel involved in the recruitment, screening, selection, promotion, disciplinary, and
related processes will be trained on affirmative action for individuals with disabilities and
Covered Veterans.
4. If Augusta Richmond County holds briefing sessions for recruitment sources, representatives
from agencies who specialize in individuals with disabilities and Covered Veterans will be
included. Formal arrangements will be made for the referral of job applicants, for follow-up, and
for feedback on the disposition of applicants referred.
5. Arrangements will be made to provide opportunities for employees with disabilities and Covered
Veterans to discuss any performance problems with their supervisors, and any need for
accommodation with their supervisors or the Human Resources Department.
6. To the extent that Augusta Richmond County makes employees available for participation in
community activities, employees who are individuals with disabilities or Covered Veterans will
be among those who are encouraged to participate.
7. To the extent that Augusta Richmond County conducts recruiting efforts at various schools,
special efforts will be made to reach students with disabilities and Covered Veterans.
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INTERNAL REVIEW PROCEDURE
Augusta-Richmond County has developed an internal review procedure whereby individuals with
disabilities and Covered Veteran employees can raise any issues or claims that may arise during the
course of their employment. General communications procedures encourage any and all employees,
including those with disabilities or who are Covered Veterans, to discuss such issues or claims. All
matters brought to the attention ofthe Human Resources Department or EEO Office will be
confidentially addressed.
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MONITORING AND REPORTING SYSTEMS
41 C.F.R. 60-741.44(h), 41 C.F.R. 60-250.44(h). 300.44(h)
It is the responsibility of Augusta-Richmond County's EEO Office, in conjunction with the Augusta Law
Department, to monitor all employment and personnel practices to ensure compliance with applicable
laws and regulations and adherence to Augusta-Richmond County's Statement of Policy, to report
specific problems to the appropriate management personnel, and to measure the effectiveness of
Augusta Richmond County's AAP.
Augusta-Richmond County's audit and reporting system is designed to:
o Measure the effectiveness ofthe AAP;
o Identify any need for remedial action;
o Determine the degree to which Augusta-Richmond County's objectives are being attained;
o Determine whether individuals with known disabilities or Covered Veterans have had the full
opportunity to participate in all Augusta-Richmond County sponsored educational, training,
recreational and social activities;
o Measure Augusta-Richmond County's compliance with the AAP's specific obligations.
To ensure that the audit system is effective, all records concerning applicants who are individuals with
disabilities or Covered Veterans will be maintained for two years, and all personnel actions involving
these employees will be individually maintained as a part of their personnel files.
Special reports summarizing affirmative action efforts to assist covered employees, descriptions of any
formal complaints, etc. will be provided to the Augusta-Richmond County Commission and Department
Directors at least annually. This AAP will be updated annually and will include a summary ofthe
previous year's actions and programs.
21
HARASSMENT
41 C.F.R. 60-741.44(e), 41 C.F.R. 60-250.44(e), -300.44(e)
Augusta Richmond County has developed and implemented procedures to ensure that employees who
are individuals with disabilities or Covered Veterans are not harassed because of their disability or
veteran status.
A copy of Augusta-Richmond County's Equal Employment Opportunity Policy forbidding harassment
against individuals based on protected characteristics is included in the Exhibits section.
22
TRAINING
41 C.F.R. 60-741.44(j), 41 C.F.R. 60-250.44(j), -300.44(j)
Augusta-Richmond County trains all personnel involved in the recruitment, screening, selection,
promotion, disciplinary, and related processes to ensure that the commitments in Augusta-Richmond
County's AAP are implemented.
23
LISTING OF EXHIBITS
Exhibit A - Post-Offer/Pre-Employment Invitation for Individuals with Disabilities and Covered
Veterans
Exhibit B - Harassment Policy
24
EXHIBIT A
AFFIRMATIVE ACTION PROGRAM
WORKERS WIlli DISABILITIES, SPECIAL DISABLED VETERANS, DISABLED VETERANS, VIETNAM ERA
VETERANS, ARMED FORCES SERVICE MEDAL VETERANS, OTHER PROTECTED VETERANS, AND ONE-
OR TIIREE- YEAR RECENTLY SEP ARA TED VETERANS
As a government contractor, Augusta Richmond County is subject to the Rehabilitation Act of 1973 (Section 503), and
Section 402 ofthe Vietnam Era Veterans Readjustment Act of 1974 (VEVRAA) as amended by the 2002 Jobs for
Veterans Act, which require government contractors to take affIrmative action to employ and advance in employment,
qualifIed persons with disabilities, qualifIed Vietnam veterans, and other qualifIed eligible veterans covered by
VEVRAA as defIned below. If you are a qualifIed person with a disability or a veteran covered by VEVRAA,
Augusta-Richmond County invites you to participate in our affIrmative action program. If you would like to be
included under the affIrmative action program, please notify Augusta-Richmond County. You may inform Augusta-
Richmond County of your desire to benefIt under this program at this time and/or at any time in the future. Augusta
Richmond County's affIrmative action program describes Augusta-Richmond County's commitment to undertaking
affirmative action to recruit, place and advance in employment covered veterans and qualifIed individuals with
disabilities. The affIrmative action program is available to all employees for review during regular business hours.
Submission of this information is voluntary and your decision not to provide it will not affect the consideration you are
being given for employment nor will participation subject you to any adverse treatment. The information you provide
will be kept confIdential as far as practicable and in accordance with the law, and will be used to assist in providing
reasonable accommodation and for statistical reporting as required by government agencies. In particular, the
following may have access to the information you provide: (i) supervisors and managers may be informed regarding
restrictions on the work or duties of disabled persons, and regarding necessary accommodations, (ii) fIrst aid and safety
personnel may be informed, when and to the extent appropriate, if the condition might require emergency treatment,
and (iii) Government offIcials engaged in enforcing the Americans with Disabilities Act or laws administered by the
OffIce of Federal Contract Compliance Programs, may be informed. The information shall not be used in a manner
inconsistent with VEVRAA or Section 503.
If you are disabled, it would assist us if you tell us about:
(i) Any special methods, skills, and procedures which qualify you for positions that you might not otherwise be able to
do because of your disability, so that you will be considered for any positions ofthat kind.
(ii) Any accommodations which we could make which would enable you to perform the job properly and safely,
including special equipment, changes in the physical layout of the job, elimination of certain duties relating to the job,
provision of personal assistance services or other accommodations.
I voluntarily identify myself as:
[ ] An Individual with a Disability - An "individual with a disability" is defmed as a person who (1) has a physical or
mental impairment which substantially limits one or more of his or her major life activities, (2) has a record of such
impairment, or (3) is regarded as having such an impairment.
[ ] A Special Disabled Veteran - A "special disabled veteran" is defIned to be a veteran who is entitled to disability
compensation (or who but for the receipt of military retired pay would be entitled to compensation) under laws
administered by the Veterans Administration for a disability (i) rated at 30 percent or more, (ii) rated at 10 or 20
25
percent in the case of a veteran who has been determined under section 1506 to have a serious employment disability,
or (iii) a person who was discharged or released from active duty because of a service-oriented disability.
[ ] A Disabled Veteran - A "disabled veteran" is (1) A veteran of the U.S. military, ground, naval or air service who is
entitled to compensation (or who but for the receipt of military retired pay would be entitled to compensation) under
laws administered by the Secretary of Veterans Affairs, or (2) A person who was discharged or released from active
duty because of a service-connected disability.
[ ] A Veteran ofthe Vietnam Era - A "veteran of the Vietnam Era" is defmed as a person who (1) served on active
duty for a period of more than 180 days during the Vietnam Era and who was discharged or released therefrom with
other than a dishonorable discharge, or (2) was discharged or released from active duty for a service-connected
disability if any part of his or her active duty was performed during the Vietnam Era. The "Vietnam Era" is defmed as
(i) any active duty occurring between August 5, 1964 and May 7, 1975 or, (ii) any active duty part of which occurred in
the Republic of Vietnam between February 28, 1961, and May 7, 1975.
[ ] An Armed Forces Service Medal Veteran - An "Armed Forces Service Medal veteran" is any veteran who, while
serving on active duty in the U.S. military, ground, naval or air service, participated in a United States military
operation for which an Armed Forces service medal was awarded pursuant to Executive Order 12985.
[ ] An Other Protected Veteran - An "other protected veteran" is a veteran who served on active duty in the U.S.
military, ground, naval or air service during a war or in a campaign or expedition for which a campaign badge has been
authorized, under the laws administered by the Department of Defense.
[ ] Recently Separated Veteran - One Year - A "Recently separated veteran - one year" is defmed as any veteran
during the one-year period beginning on the date of the veteran's discharge or release from active duty.
[ ] Recently Separated Veteran - Three Years - A "Recently separated veteran - three years" means any veteran
during the three-year period beginning on the date of such veteran's discharge or release from active duty in the U.S.
military, ground, naval or air service.
Please provide your date of discharge or release from active duty:
A complete list of qualifying military engagements is available online at
http://www.opm.gov/veterans/html/vgmeda12.htm.
Signature:
Date:
Print Name:
Employee #:
26
EXHIBIT B - HARASSMENT POLICY
Harassment is verbal, physical or visual conduct of a sexual, racial, ethnic or other nature which, impairs
his or her ability to perform the job, or creates an offensive or hostile work environment. Harassment is
contrary to basic standards of conduct between individuals.
Augusta Richmond County will not condone or tolerate the harassment of its employees by their
coworkers, supervisors or any individuals under our control. All employees, regardless of position or
title, will be subject to severe discipline, up to and including termination of employment, should
Augusta-Richmond County determine that an employee is engaged in the unlawful harassment of
another employee. Augusta-Richmond County will promptly and thoroughly investigate the facts and
circumstances of any claim of harassment.
If you feel that you are being subjected to harassment, you should report this matter directly to your
supervisor immediately, or, if you would prefer to discuss the matter with someone else, report the issue
to the supervisor's superior or to another manager of Augusta-Richmond County. No one will be
subject to, and Augusta-Richmond County prohibits, any form of discipline or retaliation for reporting
incidents of unlawful harassment or pursuing any such claim of harassment.
27
AFFIRMA TIVE ACTION PLAN
FOR MINORITIES & WOMEN
Equal Employment Opportunity (EEO) Office
Augusta-Richmond County Government
January 1, 2008 - December 31, 2008
The Mayor, Augusta-Richmond County Commission and the City Administrator
Diana Darris, M JPS
EEO Coordinator
Designated Affirmative Action Plan Manager
Note: The data and information contained in this Affirmative Action Plan (AAP) is limited to the
information located in the IFAS database of Augusta-Richmond County.
TABLE OF CONTENTS
Preface. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . .. . .. . .. . . . . .. . . . . .. . .. . . . . . . . .. . .. . . . . .. . . . . . . . .. . . . . .. . . . . .. . .. . . . . .. . . . . .. . .3
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . .. . .. . . . . .. . . . . . . . . . . . . . .. . . . . . . . .. . .. . . . . . . . . . . . . . .. . . . . . . . . . . .5
Responsibility for Implementation........ ...... .......... ........... .... .............. ......... .... ......... .......6
Organizational Profile. . ..... . .. ......... .... .. . .. . .. . ... .. . .. . ..... ... ...... . ........ . .. . .. . .. ... . ..... . ... .. . .. . ... ..8
Job Group Analysis...... ........ ............ .............. ............ .... ......... ......... ............... ...........9
Availability Analysis............................................................................................. .....1 0
Comparison of Incumbency and Availability.. ............ ......... ........ ......... ....... ........ ....... ... ... .11
Placement Goals.... . .. '" . .. . .. . .. . .. . ..... . .. . .. . . . . .. ... . . . . .. . ..... . .. . .. . .. ... . .. . ... .... . . .. .... ........ ... . .. . . .12
Identification of Problem Areas.................................................................................... .13
Development and Implementation of Action Oriented Programs........................................... ...18
Internal Audit & Reporting System........ ........ ........ ..... .... ............... ........... .... ............... ...21
Conclusion. . .. . .. . .. ... . ... ..... ... . . . . .. . ..... . .. ... . .. . ... .. . .. . . . . .. ...... . .. . ... .. . ... ... .. . .. . .. . ........ . .. . .. . . .22
Exhibits
2
PREFACE
The Augusta-Richmond County Government and its internal Equal Employment Opportunity (EEO)
Office (also referred to as the EEO Office) are fully committed to the concept and practice of equal
opportunity and affirmative action in all aspects of employment.
In the preparation of this Affirmative Action Plan (AAP), the EEO Office has used the terminology
found in Federal Executive Order (E.O.) 11246 and the implementing regulations as a guide. The use of
such terms as "underutilization," "deficiency," "concentration," "affected class," "goal," "problem area,"
etc. are intended to have the same meaning as defined in E.O. 11246, unless otherwise indicated. The
use of these and similar terms are not to be construed as an admission by Augusta-Richmond County, in
whole or in part, that either minorities or women have been or are presently being underutilized,
concentrated, or discriminated against in any way by Augusta-Richmond County in violation of federal,
state, or local employment laws or regulations. Furthermore, nothing contained in this AAP or its
supporting data should be construed as an admission, in whole or in part, that Augusta-Richmond
County has contravened any federal, state, or local employment laws or regulations.
In developing and implementing this AAP, the EEO Office has relied on its established policy of
providing equal employment opportunity. Any placement goals established herein are not intended as
rigid, inflexible quotas that must be met, but rather as targets reasonably attainable by applying every
good faith effort in implementing this AAP. The use of placement goals in this AAP is not intended to
have the effect of discriminating against any individual or group of individuals with respect to any
employment opportunities for which such individual or group of individuals are qualified on the grounds
that such individual or group of individuals are not the direct beneficiaries of affirmative action.
Nothing herein is intended to sanction the discriminatory treatment of any person or group. Indeed, all
employment decisions are to be made based on job-related criteria. This AAP has been developed in
strict compliance with the Guidelines on Affirmative Action issued by the Equal Employment
Opportunity Commission (EEOC) (29 C.F .R. Part 1608).
While Augusta-Richmond County firmly believes in wide dissemination of its affirmative action
policies and equal employment opportunity practices, certain data generated in accordance with this
AAP contains private data and proprietary information relating to the organization's business that is
subject to protection.
This AAP and its support data are to be disclosed with the following requirements:
1. Information submitted to the Office of Federal Contract Compliance Programs (OFCCP)
pursuant to (E.O.) 11246 and the implementing regulations, it is to be considered confidential
and not subject to public disclosure by the OFCCP without notifying Augusta-Richmond County
of the agency's decision to disclose and providing Augusta-Richmond County with ample time to
contest the disclosure.
2. If this information is supplied to another government contractor, EEOC representative, or any
other person who is given access to the AAP, it is not to be copied, reproduced, or disclosed
without prior notification to Augusta-Richmond County.
3. Subject to the limitations contained herein, this AAP shall be accessible for open review by
Augusta- Richmond County employees and the public and shall be posted in conspicuous places
at Augusta-Richmond County.
3
4. All monitoring system reports as required by federal regulations and laws shall be completed and
submitted to authorities as required. Reports that require specific data such as names of
employees and salary information are not an official part ofthis AAP. This information is on file
at Augusta-Richmond County as documentation and supporting data for AAP Reports and is
available for review only as required by law.
The material supporting this AAP may include personnel file data, investigatory records, statistical data
and other information which may, in part, be confidential in nature according to HIPPA, the Freedom of
Information Act (5 U.S.c. Section 552) and Title VII ofthe Civil Rights Act of 1964 (as amended) (42
U.S.C. Sections 2000e et seq.). The disclosure of such records is prohibited by law.
The overall plan covers all departments under the jurisdiction of the Augusta-Richmond County
Government including, but not limited to: the Augusta Utilities Department, the Augusta Regional
Airport, the Augusta Transit Department and the Augusta Housing and Economic Development
Department. Augusta-Richmond County maintains data and monitoring systems for its departments and
the organization as a whole.
This AAP does not constitute an express or implied contract between Augusta-Richmond County and its
employees, job applicants, or other persons. Nothing in this AAP provides any individual or group with
a private right of action against Augusta-Richmond County or any of its officers, employees or agents.
4
INTRODUCTION
Ever committed to equal employment opportunities, the EEO Office has prepared this AAP to cover
employees working within the Augusta-Richmond County organization under the specific jurisdiction of
the Mayor and the Augusta-Richmond County Commission.
As detailed in the Job Group Analysis, this AAP covers approximately 2,837 employees including
approximately 1,357 (47.83%) minorities and 1,001 (35.28%) women. These employees help Augusta-
Richmond County work toward mutual goals of profitability and efficiency, resulting in both business
and personal growth. As described in detail in the Plan that follows, Augusta-Richmond County and its
internal EEO Office has a continuing commitment to the practice and implemented action ofthis AAP.
5
RESPONSIBILITY FOR IMPLEMENTATION
In accordance with 41 C.F.R. 60-2.17
The EEO Office has the overall responsibility for implementing the Equal Employment Opportunity
Policy and the AAP. The Augusta-Richmond County Commission has assigned primary management
responsibility and accountability for ensuring full compliance with the plan to the Coordinator of the
internal Augusta-Richmond County EEO Office. The EEO Coordinator has the authority to coordinate
with Augusta-Richmond County officers and Department Directors and obtain their support and
resources as necessary to ensure implementation and compliance with this AAP. The EEO Office, the
Mayor and the Commission endorse this AAP program and are authorized to provide assistance
whenever it is needed to make managers and supervisors aware of the program and ensure their
cooperation and assistance. The name of the EEO Coordinator should appear on internal and external
communications on the organization's Equal Employment Opportunity Policy and AAP.
1. The duties of the EEO Coordinator as related to this AAP include:
A. Developing policy statements, AAP methods, and internal and external communication
techniques. Affirmative action policies and procedures will continue to be developed to
ensure efficient implementation of this AAP.
B. Assisting in the identification of problem areas, and developing strategies to eliminate
any problems identified.
C. Assisting line management and supervisors in devising solutions to equal employment
problems, including counseling and training, to ensure full understanding of this plan and
its implementation.
D. Designing and implementing monitoring and reporting methods that will:
. Measure the effectiveness of the organization's AAP.
. Indicate any need for remedial action with regard to the AAP.
. Determine the degree to which the organization's placement goals and objectives
are being attained.
. Provide officers and employees with a working understanding of the
organization's AAP placement goals and objectives.
E. Meeting with managers, supervisors, and employees to assure that the organization's
AAP is being followed.
F. Working in collaboration with administration to ensure that supervisors understand the
importance of the AAP. Supervisors should be encouraged to demonstrated commitment
to equal employment opportunity and take responsibility to prevent all types of unlawful
workplace harassment.
6
G. Serving as a liaison between enforcement agencies. I
H. Making contact with and serving as a liaison between appropriate minority and women's
organizations, schools and colleges and community action groups concerned with
employment opportunities for minorities and women.
I. Keeping officers and employees informed of developments in the equal employment
opportunity and affirmative action area.
J. Conducting periodic internal assessments to ensure that Augusta-Richmond County
complies in the following ways:
1. AAP material is properly displayed.
2~ All employees are afforded the opportunity and are encouraged to participate in
all EEO Office sponsored educational and training activities in the workplace.
2. The EEO Office recognizes that the cooperation of department supervisors and managers is
required to reach the full potential of this AAP. Therefore, supervisors and managers are
expected to:
A. Assist the EEO Coordinator in the identification of any problem areas and help to
eliminate any barriers to equal employment opportunity.
B. Whenever possible, become involved in local minority organizations, women's
organizations, community action groups, and community service programs.
c. Work with the EEO Coordinator to periodically review hiring, promotion patterns, and
training programs in order to isolate impediments to the attainment of affirmative action
placement goals and objectives. The results from these reviews will be communicated
through appropriate means to the Human Resources Department, Department Directors
and other management.
D. Review the qualifications of employees to ensure that minorities and women are given
full opportunity for transfers and promotions.
E. In conjunction with Human Resources, provide career counseling for employees as
needed.
F. Adhere to the organization's policy of equal employment opportunity for all employees
and ensure that the policy is understood, supported and adhered to by the employees they
supervIse.
G. Take action to prevent the harassment of employees based on protected characteristics or
participation in this AAP.
1 In the event of any conflict or legal dispute arising out of or relating to this AAP, nothing in this section is intended to
preclude Augusta-Richmond County's legal representatives from communicating with enforcement agencies or any person or
organization challenging any aspect ofthis AAP.
7
ORGANIZATIONAL PROFILE
In accordance with 41 C.F.R. 60-2.11
As one ofthe diagnostic components of the Augusta-Richmond County's AAP and to conform to
applicable regulations, the EEO Office has completed a profile ofthe Augusta-Richmond County
workforce. The organizational profile is an overview ofthe staffing patterns at Augusta-Richmond
County and is used to determine whether there are areas in the workforce where minorities or women
are underrepresented or concentrated. To complete our organizational profile we have elected to follow
the organizational display methodology.
THE ORGANIZATIONAL DISPLAY:
The following chart sets forth our Organizational Display. For each Department Code, we provide the
following data: the total number of male and female incumbents, and the total number of minorities.
Racial/ethnic groups (as determined and defined by the Federal Government Guidelines) are: Black,
Hispanic, Asian/Pacific Islander, and American Indian! Alaskan Native.
8
JOB GROUP ANALYSIS
In accordance with 41 c.F.R. 60-2.12
As a second diagnostic component of our AAP, we have conducted ajob group analysis. The job group
analysis is the first step in comparing the representation of minorities and women in the workforce
covered by this AAP with the estimate of the available qualified minorities and women who could be
employed in positions covered by this AAP.
In designing these job groups, the following elements were considered:
. Similarity of duties and responsibilities;
. Similarity of compensation; and
. Similarity of opportunities for advancement including training, transfers, promotions,
mobility and other career enhancements.
Although not a determinative factor in designing job groups, there was an attempt to create job groups
that are large enough to conduct appropriate analysis.
The following charts identify the job groups created for this AAP, the job titles that comprise each job
group, the percentage of minority incumbents and the percentage of female incumbents in each job
group.
9
AVAILABILITY ANALYSIS
In accordance with 41 C.F.R. 60-2.14
The availability analysis is a part ofthe Incumbency vs. Estimated Availability Analysis which is the
final diagnostic component of this AAP. The purpose of the availability analysis is to establish a
benchmark against which the demographic composition of our organization's workforce may be
compared to determine whether barriers to equal employment opportunity may exist within particular
job groups.
Pursuant to applicable regulations, the availability analysis for each job group examines two potential
areas of availability: individuals with the requisite skills outside the establishment (external availability)
and those within the establishment who are promotable, transferable and/or trainable (internal
availability). In determining availability, we have selected our reasonable recruitment area and our pool
of promotable, transferable, and trainable employees in such a way as not to exclude qualified minorities
and women. Moreover, when determining external availability the EEO Office has used, as the source
of data, the most current and discrete statistical information available. For this availability analysis, the
EEO Office has used the 2000 census data. Finally, where a job group is composed of different job
titles that carry different availability rates, the EEO Office calculated a composite availability figure.
The EEO Office arrived at the composite availability figure by determining the proportion ofthe job
group incumbents employed in each job title, weighting the availability for each job title by the
proportion of incumbents employed in that title, and adding together the weighted availability estimates.
A brief overview for the selection of the recruitment areas established by the EEO Office and internal
pools by job group follows:
EEO Office Recruitment Area Breakdown:
Richmond County - 50%
Atlanta GA - 20%
Savannah GA - 10%
Macon GA - 10%
Columbus GA - 10%
10
COMPARISON OF INCUMBENCY AND AVAILABILITY
In accordance with 41 c.F.R. 60-2.15
The EEO Office has compared the representation of minorities and women in each job group with their
representation among those identified in the availability analysis as available for employment in the job
group. Where actual representation was less than the calculated availability, the EEO Office conducted
a statistical test to determine whether the difference was greater than could reasonably be expected. The
comparison of availability with actual representation is reflected in the following chart.
11
PLACEMENT GOALS
In accordance with 41 C.F.R. 60-2.16
As required by applicable federal regulations (41 C.F .R. 60-2.16), the EEO Office has established
placement goals where the actual representation of women or minorities in ajob group is less than
would be reasonably expected based on calculated availability. No set asides or quotas will be
implemented or permitted.
In establishing placement goals (in accordance with 41 C.F.R. 60-2.16), we applied the following
principles:
1. When the percentage of minorities or women employed in a particular job group is less
than would reasonably be expected given their availability percentage in that job group,
the EEO Office established a percentage annual placement goal at least equal to the
availability figure derived for women or minorities, as appropriate, for that job group.
2. Placement goals are permitted under Federal Law (41 C.F.R. 60-2.16). These goals are
not quotas that must be met, nor are they to be considered as either a ceiling or a floor for
the employment of particular groups.
3. In all employment decisions, the Augusta-Richmond County organization and all of its
departments makes selections in a nondiscriminatory manner. Placement goals do not
provide a justification to extend a preference to any individual, select an individual, or
adversely affect an individual's employment status, on the basis of that individual's race,
color, religion, sex, age, disability, veteran's status, or national origin. Placement goals
are used to promote organizational diversity.
4. Placement goals do not create set-asides for specific groups, nor are they intended to
achieve proportional representation or equal results.
5. Placement goals are not used to supersede merit selection principles, nor do these
placement goals require Augusta-Richmond County or any of its departments to hire a
person who lacks the qualifications to perform the job successfully. Placement goals do
not require Augusta-Richmond County or any of its departments to hire a less-qualified
person in preference to a more-qualified one.
6. The placement goals established in this AAP may reflect the permissible preference for
American Indians living on or near an Indian reservation as permitted under Federal
Guidelines. However, since there are no American Indian Reservations in Augusta-
Georgia or Richmond County, this is not an issue which our organization anticipates
encountering.
As is described in more detail in the Action Oriented Program section of this AAP, where a placement
goal is set (as authorized under Federal Regulation 41 C.F.R. 60-2.16), the Augusta-Richmond County
HR Department and the EEO Office will develop action-oriented steps to increase the recruitment and
training of minorities and/or women.
12
IDENTIFICATION OF PROBLEM AREAS BY
ORGANIZATIONAL UNIT AND JOB GROUP
In accordance with 41 C.F.R. 60-2.17(b)
The EEO Office has conducted in-depth analyses of Augusta-Richmond County's total employment
process, including the workforce by organizational unit and job group, personnel activity, compensation,
and other personnel procedures to determine whether and where impediments to equal employment
opportunity exist.
An analysis of each of these processes follows.
I. Composition of the Overall Workforce by Organizational Unit Based on Data Provided in the
Augusta-Richmond County IF AS Database.
The EEO Office analysis by organizational unit reveals that minorities and women are not
significantly underrepresented or concentrated in any particular organizational unit.
Minorities are employed at a rate of 47.83% and are represented in 85.61 % ofthe
organization's departments. Further, minorities are represented in 100% ofthe departments
that employ 10 or more people. Women are employed at a rate of35.28% and are
represented in 87.05% of all departments, and 96.61% of all departments that employ 10 or
more people. This analysis suggests that there is no overall formal policy or practice
excluding minorities or women, nor is there any overall racial or sexual discrimination
indicated in the selection process.
2. Composition of the Workforce by Job Group
Pursuant to the Office of Federal Contract Compliance Programs' (OFCCP) regulations, the
EEO Office has conducted an availability analysis by job group, taking into account both
external and internal availability, and have compared incumbency to estimated availability to
determine placement goals. The descriptions of Factor 1 and Factor 2 by job group are
summarized in the Availability Analysis. Our findings are as follows:
The EEO Ofice analysis of incumbency vs. estimated availability indicates that in some
cases, incumbency is less than estimated availability; however, our more detailed analysis
concludes that there is no significant problem concerning overall minority utilization.
As opposed to quotas, Augusta-Richmond County will established affirmative action
placement goals and programs to address underutilization, and will continue to make a good
faith effort to reach the placement goals established and implement action-oriented programs,
which are detailed elsewhere in this AAP.
3. Analysis of Progress Towards Yearly Placement Goals
In establishing placement goals, the following principles apply:
A. When the percentage of minorities or women employed in a particular job group is less than
would reasonably be expected given their availability percentage in that job group, Augusta-
Richmond County has established an annual percentage placement goal at least equal to the
13
availability figure derived for women or minorities, as appropriate, for that job group.
B. Placement goals are not quotas that must be met, nor are they to be considered as either a
ceiling or a floor for the employment of particular groups.
C. In all employment decisions, Augusta-Richmond County makes selections in a
nondiscriminatory manner. Placement goals do not provide a justification to extend a
preference to any individual, select an individual, or adversely affect an individual's
employment status, on the basis of that individual's race, color, religion, sex, age, disability,
veteran status, or national origin.
D. Placement goals do not create set-asides for specific groups, nor are they intended to achieve
proportional representation or equal results.
E. Placement goals are not used to supersede merit selection principles, nor do these placement
goals require Augusta-Richmond County to hire a person who lacks qualifications to perform
the job successfully or hire a less-qualified person in preference to a more-qualified one.
A review of progress and goal attainment by job group reveals the following areas of significant success
for minorities and women:
4. Personnel Activity
The EEO Office has analyzed additional personnel activities to determine whether and where
impediments to equal employment opportunity exist and whether there are significant selection
disparities by race/ethnicity or gender. These activities include applicant flow, hires,
promotions, terminations, and other personnel actions.
A. Applicant Flow
During the plan year, January 1,2008 - December 31, 2008, the Human Resources
Department will post the majority of all open positions with the State Employment
Service. The Human Resources Department will accept applications for open positions,
and all persons interested in obtaining employment with Augusta-Richmond County were
advised to apply according to our current policy. Applications and complete records will
be kept by the Human Resources Department to ensure goals of equal employment
opportunity are being applied to this process.
Augusta-Richmond County believes that applicant flow is not and will not be a problem
area. Our analysis reveals that the percentage of minority applicants compares very
favorably with the general availability in the respective categories. Clearly Augusta-
Richmond County's success in implementing and communicating affirmative action and
outreach efforts is demonstrated by the statistics included in this AAP.
The following reports summarize applicant flow by job group. Please note that
applicants with an identified gender but no race will be included in the Applicant Detail
by Gender and applicants with an identified race but no gender will be included in the
Applicant Detail by Race.
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B. Hires
For the sake of organizational consistency, the Human Resources Department, in
collaboration with the EEO Office, develops all procedures to ensure that all hiring is
conducted on the basis of nondiscriminatory criteria. The EEO Office is to work
collaboratively with the Human Resources Department in relation to needed adjustments.
Specifically, the following criteria and procedures have resulted in hiring decisions that
are free of discrimination:
1. Job descriptions have been reviewed and revised to ensure that duties are
accurately described, that the experience and education requirements are strictly
job-related, and that all incumbents meet minimum job requirements. Job titles
have and will continue to be written without regard to race, color, religion, sex,
age, disability, veteran status, national origin, or any other characteristic protected
by applicable law.
2. Application forms have been reviewed to ensure that all requested information is
job-related, and that the forms comply with all applicable laws. In addition, all
forms state that Augusta-Richmond County is an Equal Opportunity/Affirmative
Action Employer.
3. An representative knowledgeable of Equal Employment Opportunity/Affirmative
Action oversees employment interviews.
4. Tests have been reviewed and are administered and conducted in a non-
discriminatory manner.
5. All employees are encouraged to refer qualified applicants to Augusta-Richmond
County for employment. In addition, Human Resources has formal recruitment
procedures to apprise minority and women's groups, educational institutions, and
other referral sources of openings.
6. Placing an applicant in a specific job in a department is the responsibility of
management. Hiring decisions are based on the applicant's knowledge, skills,
abilities, and any other job-related criteria. However, an applicant's qualifications
should not be arbitrarily waived merely in favor of one specific individual. All
qualified persons should be afforded an equal opportunity to gain employment.
A review of external hires for the prior plan year indicates the presence of equal
employment opportunity and a strong commitment to affirmative action. There were
approximately 376 new employees hired during the period from January 1, 2007 -
December 31,2007, including 216 minorities at 57.45% and 141 women at 37.5%.
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C. Promotion Practices
A review of promotion data indicates that these practices represent an area of
employment opportunity for minority and female employees. The overall promotion
practices are not problem areas for minorities and women in any job group. Our analysis
reveals that neither minorities nor women are being treated disparately in promotions
because:
1. Augusta-Richmond County provides every reasonable opportunity for employees
to advance. In this regard, training and other developmental opportunities are
offered.
2. Employees are encouraged to contact their supervisor and/or the Human
Resources Department, at any time, should they desire information relative to
another position within Augusta-Richmond County.
3. Management-initiated promotions are based on performance and other job-related
criteria without discrimination on account of race, color, religion, sex, age,
disability, veteran status, national origin, or any other characteristic protected by
applicable law.
4. Most promotional opportunities are posted, providing all interested employees
with an opportunity to apply and call their special skills to the attention ofthe
manager.
5. Our program of career development enables all employees to designate career
paths and positions for which they wish to be considered.
All ofthese factors strongly indicate that overall promotions represent an area of employment
opportunity for minority and female employees.
D. Compensation Systems
As part of its affirmative action obligations, Augusta-Richmond County has conducted a
compensation analysis to determine whether there are pay disparities on the basis of
gender, race, or ethnicity. If the organization discovers significant salary differences
between men and women or non-minorities and minorities, it will determine whether they
are the result of legitimate, nondiscriminatory factors such as tenure, time in job, time in
grade, performance, education, previous experience, etc. Where appropriate, Augusta-
Richmond County will take all reasonable and immediate steps to make any necessary
adjustments.
E. Terminations
Augusta-Richmond County has evaluated its termination practices to determine whether
there are disparities on the basis of gender, race or ethnicity. When terminations or
reductions in force are necessary, Augusta-Richmond County will make its decisions
without regard to race, color, religion, sex, age, disability, veteran status, national origin,
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or any other characteristic protected by applicable law.
5. Technical Phases of Compliance
Analysis of the technical phases of compliance reveals that Augusta-Richmond County fully
complies with all the technical phases of its affirmative action obligations:
A. Equal Employment Opportunity posters are prominently displayed in each location.
B. Augusta-Richmond County notifies all contractors and subcontractors via purchase orders
and subcontracts that they may be subject to federal affirmative action obligations.
C. Augusta-Richmond Country requires that all of their qualified contractors and subcontractors
develop and maintain a written AAP.
D. Augusta-Richmond County's employment application has a statement concerning Equal
Employment Opportunity.
E. All recruitment agencies and area schools and colleges will continue to be notified of the
organization's commitment to the goals of affirmative action.
F. All recruitment advertising includes the solicitation "An Equal Opportunity Employer" or its
abbreviation.
G. All other required affirmative action notices and policy statements are posted on bulletin
boards and are updated annually.
H. All personnel and employment records made or kept by Human Resources are retained for
the required period as mandated by OFCCP regulations.
I. Augusta-Richmond County files annual EEO-4 and VETS-I00 reports with the appropriate
agencIes.
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DEVELOPMENT AND IMPLEMENTATION
OF ACTION ORIENTED PROGRAMS
In accordance with 41 C.F.R. 60-2.17
Augusta-Richmond County has developed and executed action-oriented programs designed to correct
any problem areas that may exist. These programs, which are listed below, demonstrate our good faith
efforts to remove identified barriers, expand employment opportunities, and produce measurable results.
1. Augusta-Richmond County has analyzed and will continue to analyze all positions and prepare
written descriptions to accurately reflect position functions. Due to the use of a position
description format, they are and will continue to be consistent for the same position from one
organizational unit to another.
2. Job descriptions have been and will continue to be reviewed to determine the knowledge, skills,
abilities, and other requirements necessary for the adequate performance of every job.
Specifications will continue to be consistent for the same job title in all organizational units and
will not contain any requirements that would result in discrimination on the basis of race, color,
religion, sex, age, disability, veteran status, national origin, or other characteristic protected by
law.
3. Job descriptions are available to incumbents and all members of management involved in the
recruiting, screening, selection, and promotion process. Job descriptions are also made available
to employees, applicants, and recruiting sources as appropriate.
4. Augusta-Richmond County has carefully evaluated the total selection process and found it to be
free from discrimination.
A. Augusta-Richmond County has instructed all supervisory personnel to ensure elimination
of discrimination in all personnel actions in which they are involved.
B. The tests administered by Augusta-Richmond County are job-related and given to all
applicants for applicable position.
C. Application forms do not contain questions with potential discriminatory effects.
D. Augusta-Richmond County does not and will not use any selection techniques that can be
improperly used to discriminate against minority groups or women.
5. The Human Resources Department in collaboration with the EEO Office has evaluated its
techniques for improving recruitment and increasing the flow of qualified minority or female
applicants through the following:
A. Minority and women, as well as non-minority and male, employees are actively
encouraged to refer applicants to our organization.
B. Augusta-Richmond County relies on the State Department of Employment as well as job
fairs and recruiting programs sponsored by local community colleges and other
community organizations.
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C. The Human Resources Department provides an orientation program to inform new
employees oftheir equal employment responsibilities, promotional opportunities, rules,
ways to alleviate any problems that might arise, and any other issues related to
affirmative action compliance.
D. Local organizations will continue to be contacted for referrals of potential minority and
female employees.
E. Augusta-Richmond County utilizes the Internet to identify targeted recruitment sites for
qualified minority and female applicants.
F. Furthermore, Augusta-Richmond County plans to take the following additional steps to
ensure adequate representation of all minorities and women:
(a) Where placement goals exist as defined by the OFCCP, the Augusta-Richmond
County will continue to contact universities and two- and four-year local
colleges, vocational technical schools, high schools, local business schools, and
state and community organizations which attract qualified minority and female
students. Augusta-Richmond County will advise these institutions of its desire
to fill job openings in these classifications with minority and female employees.
When possible, Augusta-Richmond County will continue to participate injob
fair and career day activities and relevant work experience programs.
(b) During the period from January 1,2008 - December 31, 2008, special
recruitment activities will be conducted at the following schools, universities
and community organizations:
Paine College
Augusta State University
Augusta Technical College
Local high schools
Georgia Labor Department
Department of Veteran's Affairs
G. Augusta-Richmond County will continue to contact normal sources of recruitment (e.g.,
State Employment) and advise them that under the AAP it is specifically seeking to
employ minorities and/or women for job openings. During the AAP Plan period the
organization will conduct targeted recruitment activities.
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6. Augusta-Richmond County has implemented the following programs and procedures to ensure
that minority and female employees are given equal opportunities for promotion:
A. On-the-job training is provided to all qualified employees to assist them in developing the
necessary knowledge and skills for promotion to higher-level jobs. In addition, a tuition
reimbursement benefit is also available to all qualified employees.
B. Augusta-Richmond County utilizes a formal performance evaluation program for all
employees. In addition, management and supervisors are trained on the basic
methodology of performance evaluation.
C. Neither minority nor female employees are required to possess higher qualifications than
those of the lowest qualified incumbent in the job for which they apply.
D. Seniority practices are not a problem since Augusta-Richmond County has no formal
seniority system. Promotions are based on merit selection principles.
E. Augusta-Richmond County will continue to make opportunities for advancement into
more stimulating positions widely known through our career development process and by
encouraging minorities and women to take advantage of these opportunities.
F. Special internal training programs are provided as necessary to ensure the achievement of
our placement goals. The following programs are offered to eligible employees without
regard to race, color, religion, sex, age, disability, veteran status, national origin or any
other characteristic protected by applicable law:
G. Augusta-Richmond County will continue to participate in targeted external training
programs.
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INTERNAL AUDIT AND REPORTING SYSTEM
In accordance with 41 C.F.R. 60-2.17
Augusta-Richmond County has developed and implemented an auditing system that periodically
measures the effectiveness of its total AAP. Augusta-Richmond County views the activities that are
listed below as critical to the success of the AAP.
1. The EEO Office and the HR Department will continue to monitor records of applicant flow,
referrals, placements, rejected offers, training, transfers, promotions, terminations, and any
layoffs or recalls to ensure that Augusta-Richmond County's non-discriminatory policy is carried
out. Procedures are reviewed and revised as problems are identified.
2. Top management is and will continue to be informed of any problems that arise in their
respective areas so that immediate and appropriate steps can be taken to resolve any issues.
3. Augusta-Richmond County recognizes its responsibility to affirmative action and is committed
to fulfilling this responsibility by complying with all government regulations and laws pertaining
to equal employment opportunity. As part of this commitment, management will be kept abreast
of developments in the affirmative action area. The primary vehicle for communication with
management will be periodic affirmative action briefings.
4. Augusta-Richmond County will generate internal reports on a regular basis to evaluate the
degree to which equal employment opportunity and organizational objectives are being obtained.
5. Augusta-Richmond County will review report results with all levels of management as to the
degree to which their affirmative action goals and compliance are being attained, and will design
and implement corrective actions, including adjustments in programs, as needed.
6. Progress on Augusta-Richmond County's AAP will be discussed at supervisors meetings, and
relevant information will be communicated to employees during regular departmental meetings
as appropriate.
7. The EEO Coordinator will periodically report to the Mayor, the Commission and the City
Administrator of Augusta-Richmond County and other appropriate top management on the
effectiveness of the program and will submit recommendations for improvement.
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CONCLUSION
The AAP Year, January 1,2008 - December 31, 2008, shows a commitment to equal employment
opportunity and affirmative action, and has strong plans to ensure both organization and employee
success.
Through its EEO Coordinator, Augusta-Richmond County will continue to communicate its policies,
both within the organization and to the community in which we work. The Mayor, the Commission and
the City Administrator afford the EEO Coordinator full authority to implement this AAP plan and to
pursue solutions to problems that might impede the progress ofthis plan.
At the close ofthe Equal Employment Opportunity (EEO) Office's most recent Plan year, an analysis of
the composition ofthe workforce was undertaken. The workforce was analyzed by job group and by
department to determine the employment of minorities and women, and to identify if placement goals
are indicated when compared to the appropriate available workforce. This analysis revealed only two
(2) area(s) in which the difference between incumbencies versus estimated availability was statistically
significant, showing that for the overwhelming majority of the workforce, employment levels of women
and minorities are representative of our recruiting population. Nonetheless, Augusta-Richmond County
expects to continue its successful outreach efforts and to ensure that all applicants and employees are
treated fairly, based on job-related criteria and without regard to race, color, religion, sex, age, disability,
veteran status, national origin, or any other characteristic protected by applicable law.
Augusta-Richmond County is mindful of the fact that continued achievements in the area of equal
employment opportunity and affirmative action are important. As a result, Augusta-Richmond County
has included additional action-oriented plans and programs for recruiting, communication, and
reporting, to ensure that our compliance with affirmative action continues.
Finally, it should be noted that the EEO Office's analysis of its workforce reveals that Augusta-
Richmond County is in full compliance with sex discrimination guidelines and that there is no overall
evidence of discrimination against female employees. As outlined in this AAP, Augusta-Richmond
County is ready and willing to make affirmative action both a commitment and a continued reality for
Augusta-Richmond County.
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LIST OF EXHIBITS
Exhibit A - Policy of Affirmative Action Letter
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Exhibit A
Policy of Affirmative Action Letter
Dear Outreach and Placement Professional:
This letter is to inform you that Augusta-Richmond County is committed to the principles of equal
employment opportunity. Moreover, as a government entity and contractor bound by Executive Order
11246, Augusta-Richmond County takes its affirmative action obligations very seriously. Equal
Employment Opportunity (EEO) Office states as its Policy of Affirmative Action the following:
A. It will be the policy of Equal Employment Opportunity (EEO) Office to recruit, hire, train, and
promote persons in all job titles without regard to race, color, religion, sex, age, disability,
veteran status, national origin, or any other characteristic protected by applicable law.
B. All employment decisions shall be consistent with the principle of equal employment
opportunity, and only job-related qualifications will be required.
C. All personnel actions, such as compensation, benefits, transfers, tuition assistance, social and
recreational programs, etc. will be administered without regard to race, color, religion, sex, age,
disability, veteran status, national origin, or any other characteristic protected by applicable law.
To assure compliance with Augusta-Richmond County's AAP, the EEO Coordinator, has been
designated to administer and monitor the Affirmative Action Plan and make reports to Senior
Management. Members of our Human Resources Department and EEO Office will contact you when
positions are available. The EEO Office requests that you refer to us all qualified candidates, including
women and minorities.
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