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America’s Job Exchange 400 Minuteman Road, Andover, MA 01810 www.americasjobexchange.com 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

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Page 1: Developing an Effective OFCCP Compliance Program for Job … · 2011/11/9  · America’s Job Exchange 400 Minuteman Road, Andover, MA 01810 Developing an Effective OFCCP Compliance

America’s Job Exchange400 Minuteman Road, Andover, MA 01810

www.americasjobexchange.com

Developing an Effective OFCCP Compliance Programfor Job Posting and Distribution

14th Annual Compliance Conference - Phoenix, AZ - November 15, 2011

Rathin Sinha

President, America’s Job Exchange

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Agenda

Compliance Regulations

Contractor Obligations

Implementation Challenges

The Case for Third Party Vendors

The AJE Advantage

Q & A

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Executive Order 11246Prohibits Federal contractors from discriminating in employment decisions

based 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 and

promote individuals with disabilities.

Vietnam Era Veteran’s Readjustment Act, as amended in

conjunction with Jobs for Veterans Act (VEVRA/JVA)Requires Federal contractors to take affirmative action to hire, retain and

promote veterans.

The OFCCP mandates that companies doing business with the Federal government must

comply with the following set of regulations in their recruitment practices.

OFCCP Regulations – The Broad View

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Executive Order 11246Post job vacancy announcements to expose them to a large number of

minorities, women, and underrepresented groups.

Section 503 of the Rehabilitation Act of 1973Reach out to persons with disabilities and provide information about job

vacancy announcements.

Vietnam Era Veteran’s Readjustment Act (VEVRAA/JVA)List all employment opportunities with the appropriate employment delivery

system in the state where the job is located.

Companies must take measures to ensure that job vacancy announcements reach job

seekers who are veterans, minorities, women and persons with disabilities.

OFCCP Regulations – The Spirit of the Law

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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 contractors

list 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-Peyser

Act, 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 appropriate

employment delivery system?A contractor may satisfy the mandatory job listing requirement by using any means that is permitted by the appropriate

employment delivery system for listing employment openings, which may include mail, facsimile (FAX), electronic

mail, or other electronic postings. The vast majority of the state workforce agency job banks accept job listings via the

Internet. Contractors may use third parties, such as private or non-profit sector job banks, Internet gateway and portal

sites, and recruiting services and directories, to assist them with the transmission of job listings to the appropriate

employment service delivery system. However, a contractor remains responsible for complying with OFCCP's job

listing requirements.

The regulations are very specific as they relate to job posting requirements for VEVRAA/JVA

OFCCP Regulations – The Letter of the Law

Source: http://www.dol.gov/ofccp/regs/compliance/faqs/jvafaqs.htm#Q11

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Post Jobs in National Job SitesPost job listings in job sites that reach large number of seekers including

minorities, 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 other

electronic means, or to the state job banks.

The law obligates contractors to be accountable for a set of activities, whether performing

internally or using a third party vendor, and to be ready to show proof, if audited.

Contractor Obligations

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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 when

posting 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 is

sending 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, as

well as maintaining consistency of content.

For most contractors performing these tasks internally and maintaining proper records is

labor intensive and incurs a significant expense.

Implementation Challenges

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Job Postings on AJE and the AJE Network of Job SitesListings that reach a million job seekers per month with a large

concentration of minorities, women, veterans and the disabled.

Job Postings to Niche Diversity Partner WebsitesListings that reach job seeker audiences in targeted communities of

minorities, women, veterans and people with disabilities.

Job Delivery to the Appropriate State Employment SystemsAutomated job delivery to State Workforce centers, Career One Stop

Centers, 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.

For a fraction of this cost, Federal contractors can obtain solutions from third party vendors

such as America’s Job Exchange (AJE), a leader in recruitment compliance.

A Better Alternative

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Automated TechnologyState-of-the-art web platform, job distribution technology, data

exchange mechanism, and search methodologies.

PartnershipsLarge network of partnerships with niche job sites, community

organizations, states, associations and employment agencies.

Domain ExpertiseAs developer and operators of the America’s Job Bank program, AJE

has more than 15 years of experience in this area.

Scale EconomicsAJE serves more than 500 of the leading enterprises for compliance

solution and derives efficiency from repetitive processes.

Third party vendors such as AJE achieve efficiency through a combination of automated

technology, partnerships, domain expertise and scale economics.

Efficiency Drivers

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Traffic GenerationGet traffic to your jobs as well as to your career website through

search engine optimization (SEO) and search marketing (SEM).

Recruitment Brand DevelopmentA full suite of media products for recruitment sourcing, corporate

branding, 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 audit

including consultation, and retrieval of past documents.

Solutions from a third party vendor such as AJE also provide additional products to bolster

ROI of your recruitment media and advertising program for diversity and inclusion.

Additional Benefits

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Irrelevant ProductsDon’t get sidetracked by products that are not related to

compliance requirements.

EndorsementsRemember that endorsements are nothing but PAID sales

pitches!

Marketing GimmicksBeware of aggressive sales/marketing talk. Stay focused on

what you need.

Exaggerated PromisesDon’t fall for over-promises by vendors exaggerating the

effectiveness of the solution.

Irrelevant ProductsDon’t get sidetracked by products that are not related to

compliance requirements.

EndorsementsRemember that endorsements are nothing but PAID sales

pitches!

Marketing GimmicksBeware of aggressive sales/marketing talk. Stay focused on

what you need.

Exaggerated PromisesDon’t fall for over-promises by vendors exaggerating the

effectiveness of the solution.

What’s Not Important

Completeness/CustomizabilityDoes the solution address the regulation fully and is it

customizable for your business?

Breadth of DistributionDoes the provider maintain a large network of partners for

job distribution?

Reporting and SupportDoes the solution provide easy access to reports and

expert support if your company is audited?

Reputation and Track RecordHow long has the vendor been providing these services and

how satisfied are their customers?

Completeness/CustomizabilityDoes the solution address the regulation fully and is it

customizable for your business?

Breadth of DistributionDoes the provider maintain a large network of partners for

job distribution?

Reporting and SupportDoes the solution provide easy access to reports and

expert support if your company is audited?

Reputation and Track RecordHow long has the vendor been providing these services and

how satisfied are their customers?

What’s Important

Contractors should consider the following criteria when selecting a third party vendor.

Third Party Vendor Selection Criteria

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Legacy of America’s Job BankAJE launched on the same technology platform with the same people

who developed and operated the DOL program.

Backed by a Fortune 500 CompanyAJE is a wholly owned subsidiary of Time Warner Cable with the

financial and technology resources to drive product innovation.

Fast GrowingAJE is one of the fastest growing job boards with an expanding

product 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.

America’s Job Exchange is one of the fastest growing companies in the industry and a

leading provider of recruitment media, advertising and compliance solutions provider.

America’s Job Exchange – A Brief Overview

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America’s Job Exchange - Solution Summary

Several AJE products and servicesare bundled to form the industry’s

most complete Job Listing andDistribution Solution

Industry leading tools, technologiesand live assistance are combined to

offer an unparalleled customerexperience

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CLIENTELE

TRACK RECORD

REPUTATION

Completeness of SolutionBundles several distinct products and services to satisfy the broad

range of tasks required by the regulators.

Customizability of SolutionThe AJE solution is customizable and priced based on your business

needs with variables such as size, hiring forecast and budget.

Breadth of Distribution NetworkBroad network of partners and affiliates including recruitment media

agencies, technology provider, associations and states.

Subsidiary of Publicly Traded CompanyAJE is not a membership-based non-profit association but part of a

customer centric, publicly traded organization you can trust.

The solution from America’s Job Exchange is well differentiated from others.

The AJE Difference

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ComprehensiveUtilize a turnkey set of products and services to fulfill current requirements

and stay abreast of changing regulations with updates and new products.

Cost EffectiveThe cost of services is significantly lower than companies doing the same

work internally or using an agency to do in pieces.

ExpertiseCompliance services being the core offering, third party vendors provide deep

expertise and domain experience to help contractors navigate the regulations.

Third parties such as America’s Job Exchange are a significant resource available to

Federal contractors who must meet the OFCCP compliance regulations in recruitment.

Conclusion

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Thank You

For more information, please contact:

Rathin [email protected]