1. 1 A Letter from the DOL ~ OFCCP audit Trudy Schapansky, PHR Director, Human Resources

2. 2 My Story My philosophy My inheritance What the law states Receipt of the “letter” Organize yourself What I prepared What is required The week before the audit What do I do now What I recommend

3. 3 My Philosophy Have a sense of humor Be authentic & direct Learn from every success & every failure Ask questions Embrace learning new things Keep in touch with your Network

4. 4 My Inheritance 100 employees PEO ~ employer of record July ’07 HR hired* 30 + million in sales ( Ask the question…do we have government contracts ?) Partnership & Reseller program * Rolled out of PEO, Vocera hired 100 employees, hired an Insurance Broker, purchased payroll & HR service, contacted AA vendor 10/07, hired ~25 new employees, audited employee files, Dec open enrollment, physically moved company, taught company online HR system, hired ~ 25 new employees, received DOL letter, managed RIF, onsite DOL audit

5. 5 What the Law states If your company has: Over fifty (50) employees Any government contract over $50,000 In plain language: –Any Sales employee AND/OR any partner who sells a government contract of over $50,000 –HR knows this law…your executives may not…your job is to know you need an Affirmative Action Program Executive Order 11246: Requires any company to have an Affirmative Action Program http://www.dol.gov/esa/ofccp/regs/compliance/fs11246.htm

6. 6 Receipt of the “letter” It is sent to the CEO You will have 30 days to make a response Read it over, and over, and over “OFCCP will conduct the compliance review as described in the regulations at 41 CFR 60-1.20 (a) (1) and 60-250.60 (a) (1) which outline the three possible phases of the process. These phases may include: –a desk audit –an onsite review –an offsite analysis

7. 7 Organize yourself Gather information Call an Affirmative Action consultant – I hired one Contact your Network of HR colleagues who have tackled an audit –Ask them what they experienced –What their recommendation are for you –What they wish they would have done –Ask them what else they would share…that you wouldn’t know to ask Research on Google Understand exactly what the DOL is requesting Set aside other projects…this takes total priority –I hired a student for data entry –I hired a consultant

8. 8 What I prepared Updated and published a job description for each position in the company (~120 employees) Audited the I - 9 binder Gathered all resumes of candidates we interviewed & hired (’07, ’08) Created Applicant Flow chart of all candidates (’07, ’08) Gathered ‘07 Policies & Procedures Updated & wrote ’08 Policies & Procedures –Employment Selection Process, New Hire Req Form, Vocera Career Web page, Email to recruiters (updated recruiting contracts), Recruitment module (ADP), copy of job postings & pre-employment Self ID form, pre-employment form, employment application, background check authorization, AA Interview process, interview rating sheets, Interview training material, AA New Hire process, New Hire template, Emp Self ID form, Memo to execs & hiring managers regarding AA, CALJOBS & AA postings

9. 9 What I prepared Updated and published a job description for each position in the company (~120 employees) Audited the I - 9 binder Gathered all resumes of candidates we interviewed & hired (’07, ’08) Created Applicant Flow chart of all candidates (’07, ’08) Gathered ‘07 Policies & Procedures Updated & wrote ’08 Policies & Procedures –Employment Selection Process, New Hire Req Form, Vocera Career Web page, Email to recruiters (updated recruiting contracts), Recruitment module (ADP), copy of job postings & pre-employment Self ID form, pre-employment form, employment application, background check authorization, AA Interview process, interview rating sheets, Interview training material, AA New Hire process, New Hire template, Emp Self ID form, Memo to execs & hiring managers regarding AA, CALJOBS & AA postings

10. 10 What is required 1. Applications, resumes from Jan. ’08 – June ’08 2. Applicant flow log from Jan. ’08 – June ’08 3. Written policies and/or procedures describing recruitment, application, interview & hiring process for ’07 4. Written policies and/or procedures describing recruitment, application, interview and hiring process for ’08, including on-line application process…with note at which step in the process an invitation to self identify race/ethnicity/gender is issued 5. A list of personnel involved in the selection process and the step of the process they are involved 6. Copy of Federal contract/subcontract showing start and end dates, dollar amount, funding agency, signatures of company representative 7. Employee Handbook, highlighting employment policies 8. I – 9 binder, current & former 9. Job descriptions

11. 11 The week before the Audit… 1. Affirmative Action consultant trained 1) our executive team, 2) our managers, 3) our employees 2. CEO sent an email to the employees The day before: Reviewed all material with the CFO Staged room (choose a quiet room) Created a cover letter & numbered all the items The day of: Two auditors ~ 29 year veteran, 1 year veteran 30 minute meeting with Auditors, HR, CEO, CFO, VP Engineering, VP Services, AA consultant Auditors, HR, AA consultant moved into staged room –I was interviewed about each process (including I-9 process) –Asked to choose 3 – 5 managers for auditor to interview

12. 12 What do I do now Candidates apply through Vocera’s recruitment module (this allows them to fill out the self ID form) I conduct an interview training course with each hiring manager/group, when we have open positions Hiring managers must interview ~ 5 candidates for each position Managers keep list of candidates, resumes…turn them into HR at completion of interview process Keep ongoing Applicant Tracking spreadsheet Update job descriptions Keep log of all job postings

13. 13 What I recommend Stay focused and organized ~ know your material Run all communication thru Affirmative Action consultant This is no time to be unsteady (example “just show me your files…I’ll take what I need ) Stay cool, calm & professional Ask questions to clarify…and stay open to learn from the auditors –They will teach you and answer any questions you may have Be authentic & honest

14. 14 Questions