Magazine Article
Build Your Compliance, Diversity Programs
October 21, 2009
Integrated Solutions For Retailers, October/November 2009
Erin Harris
The Home Depot, the $65 billion retail giant, is known for providing the right tools and services to guide customers through various home improvement projects. Interested in further developing its revenue plan, The Home Depot wanted to become a federal contractor so it could expand into the government sector. However, to qualify as a government contractor, the retailer needed to implement an affirmative action program as part of a companywide diversity initiative. The company needed a solution that could not only create affirmative action plans (AAPs), but also provide metrics on a consistent basis and training for team members.
Do You Need An
Affirmative Action Plan?
Affirmative action is the practice in which employers identify conspicuous imbalances in the workforce and take positive steps to correct under representation of or adverse impact practices toward "protected classes," such as women, minorities, people with disabilities, and veterans. AAPs focus on the hiring, training, promoting, and compensating of protected classes where there are deficiencies. The OFCCP (Office of Federal Contract Compliance Programs) requires government contractors and subcontractors to annually establish and maintain an AAP to ensure they take proper action toward providing equal employment opportunities. (If you're a government contractor, or subcontractor, with 50 employees or more and over $50,000 in annual contracts, you should have an AAP in place.) In order to become a government contractor, The Home Depot needed to create an AAP for more than 1,900 stores. "Our decision to elevate to the level of government contractor put us over the $50,000 threshold, so we needed an AAP," says Jeff Spratlin, director of government compliance at The Home Depot. Indeed, Spratlin needed to ensure that not only were the company's overall diversity objectives met, but that the retailer was compliant with the ever-changing and constantly increasing federal requirements, many of which are subject to broad interpretation.
Review Your Compliance
Records On A Quarterly Basis
Spratlin researched several vendors that offered a range of compliance and diversity program development services before choosing Peopleclick CAAMS, a Web-based affirmative action software for multilocation, multi-AAP, distributed enterprises. "Rather than licensing Peopleclick's software and running it on our systems in-house, Peopleclick acts as our third-party administrator and hosts it for us," says Spratlin. "Our staff here at the Store Support Center simply log on and use the software online via our intranet. On a quarterly basis, we provide Peopleclick with all of our employment transactional data. They run computations and return valuable data in various reports that we transmit to each of our stores." CAAMS auto-generates a set of required OFCCP reports including narratives, progress to goals, adverse impact analysis, and compensation analysis. The software automates development of self-defined management-based plans for an accurate view of The Home Depot's compliance picture.
Because of the vendor's hosted software system, The Home Depot has strengthened the partnership between itself, the OFCCP, and the Department of Labor. "We are able to successfully demonstrate our compliance and diversity efforts to the OFCCP with confidence and success by creating an AAP," says Spratlin. This project is a success because The Home Depot has increased awareness enterprisewide. Now that The Home Depot is a compliant organization, it is able to obtain more government contracts, which inevitably will lead to increased revenue.

