The SESCO Report – August 2024
Who Must Develop an Affirmative Action Program?
If a business or organization has a federal contract, subcontract,or federally assisted constructioncontract, it may be subject to the requirements of Executive Order 11246.
Generally speaking, any business or organization that: 1) holds a single federal contract, subcontract, or federally- assisted construction contract in excess of $10,000; 2) has federal contract
or subcontracts that combine total in excess of $10,000 in any 12-month period; or 3) holds government bills of lading, serves as a depository of federal funds, or is an issuing and paying
agency for U.S. savings bonds and notes in any amount will be subject to requirements under one (1) or more of the laws enforced by the OFCCP.
Financial Institutions IncludingCredit Unions – A financial institution with 50 or more employees which is an issuing and paying agent for U.S. savings bonds and savings notes in
any amount must develop an Affirmative Action Program.
Organizations with Multiple Facilities – If an organization has multiple facilities, even in multiple states, the business must develop an Affirmative Action Program covering the entire organization and establishments or facilities will be subject to the same regulatory requirements, regardless of where the federal contract is actually performed.
Construction Contractors –All construction contractors and subcontractors who hold a federal or federally assisted construction contract in excess of $10,000 will be subject to the OFCCP.
Financial Institutions and Credit Unions Covered by the Federal Deposit Insurance Corporation or National Credit Union Association-Financial institutions with federal share and deposit insurance are considered to be government contractors within the meaning of the regulations implementing compliance to Executive Order 11246, Section 503 of the Rehabilitation Act, Vietnam Era Veteran’s Readjustment Assistance Act of 1974.
“Nonpersonal Services”-The Executive Order 11246 includes, but is not limited to, the following services:
• Utilities
• Construction
• Transportation
• Research
• Insurance
• Fund Depository
Subcontractors-Subcontractors are businesses and organizations that perform work for a federal contractor that is related to and necessary for the performance of a federal contract. A subcontractor includes:
1. The purchase, sale or use of personal property or nonpersonal services which, in whole or in part, is necessary to the performance of any one or more contract; or
2. Under which any portion of the contractor’s obligation under any one or more contracts is performed, undertaken or assumed.
Compliance to the OFCCP applies to some subcontractors if:
• In any 12-month period, the subcontractor expects the total dollar amount of the business’ federal contracts or subcontracts (construction and non construction) to exceed $10,000.
• The organization holds a single federal contract or subcontract in excess of $10,000 to be performed over a period of more than one year.
As with all federal agencies, the OFCCP is aggressively conducting “desk audits” to determine employers’ compliance. SESCO specializes in developing compliant Affirmative Action Programs, representing clients before the OFCCP and generally advising contractors and subcontractors as defined in their obligations. Noncompliance results in loss of contracts and potential fines and penalties.
Today's Leader Must Be an Effective Coach
The old-school "supervisor" or "foreman" was considered an expert in a technical, functional or professional skill. Being a good supervisor was having the right answers and subsequently
commanding and controlling employees.
Today's leader must be an effective coach foremost. In today's workplace, we experience rapid, constant and disruptive change. Coping with this reality must require leadership to move away from traditional command-and-control practices toward something very different: a model in which leaders give support guidance rather than instructions. Employees learn how to adapt to changing environments. Furthermore, today's younger and more successful employees respond to mentoring and coaching much more favorably than being told what to do. Today's younger generation wants to be a part of the process and subsequently grow and develop.
Why coaching is so critical to the organization's success:
- Most employee turnover occurs within the first six (6) months of employment. This is due to the lack of training and coaching of employees. "Come to work, do a good job and we will take care of you" is not the answer in today's environment. As stated, employees want to be successful and as such, it is the leader's primary responsibility to train and work their employees, especially during the firs (6) months. If employees are not trained and coached, they become frustrated and isolated. This results in turnover.
- Labor is every business's largest, single controllable cost. As such, for an organization to maximize profitability, they must maximize their labor cost. This means reducing turnover as well as doing more with less. The organization cannot afford mediocre behavior to hang around. It kills morale and furthermore, we cannot afford the cost in terms of dollars for mediocre behavior. Thus, once we hire the best individual for the position (which has become more and more difficult), the leader then must train and coach to ensure that individual's success. This coaching becomes the leader's number one responsibility. Coaching employs to maximize their performance is win-win, re: individual employee success and growth and organizational profitability.
As stated earlier, a leader cannot command and control in today's environment. There are different styles of coaching, but SESCO recommends situational coaching. Situational coaching, as its name suggests, involves striking a fine balance between command and avoidance styles.
The professional leader who coaches by situation will:
- Prepare for the conversation. (See the recommended preparation worksheet.) The leader must be fully engaged in each and every employee's growth.
- The effective leader will then engage the growth model which first asks of the employee, "What will you do?" As part of coaching, this encourages the employee to be engaged. Engage in a conversation with the employee asking critical questions to confirm the growth model.
In the end, we all live in a world of change. Successful leaders must increasingly supplement their technical and functional expertise with a general capacity for learning — they must develop that capacity and the people they supervise. Leaders and subsequently the organizations in which they are employed will not meet their potential using a command and control managerial style. Instead, with full organizational support, from the top, leaders at all levels must reinvent themselves as coaches whose job it is to draw energy, creativity and learning out of the people with whom they work. As such, every organization must set aside a small percentage of their gross revenue to train and develop leaders to become successful coaches.
SESCO Management Consultants has been training managers and leaders for over 70 years. We employ a number of successful leadership development programs which can be delivered in house, remotely, as well as provided to in-house professional trainers. Contact SESCO at 423-764-4127 to learn more about our Professional Leadership Development Series.
Coaching Conversation Preparation Sheet
Coaching Conversation Preparation Sheet
Meeting with:
Date:
Manager Preparation – The goal is to be able to “✓” the ❑ for each of these items below:
❑ Positive frame of mind
❑ Ready to focus on employee
❑ Be present mentally, emotionally, and physically
❑ Listen (paraphrase, check perceptions, meeting/environment is favorable for conversation)
❑ Curious and ask open ended questions
❑ Awareness of body language, tone of voice, words, and utterances
❑ Awareness of “Ladder of Inference”
❑ Set electronics to off/turned to vibrate, and set to the side
I am curious about (list topics, possible open-ended questions to use):
What personal preferences and biases do I need to be aware of that may impact the conversation?
The intent is not to utilize every question, but to use the question or set of questions that would produce the most insight and learning for the staff member at
that moment.
Coaching Conversation Preparation Sheet
Many managers find the GROWTH model helpful in providing structure to their conversations with staff members. The acronym represents the coaching process, and these steps help staff get from where they are to where they want to be. And signifies the overall objective of coaching: G-R-O-W-T-H
G-Goal The mutually agreed upon desired end state or outcome that is to be achieved.
R-Reality The current state of affairs. What is occurring that is relevant to understanding this situation...what is creating this situation and what is maintaining it?
O-Options for The alternatives that exist for achieving the goal.
W-Way Forward The mutually agreed upon pathway as well as any additional resources and supports needed along the way.
T-Track Progress The planning and thoughtful monitoring of progress and provision of feedback and support by the coach at specified check-in times.
H-Honor Accomplishments The celebrating of successes along the way.
SESCO Client Feedback
SESCO Client Feedback
"Bill, thank you so much for your assistance with the FLSA. It was very helpful!" ~ Angie Rasnake, Sr. Manager, HR/People Operations/Office Management — Universal Companies
"Bill, you and your team have been great to work with."~ Jackie Mayo, President & CEO — HomeSource East Tennessee
"Bill and I spoke this morning. He is fantastic! What a great partnership for the TMA and its members!" ~ Michele Kuper, Director of Human Resources — Simmons Knife & Saw — Chicago, IL
SESCO's Exclusive Professional Service Agreement
4 Flex Consulting Hours
• Unlimited telephone and email consulting
• Employee Handbook Review
• Two free sets federal and state compliance posters
• Free SESCO HR forms and compliance publications
• Newsletters and Email Updates
• Reduced Project Fees
Call to Learn More 423-764-4127 or email: sesco@sescomgt.com
Special Thanks to New SESCO Clients!
Great Rivers Environmental Law Center
St. Louis, MO
Noah Horn Well Drilling, Inc.
Vansant, VA
Moore Tires
Rock Falls, IL
Ohio Alliance to End Sexual Violence
Independence, OH
Stringer Auto Repair, LLC
Johnstown, OH
Bamberg Board of Public Works
Bamberg, SC
Assured Insurance Consultants
Johnson City, TN
