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Gerstco Services

Affirmative Action Planning Services Tailored
To Your Needs


Affirmative Action Plans


Our approach is to design and develop Affirmative Action Plans that meet the specific needs of our clients while maintaining contract compliance. We work in consultation with contractors to ensure that their organization's plans accurately reflect their operational structure and company practices. Our design process involves mutual decision-making by:

  • determining the organizational reporting structure
  • identifying Corporate employees and employees reporting across geographical AAP sites,
  • forming of AAP job groups and identifying recruitment areas
  • determining the 'availability' of women and minorities
  • selecting appropriate AAP goal methodologies, and
  • preparing appropriate compensation analyses.

The Affirmative Action Plans will meet current government regulations for the following programs:

  • Executive Order 11246, as amended (AAP for Minorities and Women);
  • The Rehabilitation Act of 1973, as amended (AAP for People with Disabilities); and
  • The Vietnam Era Veterans' Readjustment Assistance Act of 1974, as amended.

The Plans will consist of workforce data, analysis, reports, and narratives:

  • Executive Order 11246 narratives:
  • Current policies and procedures for communication of the AAP.
  • Designation of AAP responsibility.
  • Action-Oriented programs to obtain goals and objectives.
  • Internal audit and reporting of AAP performance.
  • Narratives related to The Rehabilitation Act of 1973.
  • Updated narratives related to the Vietnam Era Veterans' Readjustment Act of 1974, which went into effect September 7, 2007.

Required Executive Order 11246 reports and analyses include:

  • Updating the company's workforce analysis and job groups, as needed.
  • Updating the Two-Factor Analysis by job groups, for minorities and women.
  • Generating an updated Incumbency to Availability, by job group, race and gender.
  • Updating AAP goals, analyzing prior year goal performance.
  • Identifying and updating 'problem' areas, when necessary.
  • Assessing Results-Oriented efforts to achieve AAP goals.
  • Analyzing hire, promotion, termination, selection rates.
  • In addition, we will continue to assist you with applicant recordkeeping processes to meet Internet Applicant rules.

Specialized Affirmative Action Plans

We can prepare specialized Plans such as Functional Affirmative Action Plans (FAAPs) instead of traditional location-based Plans for clients requesting this service. If requested, we can provide guidance to contractors that need assistance in navigating the Office of Federal Contract Compliance Program's (OFCCP's) approval process.


AAP Development Process

Whether developing an Affirmative Action Program for the first time, or transitioning plan development outsource service, Gerstco can complete AAP development to meet business objectives and achieve contract compliance. Gerstco's AAP Development process segments projects into four phases: project planning, data gathering, AAP development and AAP Completion and Publication.

AAP Development Process AAP Development Process - Large

Included in all aspects: Project Management

Project Managers schedule, ensure timeliness work with AAP developers and act as a primary liaison between company contacts and the Gerstco Team.


AAP Delivery

We deliver Affirmative Action Plans tailored to client requirements. Deliverable Plans are reviewed by Senior Consultants to ensure accuracy and compliance readiness. Clients may elect to receive Plans in soft (electronic) or hard copy formats.

Compliance AAP
The compliance AAP includes all required program narratives, policies, and procedures for Executive Order 11246, the Rehabilitation Act of 1973, and the Vietnam Era Veteran's Readjustment and Assistance Act of 1974. This document also contains the required AAP reports, data, and analysis and is considered 'compliance ready' when completed, in that a copy of the AAP, as it is constructed, and with the addition of two other documents, could be submitted to the Department of Labor's Office of Federal Contract Compliance Program (OFCCP).
Supporting Documentation
This document supports the Compliance AAP and includes detailed reports on hiring, promotions, terminations, and internet applicant results. In addition, supporting documentation such as: compensation analysis, internal AAP audit reports, Impact Ratio Analysis results, employee listings, Compliance Flags reporting*, and other client requested information will be included.
*Compliance Flags Reporting
As a standard, we assist clients with their AAP assessment in advance of a Compliance Evaluation, by providing 'compliance flags' reports when the AAP is developed and updated each year. These 'flags' will identify AAP problem areas for the current reporting period. The information focuses the EEO Professional and Legal Counsel in areas where further investigation may be necessary. 'Compliance Flags' are just one of the many ways Gerstco keeps clients up-to-date on their state of 'compliance readiness'.

Sample Affirmative Action Plan

Electronic AAP Format (eAAP)

Gerstco's 'electronic' version of an AAP can be delivered in PDF format, on a CD, or uploaded to our website and downloaded by our clients. Delivery is secure and instantaneous.

There are many benefits to receiving an eAAP copy, including more secure transmission, cost-effective distribution to other geographies, minimizing storage requirements, ease of archiving, and electronic submission to OFCCP in a Compliance evaluation.

Annual AAP Briefing Presentation

After completing the Affirmative Action Plan, we will include a customized presentation suitable for Executives, Managers, and Human Resources employees, regarding company performance to AAP goals. Discussion topics include: workforce and industry comparisons; performance to AAP Goals, Specialized Organizational AAP views and AAP obligations to managers.

AAP Client Orientation

We are committed to deliver and communicate our client's Affirmative Action Plans via web conferencing or on-site at client offices. Client meetings provide understanding of workforce changes and issues; this can be a dialog where individuals ask questions and share insights and experience in AAP implementation.

Gerstco Senior Consultants lead this meeting and cover the following information: (a) a detailed orientation to the AAP plan structure; (b) an assessment of the AAP 'compliance evaluation readiness;' (c) AAP goal performance, and (d) suggested remedies and strategies as appropriate.

Year-Round Customer Support

We encourage clients to contact us at any time during their AAP year. We make every effort to respond to clients on the same business day, or a soon as practical.