A division of a major manufacturer was preparing for a compliance review of their Affirmative Action Plan by the Office of Federal Contract Compliance Programs (OFCCP). The company requested an independent third party to conduct an analysis of its compensation practices in preparation for the compliance review.
D.G. McDermott Associates conducted a compensation analysis in the same manner that the OFCCP performs its reviews. The analysis covered a business unit with approximately 9,000 employees to determine the factors which influence pay.
Based on its analysis, D.G. McDermott Associates recommended the following:
- A review of the Affirmative Action Plan to ensure that the correct parameters were covered for purposes of consistency with its analysis
- Modifications to its pay programs to minimize inadvertent prima facie discrimination issue
- So as not to limit the review to current compensation rates, an examination of the following areas was required: starting salaries, promotion practices, tenure in the company and the job, etc., as factors which may influence pay
The company adopted D.G. McDermott Associates' recommendations and successfully completed the compliance review.