Food for Thought

"The last buggy whip factory was no doubt a model of efficiency." - Peter Drucker

"When I hear artists or authors making fun of businessmen I think of a regiment in which the band makes fun of the cooks." - Anonymous

"The thing to remember is that the future comes one day at a time." - Dean Acheson

"Most ball games are lost, not won." - Casey Stengel

How We Can Help

The unspoken question that all audiences have, whether it is an audience of one or one million, is quite simple: 

"What's in it for me?"

Rather than reciting a general list of our services, we can best answer that by describing the types of situations in which we have provided substantial help to people over the years. Look over these examples and see if any of them resemble or match your needs:

• An executive wanted to improve communication with his direct reports.
• A team needed training on harassment prevention and EEO.
• A hard-charging manager was having problems communicating diplomatically with a diverse group of employees and needed one-on-one coaching.
• A highly accomplished executive felt an outside perspective could give an added boost to his leadership skills.
• An employer with federal contracts received a letter from the Office of Federal Contract Compliance Programs (OFCCP) announcing an upcoming Affirmative Action audit.
• A large organization had conflicting departments and - unknown to them at the time - conflicting goals.
• An organization faced customer service problems, both with external and internal customers.
• Public sector executives and managers wanted training on how to make presentations to their councils and boards.
• A federal contractor needed an Affirmative Action Plan.
• An executive wanted a 360 degree evaluation of his leadership style.
• A supervisor's stress level was rising due to a very difficult employee.
• The employee handbook was boring and outdated and needed revision.
• The employer needed training in ethical decision making.
• A team was unsure about how to mesh leadership with management.
• The workplace had problems with trust.

If these resemble any of the challenges you face, let's talk. 

Call us today at 602-788-1717 or email: info@swrci.com . 

EEO/AA Management is Sound Management

Simply put, Equal Employment Opportunity and Affirmative Action programs need active and energetic management. If left untended, organizations can become a jungle where indifference, inflated job descriptions, questionable standards, sloppy screening, missed hiring opportunities, outright or subtle discrimination, hostile work environments, and quotas are tolerated or ignored. 

And any of those can attract the 500 pound gorilla of litigation.

We've found that the best EEO/AA programs neatly mesh with sound human resources practices and high ethical standards. They don't stand apart as requirements that require occasional attention but instead blend in with daily management and supervisory behavior. This not only reduces resistance to such programs, it benefits the entire organization because EEO and Affirmative Action - if handled properly - are important tools for finding, keeping, and developing talent.

Questionable EEO/AA programs fail to enlist the active participation and support of the entire team. Just as the best quality management programs reach every corner of the organization, the best EEO/AA programs demonstrate how everyone has a role that goes far beyond preventing discrimination. 

In short, EEO/AA management is a major component of talent management. It not only prevents problems, it creates positive contributions to the organization's success by ensuring that employees work and strive in an environment where the only discrimination is on the basis of merit.

For information on how we can assist with the management of your EEO/AA program, call us at 602-788-1717 or email info@swrci.com. 

The Procrastination Infection

I'll do it when:

• I'm in the right mood. [When that state is achieved, I'm a dynamo.]
• The time is right. [If it ever is.]
• I have enough time to complete the entire project. [Because doing part of it just wouldn't be right.]
• I have all of the information. [And I always need more information.]
• Everyone's back from vacation. [Don't they all go at the same time?]

It is a rare person who is immune from the procrastination infection. All of us can find ample excuses for not tackling a project. A reason why we succumb to many of those excuses is that they are seldom without merit. We also want to do it right and "it" is the entire project.

Time management consultant/author David Allen notes that we don't work on projects; projects are the result of what we work on, and that rather than adopting an "all or nothing" approach, we should  focus on the next steps. That way, we will get to the end of the day with some tangible progress in hand instead of gazing at - and being demoralized by - a list of unfinished projects. [We experience more stress from the uncompleted than from the "not started."]

There is much wisdom in Allen's advice. Most of the good and bad things in life are produced incrementally. Every day, we advance or fall back in small segments. Taking matters 30 minutes at a time can make enormous sense. There will be hectic days when 10 minute segments may be necessary.

If we are going to fight procrastination, we have to think incrementally.

Strategies for Unhappiness

Consider how many of the following strategies may have slipped into your own approach to life:

• Don't appreciate your achievements. Instead, regard them as things that anyone could do or which somehow occurred through no serious effort of your own.
• Keep raising the bar for satisfaction instead of celebrating when goals are achieved. 
• Chastise yourself for not being perfect.
• Compare yourself to others and believe that other people are much happier, more self-confident, and have fewer problems.
• Expect others to behave and think as you would behave and think.
• Expect others to know when you are upset. Regard their failure to notice as a sign that they are insensitive and uncaring.
• Link your success to achieving a particular job title or income level.
• Periodically re-open old wounds.
• Always be on the alert for any insults or slights.
• Give greater weight to criticism than to praise.
• Expect others to be angels and then condemn them when they fall short.
• Believe that anyone who has more took it from someone else.
• Worry about your failure to control things that are beyond your ability to control.
• Worry about things that are unlikely to happen.
• Always be wary of being hustled.
• Focus on getting others to understand you instead of first understanding others.
• Be harder on yourself that you would be on similarly situated others.
• Associate with people who have similar negative habits so you can reinforce one another's feelings.
• Tell yourself every day that you are an impostor who talks a good game but who really doesn't deserve to be in your job.
• Keep careful score on who gets what.
• Expect the world to be fair and always define fairness as you getting more rather than you getting less.
• Cultivate an attitude of entitlement.
• Define wants as needs and have plenty of wants.
• Seldom show gratitude.

All I Said Was Training

This week, Sanders Wade Rodarte partner Michael Wade will begin a series of All I Said Was workshops for a new client on how to avoid unintended insults, injuries, and slights in today's diverse workplace. The class is designed to help managers and employees navigate around danger zones where ill-chosen remarks can lead to complaints and lawsuits. At the same time, the class also examines how to avoid "politically correct" hypersensitivity that can erode trust and fracture teams.

Michael developed the class years ago after encountering well-meaning individuals whose comments had created unnecessary problems in their teams and had, in some cases, even sparked discrimination complaints. [He has also written a book on the subject.]

The half-day workshop is fast-paced and filled with practical guidelines and case examples. Michael notes: "It's as current as today's headlines. Rarely does a week go by without a celebrity having to apologize for or clarify some remarks. This workshop takes a no-nonsense approach to a real problem. It's really about how to be a more effective communicator because if you have to interrupt your message for an apology or an explanation, you're not communicating well."

Information on the program can be obtained by emailing michael@swrci.com. 

A SUCCESSFUL OFCCP COMPLIANCE REVIEW OF AFFIRMATIVE ACTION PROGRAMS

(1) A successful compliance review (audit) of the Affirmative Action Program ends at the desk audit stage. If the OFCCP walks away and closes the audit, that’s a successful audit.  Occasionally the OFCCP finds items they are concerned with in the desk audit.  In those cases, if you’ve been cooperative, they may let you address the items of concern before issuing the findings and then they’ll close the review and be on their way to the next company. The OFCCP will be gone for at least two years. Working with the OFCCP is a delicate matter. Be cooperative, honest and attentive (And, if you have a consultant with experience, be strategic).

(2) If the audit goes into a site visit…well there’s some headaches ahead. They’ll be on your site, requesting a meeting with the top company officer, asking for files to review, conducting interviews with employees, checking for your visible compliance evidence and more. More what? More review of materials than would have ended at the site visit. If the compliance review ends there, great!  

(3) If the compliance review ends in a conciliation agreement then you’ve got a year or two of some additional planning, diligent tracking and periodic reporting to the OFCCP. The time committed to any of these activities is worth mentioning…it will use up a lot of time that could have easily gone to other assignments. It’ll seem like the two years of oversight by the OFCCP never comes to an end. 

(4) If the compliance review ends with a lawsuit… well it really doesn’t end, does it?

Federal Acquisition Regulations (FAR) for Preaward Affirmative Action Program Clearance

According to Federal Acquisition Regulations (subpart 22.805; copy directly below), a preaward AAP clearance is required for companies entering into service and supply contracts with the federal government in amounts exceeding 10 million dollars. In these contract negotiations, contracting officers are required to ensure AAP clearance and the contracting officer will ask contractors to disclose whether or not they have written affirmative action programs and if they have undergone a compliance review of the AAP in the preceding 24 months.  If they haven’t been reviewed in the preceding 24 months then the contracting officer requests a review by the OFCCP prior to completing a contract. The contracting officer however need not request clearance from the OFCCP if the company has undergone a successful compliance review in the preceding 2 years (22.805 (a)(4)).  

Federal Acquisition Regulations (22.805):

22.805 Procedures.

(a) Preaward clearances for contracts and subcontracts of $10 million or more (excluding construction).

(1) Except as provided in paragraphs (a)(4) and (a)(8) of this section, if the estimated amount of the contract or subcontract is $10 million or more, the contracting officer shall request clearance from the appropriate OFCCP regional office before—

(i) Award of any contract, including any indefinite delivery contract or letter contract; or

(ii) Modification of an existing contract for new effort that would constitute a contract award.

(2) Preaward clearance for each proposed contract and for each proposed first-tier subcontract of $10 million or more shall be requested by the contracting officer directly from the OFCCP regional office(s). Verbal requests shall be confirmed by letter or facsimile transmission.

(3) When the contract work is to be performed outside the United States with employees recruited within the United States, the contracting officer shall send the request for a preaward clearance to the OFCCP regional office serving the area where the proposed contractor’s corporate home or branch office is located in the United States, or the corporate location where personnel recruiting is handled, if different from the contractor’s corporate home or branch office. If the proposed contractor has no corporate office or location within the United States, the preaward clearance request action should be based on the location of the recruiting and training agency in the United States.

(4) The contracting officer does not need to request a preaward clearance if—

(i) The specific proposed contractor is listed in OFCCP’s National Preaward Registry via the Internet at http://www.dol-esa.gov/preaward/;

(ii) The projected award date is within 24 months of the proposed contractor’s Notice of Compliance completion date in the Registry; and

(iii) The contracting officer documents the Registry review in the contract file.

MANAGERS LIST OF AFFIRMATIVE ACTION PROGRAM DUTIES

Part 1 of 3

AAP Regulation Requirements

		Assigned to	Date Due	Completed
1.	Annually revise EEO/Affirmative Action Programs.
2.	Formally analyze selection decisions and compensation practices for adverse impact.
3.	Revise and replace company EEO/Affirmative Action Policy. Post at/on company sites as necessary.
4.	Report EEO/AAP progress to senior management.
5.	Track Good Faith efforts.
6.	Ensure AAP Summary is available for review by employees.
7.	Ensure supervisors are familiar with EEO/AA Program and their responsibilities for implementation.
8.	Annually notify subcontractors, vendors, and suppliers of their affirmative action obligations.
9.	Ensure Equal Opportunity Clauses are incorporated in all covered contracts and purchase orders.
10.	File VETS-100 and/or VETS 100A reports by September 30th.
11.	File EEO-1 report by September 30th.

If you would like a Microsoft "word" copy of this document contact Lou at lou@swrci.com. 

Contact Lou for assistance with your AAP requirements or active compliance review.