11b. Memo
2023 Affirmative Action Program
COMMISSION AGENDA MEMORANDUM Item No. 11b BRIEFING ITEM Date of Meeting September 12, 2023 DATE: August 25, 2023 TO: Stephen P. Metruck, Executive Director FROM: George Gianacakos, Affirmative Action Program Manager, Human Resources Cynthia Alvarez, Sr. Manager Employee Relations, Human Resources SUBJECT: 2023 Port of Seattle Affirmative Action Program EXECUTIVE SUMMARY The purpose of this briefing is to present the Port Commission the key results of the Port of Seattle’s 2023 Affirmative Action (AA) Program. 2023 Key Highlights: • To meet the Office of Federal Contract Compliance Programs (OFCCP) AA reporting requirements, the Port creates annual AA plans for Women & Minorities (Executive Order 11246), Individuals with Disabilities (Section 503 of the Rehabilitation Act) and Protected Veterans (VEVRAA - The Vietnam Era Veterans' Readjustment Assistance Act). • Women at the Port of Seattle represent 32% of the workforce which is a 2% decrease from 2022. • Minorities at the Port of Seattle represent 34% of the workforce, which is a 1% decrease from 2022. • In the 2023 AA Plan for Women & Minorities, 13.3% of employees did not self-identify race in HCM. This number decreased from 16% in our 2022 AA Plan for Women & Minorities. • The Port’s AA Plan for Individuals with Disabilities includes an aspirational goal of 7% set by OFCCP for the representation of individuals with disabilities within each of the Port’s 17 EEO Job Group. The Port increased the overall representation of individuals with disabilities to 9% a 1.06% increase from last year. Twelve out of our 17 EEO Job Groups align with the 7% aspirational goal. • OFCCP set a 5.5% benchmark for the representation of VEVRAA-protected Veterans within each EEO Job Group. Port-wide, the overall representation of VEVRAA-protected Veterans is 8.86%, which is consistent with last year’s overall representation. Nine of the Port’s 17 EEO Job Groups meet or exceed the 5.5% benchmark. • The 2023 AA Plan for Women and Minorities continued to identify underutilization of women in the Technicians and Non-Commissioned Protective Services – Command EEO Job Groups. Talent Acquisition and Emerging Talent created a tracking system in workflow Template revised April 12, 2018. COMMISSION AGENDA – Briefing Item No. 11b Page 2 of 4 Meeting Date: September 12, 2023 to flag job openings in both EEO groups. They will continue to conduct targeted outreach and recruitment of women for vacant positions within the Technicians and Non- Commissioned Protective Service EEO Job Groups. • The Port’s 2023 EEO Compensation Analysis showed salary differences of more than 7.5% amongst some employees holding the same job. These differences impact employees regardless of race and gender. Human Resources is currently working on finalizing the pay equity methodology. Following the application of the pay equity analysis, we will create a plan to address discrepancies identified in the pay equity analysis. • AA Program Manager conducted a program audit to ensure full compliance with CFR 41 requirements of AA Programs as well as implement improvements in data collection for the 2024 plan year. • All Port job announcements include a statement on diversity, equity, and inclusion and Port Values. Additionally, all interviews include an equity, diversity, and inclusion question. ADDITIONAL BACKGROUND As a federal contractor, the Port of Seattle is required meet OFCCP’s AA reporting requirements, which includes the following: • Develop annual AA Plans for Women & Minorities, VEVRAA-Protected Veterans, and Individuals with Disabilities. • Conduct an annual EEO Compensation Analysis. • Monitor the effectiveness of the Port’s AA Program on a continuing basis through the development and implementation of an internal audit and reporting system that measures the program effectiveness. • Provide annual AA compliance training to employees involved in the recruitment, selection, promotion, performance management and related processes to include review of the three AA Plans, and their roles and responsibilities in its implementation to ensure women and minorities, individuals with disabilities, and protected veterans are treated in a non-discriminatory manner in all employment practices and business decisions. HOW RESULTS ARE MEASURED In accordance with OFCCP guidelines, on October 31st of each year the Port extracts employee data from our HRIS/Payroll system to compare the percentages of women and minorities in each of our 17 EEO Job Groups to the percentages of qualified women and minorities within the Port’s general recruitment area (King, Pierce, Snohomish, Thurston, and Kitsap counties). This type of review, comparing incumbency to availability (internal and external), is called a Utilization Analysis, and is required for only the AA Plan for Women & Minorities. An underutilization exists when the Utilization Analysis shows the percentage of women or minorities within an EEO Job Group is less than would be reasonably expected given the availability of qualified women and minorities within the employer’s workforce and externally within the employer’s recruitment area. Placement goals are set when an employer has an Template revised September 22, 2016. COMMISSION AGENDA – Briefing Item No. 11b Page 3 of 4 Meeting Date: September 12, 2023 underutilization within an EEO Job Group. A placement goal serves as target, not a quota or setaside , that employers make good faith efforts to meet. MOVING FORWARD The Port of Seattle’s Affirmative Action Program is aligned with our Port-wide Goals to Demonstrate Strong Commitment to Equity, Diversity, and Inclusion at the Port and Across the Region and to Operate as a Highly Effective Public Agency. The Port of Seattle will continue to improve its AA Program by doing the following: 1. Continue to ask employee to self-identify race, gender, disability status, and veteran status to reflect our workforce demographics more accurately within our 3 AA Plans. 2. Continue to partner with our colleagues in Talent Acquisition and Emerging Talent to identify recruitments for positions within the Technicians and Non-Commissioned Protective Service EEO Job Groups. Once identified, we will conduct targeted outreach and recruitment of women to ensure diverse applicant pools. 3. Continue targeted recruitment of women & minorities, individuals with disabilities, and Protected Veterans to ensure diverse applicant pools by attending job fairs and community events, offering internships/Vet-fellowships, and evaluating job descriptions to remove requirements which create artificial barriers. 4. Continue with Human Resources’ Compensation Project to address and resolve systemic pay equity issues. 5. Conduct annual audits of the 3 AA Plans to measures the program effectiveness. 6. Provide annual AA compliance training to employees to ensure women and minorities, individuals with disabilities, and protected veterans are treated in a non-discriminatory manner in all employment practices and business decisions. 7. Refresh Port-wide EEO compliance trainings, in consultation with ERGs and D&D Council, to ensure they are current with all applicable laws and regulations. 8. Continue to update HR and Code of Conduct policies to include a review of policies through an equity lens. Human Resources will continue to partner with Office of Equity, Diversity, and Inclusion (OEDI) to address institutional racism within the Port and to infuse equity in all our programs and business practices. The important work underway with the Compensation Project and Human Resources-related work stemming from the Equity Assessment and Women of Color Assessment serves and supports the fundamental purpose of affirmative action, which is to attract, hire, develop and retain a workforce that reflects the diversity of our community at all levels of the Port. ATTACHMENTS TO THIS BRIEFING (1) Presentation slides Template revised September 22, 2016. COMMISSION AGENDA – Briefing Item No. 11b Page 4 of 4 Meeting Date: September 12, 2023 PREVIOUS COMMISSION ACTIONS OR BRIEFINGS October 10, 2022 – 2022 AAP Commission Briefing January 4, 2022 – 2021 AAP Commission Briefing September 8, 2020 – 2020 AAP Commission Briefing Template revised September 22, 2016.
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