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Staff Report 5.B 07/06/2015 Staff Report and Plan
Agenda Item #5.B A L Ur I85$ DATE: July 6, 2015 TO: Honorable Mayor and Members of the City Counci t ugh the City Manager FROM: Dianne Dinsmore, Director of Human Resources SUBJECT: Resolution Adopting the January 1, 2015 Through December 31, 2016, City of Petaluma Equal Opportunity Plan. RECOMMENDATION It is recommended that the City Council adopt the attached Resolution Adopting the January 1, 2015 Through December 31, 2016 City of Petaluma Equal Opportunity Plan. BACKGROUND As a federal contractor receiving $50,000 or more in annual contracts with the federal government and employing 50 or more employees, the City is required to prepare a written Equal Opportunity Plan (Plan). Failure to comply with these laws and their implementing regulations, which are enforced by the Office of Federal Contract Compliance Programs (OFCCP), can result in debarment of the City from future contracts and subcontracts. The Human Resources Department has collaborated with the City Manager and department management to develop the 2015 - 2016 Plan in conformance with the requirements and intentions of Title VII of the Civil Rights Act, Executive Order 11246, as well as Section 402 of the Vietnam Era Veterans Readjustment Assistance Act of 1974, Section 4212 and Section 503 of the Rehabilitation Act of 1973 as amended. The purpose of the 2015 - 2016 Plan is to promulgate employment policies and practices regarding nondiscrimination and to promote equal opportunity. DISCUSSION On March 2, 2015, the City Council adopted its Goals and Priorities for 2015 and 2016. Among these was the development of a robust Equal Opportunity Plan. The City engaged Biddle Consulting Group, Inc. (Biddle) to conduct an availability and incumbency analysis, the basis for this Plan. Availability is the number and demographics of qualified individuals in the City's labor market. Responses to the United States Census Long Form is used to identify qualified individuals. Incumbency is the number and demographics of current City employees. Preliminary results were presented at the April 13, 2015 Council Workshop. The Council posed a number of questions related to methodology, including, in particular, what information is collected on the long form. In a follow up memorandum, included as Attachment 2 to this report, Biddle clarified that the Census long form "asks respondents, among other questions, to identify his/her occupation (for example, firefighter, registered nurse, administrative assistant, etc.). These responses are then gathered and assigned an SOC [Standard Occupational Classification] (i.e., Census codes)." The Bureau of Labor Statistics' website decribes the Standard Occupational Classification system as follows: "The 2010 Standard Occupational Classification (SOC) system is used by Federal statistical agencies to classify workers into occupational categories for the purpose of collecting, calculating, or disseminating data. All workers are classified into one of 840 detailed occupations according to their occupational definition. To facilitate classification, detailed occupations are combined to form 461 broad occupations, 97 minor groups, and 23 major groups. Detailed occupations in the SOC with similar job duties, and in some cases skills, education, and/or training, are grouped together. The SOC Classification Principles form the basis on which the SOC system is structured." Each City job title is assigned an SOC code. Biddle concludes, "In short, the internal workforce is compared to the external workforce information (i.e., census data) of individuals who responded, via the survey, that they hold the same /similar job (i.e., qualified) as the incumbents." This comparison of incumbency, (internal workforce) and availability (external workforce) is used to determine whether the City is "at parity" or "underutilized" in a particular j ob group. If the City is at parity, it means incumbency is equal to or greater than availability. If the City is underutilized, it means incumbency is below availability. In addition, the Council asked for clarification and further refining of the City's labor market, initially reflected as Local (Sonoma County) and Reasonable (outside Sonoma County). Biddle ran a detailed zip code analysis and further refined the City's labor market. The analysis found the majority of City applicants come from California. Therefore, Reasonable has been broken out into California - Reasonable and National- Reasonable to more accurately reflect the City's true labor market. The Council also asked whether it was possible to break job groups out to reflect law enforcement and fire service separate from general employees. The analysis was revised to incorporate this request. Biddle also conducted an applicant flow analysis, which determines whether adverse impact has occurred anywhere in the screening and selection process. The Equal Employment Opportunity Commission's (EEOC) Uniform Guidelines on Employee Selection Procedures describe adverse impact as "a substantially different rate of selection in hiring, promotion or other employment decision which works to the disadvantage of members of a race, sex or ethnic group." Human Resources met with each Department to discuss results and identify action - oriented programs. The City has designed Action - Oriented Programs to address identified underutilization. A number of these Programs reflect best practices for all recruitment and selection activity, such as: • Advertising in publications that reach underrepresented groups, as appropriate • Reviewing recruitments after a selection has been made to identify effective practices, potential deficiencies and possible improvements in the hiring process. • Ensure recruitment materials and selection processes reflect the actual work requirements of the essential job duties • Encourage managers and supervisors to discuss their employee's career goals and help develop and record plans for them to achieve them. Others are tailored to address the unique needs of individual departments when underutilization has been noted in a particular area. For example: • The City will contact other agencies in the North Bay to gather information about the demographic makeup of their public safety applicant pools. This data will be compared to the demographics of the City of Petaluma's applicant pool. If the City's pool is found to be less diverse, further analysis will be done to identify what is different about those agencies and strategies for increasing the diversity of the City's applicant pool • Employees reflecting the diversity of the labor market will be made available for participation in Career Days, Youth Motivation Programs, and related activities in the community, when possible • The City will reach out to career services and recruit at universities, community colleges, and other post -high school educational institutions in the region, such as Police Academies, that have diverse student bodies and include underrepresented groups • The City will make an affirmative effort to establish interview panels that reflect the diversity of the labor market A complete description of these Programs can be found at Chapter 10 of the Equal Opportunity Plan Narrative. An Equal Opportunity Plan is not a static document, nor is a one -time project. It must be updated annually. It requires regular analysis of the results of our efforts undertaken in the Action - Oriented Programs and adjustment of our approach, processes and procedures based on the findings. The outcome of our efforts are reflected in the next Plan, and new Action - Oriented Programs are developed. Each subsequent Plan will be brought before the City Council for adoption. An Equal Opportunity Plan is an ever - evolving process with the goal of ensuring equal employment and promotional opportunities to all City employees and applicants for employment is a reality. FINANCIAL IMPACTS There is no financial impact with this adoption. The consultant cost for preparation of the plan was $3,100, and was funded from the Risk Management operating budget. ATTACHMENTS 1. Resolution 2. Biddle Memorandum Explaining Elements of the City of Petaluma's EEOP 3. Equal Opportunity Plan Narrative ® Items listed below are large in volume and are not attached to this report, but may be viewed in the City Clerk's office. City of Petaluma 2015/2016 Equal Opportunity Plan Exhibits ray ATTACHMENT 1 Resolution No. 2015 -XXX N.C.S. of the City of Petaluma, California RESOLUTION ADOPTING THE JANUARY 1, 2015 THROUGH DECEMBER 31, 2016, CITY OF PETALUMA EQUAL OPPORTUNITY PLAN WHEREAS, the City is a federal contractor receiving $50,000 or more in annual contracts with the federal government and employing 50 or more employees and, therefore, is required to prepare a written Equal Opportunity Plan (EOP); and, WHEREAS, failure to comply with these laws and their implementing regulations, which are enforced by the Office of Federal Contract Compliance Programs (OFCCP), can result in debarment of the City from future contracts and subcontracts; and, WHEREAS, on March 2, 2015, the Council adopted its Goals and Priorities for 2015 and 2016 which included the development of a robust Equal Opportunity Plan; and, WHEREAS, the 2015 - 2016 Plan has been developed in conformance with the requirements and intentions of Title VII of the Civil Rights Act, Executive Order 11246, as well as Section 402 of the Vietnam Era Veterans Readjustment Assistance Act of 1974, Section 4212 and Section 503 of the Rehabilitation Act of 1973 as amended; and, WHEREAS, the purpose of the 2015 - 2016 Plan is to promulgate employment policies and practices regarding nondiscrimination and to promote equal opportunity. NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Petaluma: Adopts the Equal Opportunity Plan for the City of Petaluma covering the time period January 1, 2015 to December 31, 2016; and, 2. Directs the City.Manager to implement the Plan. ATTACHMENT 2 City of Petaluma 11 English Street Petaluma, CA 94952 Re: Explaining Elements of the City of Petaluma's EEOP Purpose: BCG (Biddle Consulting Group, Inc.), analyzed data, prepared reports and delivered the results of the City's (City of Petaluma's) Equal Employment Opportunity Plan to the City Council, in collaboration with the City's Department of Human Resources, at a City Council workshop, on April 13`h, 2015. Upon completion of the Workshop, several exploratory questions remained: 1. How is the availability group determined? What is standard and required by Feds for this reporting? Do they define Local vs. Reasonable? Or is that part of Biddle methodology? 2. The City casts a broad recruiting net for certain positions and receives applications nation -wide. At the same time the City fills many positions from the local labor market and occasionally fills positions from a recruitment area as broad as the entire State of California. The City's challenge —when jobs are combined into a single job group but the jobs are filled from various labor markets how are the external availability weights (e.g. Local vs. Reasonable) applied? 3. How is someone identified as qualified in the Census? We would like a description and example from the Census long form. 4. How are those census codes applied? 5. We were surprised to see that for Skilled Craft (7A), the minority availability was higher in local vs. reasonable. Why the anomaly? 6. During the initial project launch phone call, it was pointed out that there was no way to separate out completely unqualified applicants from minimally qualified applicants, and therefore all applicants were going to be sent in the data file we provided. Since adverse impact was indicated in one job group, at first blush I am not too concerned about that. However, would that be seen as a fatal flaw? The following provides responses to each of the questions above. 1. How is the availability group determined? What is standard and required by the DOL for this reporting? Do they define Local vs. Reasonable? Or is that part of Biddle methodology? The following excerpt is pulled directly from the OFCCP's website (edited for readability) regarding Job Groups Availability Determinations found here: http : / /www.dol.gov /ofccp /scaap.htm. The same logic used to create an AAP is applied to an EEOP. a. Job Grouping: Federal contractors are required to establish AAP job groups and compare their 193 blue ravine road suite 270 . folsom, ca 95630 toll free: 800 999 0438 .biddle,cor0 f employment of minorities and women within those job groups to the availability of minorities and women who are "available "for employment. Job groups are jobs that are grouped based on three factors: L similar wages; ii. similar job duties and responsibilities; and iii: similar opportunities for training, promotion, transfer, and other employment benefits. Each job title in an establishment should be placed into a job group. These are called 'AAP Job Groups. " b. Job group - availability comparison: In order to make the job group- availability comparison, federal contractors must conduct availability analyses to determine the percentage of women and minorities who have the skills required to perform the jobs within each job group. The purpose of the availability analyses is to estimate the percentage of minorities and women among those qualified for employment for each job group. Availability involves calculation of minorities and women who are "available" to work in the job from both external sources (i.e., hired from outside the company) and internal sources (e.g., transfer or promotion of existing employee in the company). L External availability -For calculating "external" availability, you want to consider who is qualified for the job within "the reasonable recruitment area "for thatjob. The "reasonable recruitment area" represents the area from which a contractor usually seeks or reasonably could seek workers for a particular job group. ii. Internal availability - Internal availability involves the percentage of minorities and women inside a contractor's workforce who are considered promotable, transferable and trainable for a particular job group. This means the percentage of minorities and women who are in 'feeder "jobs or job groups who are (at the start of the AAP year), or who will become (during the AAP year) promotable or transferable from a current job or job group into another job group. This factor also requires an assessment of the number of employees who could, with appropriate training (that a contractor is reasonably able to provide), become promotable or transferable during the AAP year. iii. External vs. Internal Weighting - OFCCP recommends weighting the external percentage factor and the internal percentage factor by historical usage patterns to reflect the proportion of incumbents hired or to be hired from external sources and the proportion from internal sources. For 193 blue ravine road sulte 270 folsom; ca 95.630 toll free: 800 999 0438 v .b ddle. r �€ example, 1. In entry job groups, you may always hire from outside. The external factor will therefore become the entire availability. 2. For other job groups, you may have hired from the outside 10% of the time over the last several years, but promoted from the inside 90% of the time. Each of your availability factors should then be weighted accordingly i.e., in our example the external percentage is multiplied by 10% and added to the internal percentage after it has been multiplied by 90% to come up with a final availability percentage. 2. The City casts a broad recruiting net for certain positions and receives applications nation -wide. At the same time, the City fills many positions from the local labor market and occasionally fills positions from a recruitment area as broad as the entire State of California. The City's challenge —when jobs are combined into a single job group but the jobs are filled from various labor markets, how are the external availability weights (e.g. Local vs. Reasonable) applied? The appropriate way to determine factor weights is to ask oneself: "Hypothetically, if there were 100 vacancies in a given job group, how these vacancies would get filled? Will it be via local areas, through reasonable area(s) or internally ?" Sure, recruitment areas are considered (local, reasonable, internal), but the weighting ( %) should really depend more on how often these areas typically contribute to the job group in question. If positions are equally recruited with both local and national outreach, but history suggests that these positions are being filled more often through local areas, then the local factor should reflect this by being weighted higher than the national factor. 3. How is someone identified as qualified in the Census? We would like a description and example from the Census long form. The Census long form asks the respondents, among other questions, to identify his/her occupation (for example, firefighter, registered nurse, administrative assistant, etc.). These responses are then gathered and assigned an SOC (i.e., Census codes). The EEOP uses this occupational data to compare the organization's workforce against. In short, the internal workforce is compared to the external workforce information (i.e., census data) of individuals who responded, via the survey, that they hold the same /similar job (i.e., qualified) as the incumbents. A copy of the Census Long form can be found here: b=s://www.census.p-ov/dmd/Wmy/pdf/d-61b.pd f 4. How are those census codes applied? Each occupied job title in the job group needs to be assigned a Census code. The Census code is a Standard Occupational Classification code assigned by the Census Bureau to jobs gathered through the Census. Below is an explanation from the Bureau of Labor Statistics 193 blue ravine roast suite 270 folsorn, ca 95630 toll free: 800 999 0438 w_wwbilddlexorn F r b 1* d d- I e (http: / /www.bls.gov /socn: opportunity, f0T all. Standard Occupational Classification (SOC) system: The 2010 Standard Occupational Classification (SOC) system is used by Federal statistical agencies to classify workers into occupational categories for the purpose of collecting, calculating, or disseminating data. All workers are classified into one of 840 detailed occupations according to their occupational definition. To facilitate classification, detailed occupations are combined to form 461 broad occupations, 97 minor groups, and 23 major groups. Detailed occupations in the SOC with similar job duties, and in some cases skills, education, and/or training, are grouped together. SOC Classification Principles - The SOC Classification Principles form the basis on which the SOC system is structured. 1. The SOC covers all occupations in which work is performed for pay or profit, including workperformed in family- operated enterprises by family members who are not directly compensated. It excludes occupations unique to volunteers. Each occupation is assigned to only one occupational category at the lowest level of the classification. 2. Occupations are classified based on workperformed and, in some cases, on the skills, education, and/or training needed to perform the work at a competent level. 3. Workers primarily engaged in planning and directing are classified in management occupations in Major Group 11 -0000. Duties of these workers may include supervision. 4. Supervisors of workers in Major Groups 13 -0000 through 29 -0000 usually have work experience and perform activities similar to those of the workers they supervise, and therefore are classified with the workers they supervise. 5. Workers in Major Group 31 -0000 Healthcare Support Occupations assist and are usually supervised by workers in Major Group 29 -0000 Healthcare Practitioners and Technical Occupations. Therefore, there are no first -line supervisor occupations in Major Group 31 -0000. 6 Workers in Major Groups 33 -0000 through 53 -0000 whose primary duty is supervising are classified in the appropriate first -line supervisor category because their work activities are distinct from those of the workers they supervise. 7. Apprentices and trainees are classified with the occupations for which they are being trained, while helpers and aides are classified separately because they are not in training for the occupation they are helping. 8. If an occupation is not included as a distinct detailed occupation in the structure, it is classified in an appropriate "All Other, " or residual, occupation. "All Other" occupations are placed in the structure when it is determined that the detailed occupations comprising a broad occupation group do not account for all of the workers in the group. These occupations appear as the last occupation in the group 193 blue ravine road suite 270. folsom; ca 9$630 toll free: 800 999 0439 i {; a Ilk with a code ending in "9" and are identified in their title by having "All Other" appear at the end. 9. The U.S. Bureau of Labor Statistics and the U.S. Census Bureau are charged with collecting and reporting data on total U.S. employment across the full spectrum of SOC major groups. Thus, for a detailed occupation to be included in the SOC, either the Bureau of Labor Statistics or the Census Bureau must be able to collect and report data on that occupation. SOC Coding Guidelines - The SOC Coding Guidelines are intended to assist users in consistently assigning SOC codes and titles to survey responses and in other coding activities. 1. A worker should be assigned to an SOC occupation code based on work performed. 2. When workers in a single job could be coded in more than one occupation, they should be coded in the occupation that requires the highest level of skill. If there is no measurable difference in skill requirements, workers should be coded in the occupation in which they spend the most time. Workers whose job is to teach at different levels (e.g., elementary, middle, or secondary) should be coded in the occupation corresponding to the highest educational level they teach. 3. Data collection and reporting agencies should assign workers to the most detailed occupation possible. Different agencies may use different levels of aggregation, depending on their ability to collect data. For more information on data produced using the SOC, see the Frequently Asked Questions (FAQs) section. 4. Workers who perform activities not described in any distinct detailed occupation in the SOC structure should be coded in an appropriate "All Other" or residual occupation. These residual occupational categories appear as the last occupation in a group with a code ending in "9" and are identified by having the words "All Other" appear at the end of the title. 5. Workers in Major Groups 33 -0000 through 53 -0000 who spend 80 percent or more of their time performing supervisory activities are coded in the appropriate first -line supervisor category in the SOC. In these same Major Groups (33 -0000 through 53- 0000), persons with supervisory duties who spend less than 80 percent of their time supervising are coded with the workers they supervise. 6. Licensed and non - licensed workers performing the same work should be coded together in the same detailed occupation, except where specified otherwise in the SOC definition. 193 blue ravine road suite 270 . folsom, ca 95630 toll free, Boo 999 0438 www.biddle.com 5. We were surprised to see that for Skilled Craft (7A), the minority availability was higher in local vs. reasonable. Why the anomaly? This is a reflection of California's diversity, which can be evidenced through comparisons to other geographic areas. The tables below demonstrate the range of Local, State and National external availabilities. Table 1 represents the external availabilities of Sonoma and surrounding counties identified in the Zip Code Analyses (also referred to as Local Labor Area), Table 2 represents the external availabilities for the State of California, and Table 3 represents the external availabilities for the entire U.S. (also referred to as National) used for "7A — Skilled Craft". Interpreting Tables 1 -3: Job Group — identifies the specific job group under analyses Labor Area — defined geographic labor market Cns Cde - census code assigned to each job title within the job group (jobs without incumbents are excluded from the availability analyses). Census Code Title - Census Code Titles as defined in the U.S. Census Tables. These should not be confused with the job titles used by the City. Wght( %) - weighted percentage of incumbents within the job group by census code. Example - 19 of 36 incumbents in this job group were assigned to Census Code 7100 (19/36 = 0.5277 or approximately 52.78 %). Raw(%) — according to the US Census Tables, this represents the availability percentages of Men/Female and eight race categories. Weighted(116) — this represents the external availability percentages to which incumbents are compared. Raw( %) x Wght( %) = Weighted ( %) Table 1 Sob Group-. 7A- SkiledCraft Labor Area: See �p Gode Anatys Cns Wght Raw (461 Weighted j%) Cde Census CodeTrtte ON M F MW W AA N A HA PI 2- M FM W AA H A NA P1. 2- 7300 Con`uo1arAv.W0nsW1- andre 7700 First-fm peavisors of production 7730 Engine and ether machi a amm 193 blue ravine road suite '270. folsi m, CA 95630 toll free: 800 999 0439 0.0 4.7 0.0 wwwbiddlezorn t, r, TAIP. 2• Tnhla 'I LatrorArea: rvaaaaa: CDs Wght RaW'1%i Weighted 1 %} Cde Census Cade Title N M F MIH W AA H A HA P1 2+ M FM W AA H A MA PI 2+ 7100 E -&Wc d and Gechon cs repakers 1 52.781 96.51 35 17.9 621 1 7.51 5.81 251 0.81 0.1 1 1.21 50.91 1.8 9.41 43.31 3-91 3.1,1 1.s I ©4 I 0 0 I „ 0.6 7340' Ma eAenarrce and re{x+ rvmri ers, g 5.561 96 5' 3.5 29.5 70.51 9.51 15.11 261 0.81 0.31 1.11 5.41 02 1.8 3.91 0.51 0.81 0.11 0.01 0.01 0.1 Etedncat, electrmics; wW e€echom 5.58 44.8 542 51.9 48.1 13.1 19.5 17.5 0.8 0.1 1.1 25 3.1 29 27 0.7 1.1 1.0 0. BUD Water andwa*water he&n`ntp 6. As a reminder, during the initial project launch phone call, it was pointed out that we did not have a way to separate out completely unqualified applicants from minimally qualified applicants, and therefore all applicants were going to be sent in the data file we provided. Since we saw adverse impact only in one job group, at first blush I am not too concerned about that. However, would that be seen as a fatal flaw? Yes, the ability to track unqualified applicants from those who are relatively qualified is critical in understanding equal opportunity through the statistical analyses of employment practices, tests or procedures. UNIFORM GUIDELINES ON EMPLOYEE SELECTION PROCEDURES http://uniformL,uidelines.com/uniformLyuidelines.html#14 The Uniform Guidelines on Employee Selection Procedures, adopted on August 25, 1978, were designed to aid in the achievement of equal employment opportunity without discrimination on the grounds of race, color, sex, religion or national origin. Federal agencies have adopted the Guidelines to provide a uniform set of principles governing use of employee selection procedures which is consistent with applicable legal standards and validation standards generally accepted by the psychological profession and which the Government will apply in the discharge of its responsibilities. The Guidelines apply to employee selection procedures, which are used in making employment decisions, such as hiring, retention, promotion, transfer, demotion, dismissal 193 blue ravine road suite 270 folsvin, ca 95630 toll free: Boo 999 0438 www.biddle..com or referral. Section 2B. Employee selection procedures include job requirements (physical, education, experience), and evaluation of applicants or candidates on the basis of application forms, interviews, performance tests, paper and pencil tests, performance in training programs or probationary periods, and any other procedures used to make an employment decision whether administered by the employer or by an employment agency. Section 2: Scope. - C. Selection procedures. [... selection on the basis of relative qualifications, if the selection procedure had been validated in accord with these guidelines for each such purpose for which it is to be used.] Section 4: Information on impact - E. Consideration of user's equal employment opportunity posture. [... selection procedures... should be based upon the ability or relative ability to do the work.] Employers should track employments selection decisions through electronic means (e.g. applicant tracking software) and apply disposition codes at each phase of the selection process as applicants are eliminated from the process. The City does not have an electronic means for dispositioning applicants from the selection process and as a result, entire applicant pools were included in the Applicant vs. Hire analyses. As part of the `plan' for equal opportunity moving forward BCG recommends that the City 1) implement an applicant tracking software program and, 2) define, apply and disposition candidates based on a definition of an applicant for each open position. What is meant by the terms "applicant" and "candidate" as they are used in the Uniform Guidelines? http: / /www.dol.govlofccplregs /compliance /ags/ig ags.htm The precise definition of the term "applicant" depends upon the user's recruitment and selection procedures. The concept of an applicant is that of a person who has indicated an interest in being considered for hiring, promotion, or other employment opportunities. This interest might be expressed by completing an application form, or might be expressed orally, depending upon the employer's practice. The term "candidate" has been included to cover those situations where the initial step by the user involves consideration of current employees for promotion, or training, or other employment opportunities, without inviting applications. The procedure by which persons are identified as candidates is itself a selection procedure under the Guidelines. A person who voluntarily withdraws formally or informally at any stage of the selection process is no longer an applicant or candidate for purposes of computing adverse impact. Employment standards imposed by the user which discourage disproportionately applicants of a race, sex or ethnic group may, however, require justification. Records should be kept for persons who were applicants or candidates at any stage of the process. 193 blue ravine road suite 270 folsom, ca 95630 tall free: Boo 999 0438 .biddl ,0oln � vF °._. Madle Definition of an Internet Applicant"? 9PPortunity. , for all, http: / /www, dol. gov/ofccp/regs /compliance /fagLliappfaas. htm An "Internet Applicant" is an individual who satisfies all four of the following criteria: • The individual submitted an expression of interest in employment through the Internet or related electronic data technologies; • The contractor considered the individual for employment in a particular position; • The individual's expression of interest indicated that the individual possesses the basic qualifications for the position; and • The individual, at no point in the contractor's selection process prior to receiving an offer of employment from the contractor, removed himself or herself from further consideration or otherwise indicated that he /she was no longer interested in the position. 193 blue ravine road suite 270 folsoni; ca 95630 toll free: Soo 999 0439 YAw.biddle.com s ATTACHMENT 3 EQUAL EMPLOYMENT OPPORTUNITY PLAN for CITY OF PETALUMA 11 English Street PETALUMA, CA 94952 707 778 -4480 January 1, 2015 through December 31, 2016 AA/EEO Contact: Dianne Dinsmore Director of Human Resources CITY OF PETALUMA 11 English Street PETALUMA, CA 94952 707 778 -4343 EQUAL EMPLOYMENT OPPORTUNITY PLAN FOR CITY OF PETALUMA TABLE OF CONTENTS Background.................................................................................................. ............................... 3 Applicable Equal Employment Opportunity Laws and Regulations ........... ............................... 5 ProtectedGroups .......................................................................................... ............................... 5 ReportingPeriod .......................................................................................... ............................... 5 Tableof Contents ......................................................................................... ............................... 7 Chapter 1: Commitment to Equal Employment Opportunity ...................... ............................... 8 Chapter 2: Organizational Profile ................................................................ ............................... 9 Chapter3: Job Group Analysis .................................................................. ............................... 10 Chapter 4: Placement of Incumbents in Job Groups .................................. ............................... 11 Chapter 5: Determining Availability ......................................................... ............................... 12 Chapter 6: Comparing Incumbency to Availability ................................... ............................... 13 Chapter7: Placement Goals ....................................................................... ............................... 14 Chapter 8: Designation of Responsibility .................................................. ............................... 15 Chapter 10: Action - Oriented Programs ..................................................... ............................... 20 Chapter 11: Internal Audit and Reporting ................................................. ............................... 23 INTRODUCTION TO THE EEOP BACKGROUND Chartered in 1858 in the State of California, the City of Petaluma (City) is a Charter City under Article XI, § 3(a) of the California Constitution. The City is an Equal Employment Opportunity Employer and is committed to provide equal employment and promotional opportunities to all City employees and applicants for employment. The City believes in treating all people with respect and dignity. The purpose of the Equal Opportunity Plan (EOP) is to commit the City to a program that makes equal employment opportunity a reality for all City employees and qualified job applicants. The EOP provides the framework for the City policy of equal employment opportunity. The EOP is a coordinated program of policies, practices, procedures, and initiatives to ensure equal employment opportunity principles are ingrained in the City's recruitment, retention, selection, and advancement practices, as well as into all other aspects of the City's employment environment. These practices are applied without regard to race, color, national origin, religion, sex, gender identity, pregnancy, physical or mental disability, medical conditions (cancer- related or genetic characteristics), genetic information, ancestry, marital status, age (40 or older), sexual orientation, veterans, service in the military or any other characteristic protected by state and/or federal law. The City, as a federal contractor, is required by Executive Order 11246, as amended, and its implementing regulations, found at 41 CFR, Part 60 -2, to implement an annual plan. The Human Resources Department has developed the 2015 - 2016 EOP in conformance with the requirements and intentions of these governing authorities, as well as Section 402 of the Vietnam Era Veterans Readjustment Assistance Act of 1974, Section 4212 and Section 503 of the Rehabilitation Act of 1973 as amended. The purpose of the 2015 - 2016 Plan is to promulgate employment policies and practices regarding nondiscrimination and to promote equal opportunity. Because the City has $50,000 or more in annual contracts with the federal government and employs 50 or more employees, we are required to prepare annual written EOP's for minorities and women, for covered veterans, and for persons with disabilities both City -wide and for each City department. Failure to comply with these laws and their implementing regulations, which are enforced by the Office of Federal Contract Compliance Programs (OFCCP), can result in debarment of the City from future contracts and subcontracts. In compliance with Title VII of the Civil Rights Act, the City has developed this EOP in accordance with and in reliance upon the EEOC's Guidelines on Affirmative Action, Title 29 Code of Federal Regulations, Part 1608. A prerequisite to the development of a satisfactory Equal Employment Opportunity Plan is the evaluation of employment opportunities, as well as an identification and analysis of any areas where incumbency does not reflect availability. Also, where a statistical analysis of the employee workforce reveals a numeric disparity between incumbency and availability, an adequate Equal Employment Opportunity Plan will detail specific Equal Employment Opportunity steps to guarantee equal employment opportunity. Such steps include the development of hiring and promotion goals to mitigate the disparity between incumbency and availability. It is toward this end that the following Equal Employment Opportunity Plan for the City of Petaluma was developed. The Plan is available for review in the Human Resources Department. APPLICABLE EQUAL EMPLOYMENT OPPORTUNITY LAWS AND REGULATIONS PROTECTED GROUPS Coverage under Equal Employment Opportunity laws and regulations applies to: Women and minorities who are recognized as belonging to or identifying with the following race or ethnic groups: Blacks /African Americans, Hispanics /Latinos, Asians, Native Hawaiians or Pacific Islanders, American Indians or Alaskan Natives, and Two or More, i.e. mixed races. State law, as well as City of Petaluma policy, prohibit discrimination based on: Race, color, national origin, religion, sex, gender identity, pregnancy, physical or mental disability, medical conditions (cancer - related or genetic characteristics), genetic information, ancestry, marital status, age (40 or older), sexual orientation, veterans, service in the military or any other characteristic protected by state and federal law. An individual with a disability is defined as a person who has a physical or mental impairment that substantially limits one or more of his/her major life activities; (2) has a record of such impairment, or (3) is regarded as having such an impairment. REPORTING PERIOD This Equal Employment Opportunity Plan is designed to cover the following reporting period: January 1, 2014 — December 31, 2014. EQUAL EMPLOYEMENT OPPORTUNITY PLAN FOR CITY OF PETALUMA JANUARY 1, 2015 THROUGH DECEMBER 31, 2016 rr EQUAL EMPLOYMENT OPPORTUNITY PLAN TABLE OF CONTENTS CHAPTER 1: COMMITMENT TO EQUAL EMPLYMENT OPPORTUNITY CHAPTER 2: WORKFORCE ANALYSIS /ORGANIZATIONAL PROFILE CHAPTER 3: JOB GROUP ANALYSIS CHAPTER 4: PLACEMENT OF INCUMBETS IN JOB GROUPS CHAPTER 5: DETERMINING AVAILABILTY CHAPTER 6: COMPARING INCUMBANCY TO AVAILABILITY CHAPTER 7: PLACEMENT GOALS CHAPTER 8: DESIGNATION OF RESPONSIBILITIES CHAPTER 9: IDENTIFICATION OF PROBLEM AREAS CHAPTER 10: ACTION ORIENTED PROGRAMS CHAPTER 11: INTERNAL AUDITING AND REPORTING SYSTEMS J CHAPTER 1: COMMITMENT TO EQUAL EMPLOYMENT OPPORTUNITY The City of Petaluma reaffirms its commitment to a policy of equal employment opportunity. The City of Petaluma will continue to administer its personnel policies and conduct its employment practices in a manner that treats each employee and applicant for employment on the basis of merit, experience, and other work related'criteria, without regard to race, color, national origin, religion, sex, gender identity, pregnancy, physical or mental disability, medical conditions (cancer- related or genetic characteristics), genetic information, ancestry, marital status, age (40 or older), sexual orientation, veterans, service in the military or any other characteristic protected by state and federal law. The City of Petaluma is committed to maintaining a meaningful, result - oriented Equal Employment Opportunity Plan in order to achieve a balanced workforce that reflects the workforce composition of the City's relevant labor market. It is the responsibility of the Human Resources Department, in conjunction with the City operating departments and under the general direction of the City Manager, to ensure the spirit and intent of the Equal Employment Opportunity Plan is carried out. The City of Petaluma designates the Human Resources Director to also serve as the Equal Employment Opportunity Officer, and will focus its Equal Employment Opportunity efforts on enhanced outreach and training programs. The City of Petaluma is committed to making a good faith effort to successfully achieve Equal Employment Opportunity. John C. Brown, City Manager CHAPTER 2: ORGANIZATIONAL PROFILE Workforce Analysis/Lines of Progression The City of Petaluma conducted a workforce analysis to identify employees by gender and race /ethnicity in each job title. The data was collected from payroll records dated 01/01/2015. Job titles are listed by organizational unit. Job titles are listed from lowest to highest paid. The list includes all job titles, including departmental supervision, exempt, and nonexempt titles. For each job title identified the total number of employees, the number of female and male employees, the total number of minority employees, the female and male minority employees, the total number of American Indian or Alaskan Native, Asian, Black, Hispanic, Native Hawaiian or Pacific Islander, White, and Two or More, i.e. mixed races, and the female and male employees within each of these race /ethnic groups. Lines of Progression Developed in conjunction with the workforce analysis is information on the City of Petaluma's lines of progression. Lines of progression (career ladders /career paths) identify the job titles through which an employee can move to the top of a line. For each line of progression, applicable departments are identified. These are the departments that employ persons in the job titles in the specified line of progression. Some lines of progression are limited to only one department, while others are found throughout several departments. The lines of progression provide useful information regarding patterns of vertical and horizontal movement throughout our workforce. These patterns will be evaluated to ascertain whether they provide to our employees the optimum career mobility and opportunities for advancement. See the Workforce Analysis/Lines of Progression for each organizational unit. Exhibit 1 CHAPTER 3: JOB GROUP ANALYSIS Although the workforce analysis was conducted individually for every job title, after it was completed, job titles were grouped for the comparison of incumbency to availability and for setting goals. There were several reasons for grouping jobs. Many job titles are so similar in content that handling them individually in the Equal Employment Opportunity Plan is not necessary. Grouping together these very similar titles is appropriate for the comparison of incumbency to availability. For many job titles, the availability data that can be collected is limited, and the same data must be used for several related jobs. Therefore, grouping these related titles together is logical. Also, many job titles have so few incumbents in them that identifying disparities between incumbency and availability by job title is not useful —as problem areas would be identified in terms of fractions of 'people. By grouping several similar titles and increasing the number of employees involved, a meaningful comparison can be conducted; any identified problem areas are more likely to be in terms of whole people. Consequently, goals established to correct problem areas are also more likely to be in terms of whole people. The three reasons for grouping job titles all discuss "similar" or "related" jobs. That is the most critical guideline in creating job groups. Above all, the job titles placed into a job group must be more similar or related to each other than the job titles in other job groups. With this in mind, law enforcement and firefighter positions were established as sub - categories within the broader job groups. Job groups must have enough incumbents to permit meaningful comparisons of incumbency to availability and goal setting. Ideally, if a job group is identified as containing a problem area, it should be large enough that a goal of a least one whole person can be established. No minimum size has been established for this purpose, however, since it is dependent not only on the size of the job group, but also on the size of the availability percentage and the number of minorities or women already employed in the job group. It may not be possible for a smaller organization's job groups to meet the guideline of not crossing EEO categories. While there are usually two or more job groups within each EEO -4 category, for smaller organization's some or all of their job groups may correspond to EEO -4 categories. The CITY OF PETALUMA did not combine job titles with different content, wages, or opportunities if doing so would have obscured problem areas (e.g., job groups which combine jobs in which minorities or women are concentrated with jobs in which they are underrepresented). CHAPTER 4: PLACEMENT OF INCUMBENTS IN JOB GROUPS Each job group appears on a Job Group Report with a job group name and number. The report lists each job title in the job group. For each job title, the worksheet provides the following information: EEO reporting category, pay grade, job title, employee headcounts for each job title, and overall percentages by gender and race /ethnicity as of 01/01/2015. See the Job Group Analysis for the listing of the job titles and the associated race and gender headcounts per job group. Exhibit 2 CHAPTER 5: DETERMINING AVAILABILITY "Availability" is an estimate of the proportion of each sex and race /ethnic group available and qualified for employment at CITY OF PETALUMA for a given job group in the relevant labor market during the life of the Equal Employment Opportunity Plan. Availability indicates the approximate level at which each race /ethnic and sex group could reasonably be expected to be represented in a job group. Availability estimates, therefore, are a way of translating equal employment opportunity into numerical terms. Correct comparisons of incumbency to availability, worthwhile and attainable goals, and real increases in employment for where dependency is below availability depend on competent and accurate availability analyses. With valid availability data, we can compare the percentages of those who could reasonably be expected to be employed versus our current employment (from the workforce analysis), identify problem areas or areas of deficiency, and establish goals to correct the problems. Steps in Comparison of Incumbency to Availability Identify Availability Factors The following availability factors are required of federal government contractors for consideration when developing availability estimates for each job group: 1. External Factor: The external requisite skills data comes from the 2010 Census of Population. A. Local labor area: An employee residence zip code analysis was conducted to identify the local labor areas. See the Zip Code Analysis. For the purposes of this plan, the Local labor area is defined as Sonoma County. B. Reasonable labor area: For the purposes of this plan, based on zip code analysis of applicants, two Reasonable labor areas have been identified and are defined as 1) All of California outside of Sonoma County, and 2) National. 2. Internal Factor: The percentage of minorities or women among those promotable, transferable, and trainable within the contractor's organization. See the Internal Availability Analysis for more detail. Assign Internal and External Factor Weights: Weights were assigned to each factor for each job group. A combination of historical data and experience were used to determine the weights. Weights were never assigned in an effort to hide or reduce problem areas. Identify Final Availability: Weights were multiplied by the component - specific data to produce weighted data for each component. Weighted data for each component was summed. This produced a final availability estimate for each sex and race /ethnic group, as well as for minorities in the aggregate. See the Availability Analysis for the availability breakdown for each job group. Exhibit 3 CHAPTER 6: COMPARING INCUMBENCY TO AVAILABILITY Once final availability estimates were made for each job group, CITY OF PETALUMA compared the percentage of incumbents in each job group to their corresponding availability. A comparison was made between the percentage employed as of January 1, 2015 and that group's final availability. See the Comparison of Incumbency to Availability for the results per job group. Exhibit 4 .A; CHAPTER 7: PLACEMENT GOALS CITY OF PETALUMA has established a percentage placement goal whenever it found that incumbency within a job group was less than would reasonably be expected given availability. In each case, the goal was set at the availability figure derived for women and/or minorities, as appropriate for that job group. These goals take into account the availability of basically qualified persons in the relevant labor area. However, it should be noted that in the majority of cases, the number of hires required to match availability would exceed the number of vacancies. The City's progress toward these goals must be measured over time in step with the City's turnover. Goals are not rigid and inflexible quotas which must be met, but are instead targets reasonably attainable by means of applying every good faith effort to make all aspects of the entire Equal Employment Opportunity Plan work. These goals will be reached primarily through recruiting, advertising, and outreach to increase the diversity of the applicant pool and through implementation of our action - oriented programs (see Chapter 9). Selections will occur only from among qualified 'applicants. Goals do not requite the hiring of a person when there are no vacancies or the hiring of a person who is less likely to do well on the job ( "less qualified ") over a person more likely to do well on the job ( "better qualified "), under valid selection procedures. Goals do not require that CITY OF PETALUMA hire a specified number of individuals of a particular gender or ethnicity. A goal is a guidepost against which CITY OF PETALUMA, a community group, or a compliance agency can measure progress toward parity in the CITY OF PETALUMA's workforce as compared to availability. By setting realistic goals, CITY OF PETALUMA should be able to meet the goals, assuming we conduct effective recruitment, advertising and assessment efforts. See the Placement Goals report for each job group. Exhibit 4 CHAPTER 8: DESIGNATION OF RESPONSIBILITY As part of its efforts to ensure equal employment opportunity to all individuals, the CITY OF PETALUMA has designated specific responsibilities to various staff to ensure the EEOP focuses on all components of the employment system. To that end, the City Manager, the Director of Human Resources, also designated as the City's Equal Employment Opportunity Officer, and those employed as department heads, managers, supervisors and all City employees have undertaken the responsibilities described below. City Manager The primary responsibility and accountability for implementing the EEOP rests with the City Manager. This person is responsible, through the Human Resources Director/Equal Opportunity Officer, for adherence to the CITY OF PETALUMA's policy of equal employment opportunity and affirmative action. This role includes, but is not limited to, the following duties: Designate appropriate personnel with the responsibility for overseeing, administering, implementing, and monitoring CITY OF PETALUMA's EEOP. Ensure that these personnel are identified in writing by name and job title. 2. Ensure that those designated personnel responsible for all EEOP components are given the necessary authority and top management support to successfully implement their assigned responsibilities. 3. Impart the personal direction that ensures total involvement and commitment to equal employment opportunity programs through CITY OF PETALUMA's EEOP. Director of Human Resources/Equal Opportunity Officer The Director of Human Resources/Equal Opportunity Officer is responsible for overall supervision of the EEOP. The Director of Human Resources/Equal Opportunity Officer ensures, through department heads, managers and supervisors, that all relevant policies and procedures are adhered to. Successful implementation of this program is a basis for evaluating the Director of Human Resources/Equal Opportunity Officer's effective work performance. The Director of Human Resources/Equal Opportunity Officer's responsibilities include, but are not limited to, the following: 1. Ensure that the CITY OF PETALUMA adheres to the stated policy of equal employment opportunity, and monitor the application of equal employment opportunity policies. 2. Ensure that the EEOP is reviewed and updated in accordance with the CITY OF PETALUMA's stated policy. 3. Participate in regular and as- needed periodic discussions with department heads, management, supervision, and all other employed personnel to ensure EEOP and equal employment opportunity policies are being followed. 4. Review the qualifications of all employees to ensure equitable opportunity, based on job - related employment practices, is given to all for transfers and promotions. 5. Conduct periodic audits of: 1) training programs and hiring and promotion patterns to remove impediments to the attainment of EEOP goals and objectives, 2) facilities to ensure they are maintained for the use and benefit of all employees and integrated both in policy and practice, and 3) sponsored educational, training, recreational, and social activities to ensure that all employees are encouraged to participate in accordance with policies on non - discrimination. 6. Ensure that all new employees receive as part of the new employee orientation process an explanation the CITY OF PETALUMA's equal employment opportunity policy and that they are informed with regard to the EEOP and its objectives. 7. Periodically analyze applicant flow to determine the mix of persons applying for employment by race /ethnic origin and gender. 8. Ensure that recruitment advertising is placed in appropriate publications to invite a diverse applicant pool, whenever applicable. 9. Review all job descriptions and specifications to ensure they are free of discriminatory provisions and artificial barriers. Ensure all requirements are job - related and reflect the actual work requirements of the essential job duties. In addition, as Equal Opportunity Officer, the Director of Human Resources/Equal Opportunity Officer's duties include, but are not limited to, the following: Provide direction to the CITY OF PETALUMA's employees, as necessary, to carry out all actions required to meet the organization's equal employment opportunity and affirmative action commitments. 2. Review, report on, and update the CITY OF PETALUMA's EEOP at least on an annual basis in accordance with stated policy. 3. Responsible for the design and effective implementation of the EEOP at all establishments. 4. Develop, implement, and maintain audit and reporting systems to measure effectiveness of equal employment opportunity programs, including those that will indicate the need for remedial action and determine the degree to which goals and objectives have been obtained. 5. Advise management in the modification and development of the CITY OF PETALUMA's policies to ensure the enhancement of equal employment opportunity r for all employees and potential employees within existing equal employment opportunity guidelines. 6. Conduct periodic audits to ensure all required posters and those advertising the CITY OF PETALUMA's equal employment opportunity policies and EEOP are displayed and that the CITY OF PETALUMA's equal employment opportunity and EEOP policies are being thoroughly communicated. 7. Assist in review and revision of all policies, procedures, and rules to ensure they are not in violation of federal or state laws and regulations. Department Heads Managers and Supervisors In their direct day -to -day contact with the CITY OF PETALUMA's employees, department heads, managers and supervisors have assumed certain responsibilities to help the organization ensure compliance with equal employment opportunity programs and effective implementation of the ESOP. These include, but are not limited to, the following: Aggressively adhere to the CITY OF PETALUMA's equal employment opportunity policy. A. Support and assist the Director of Human Resources/Equal Opportunity Officer in developing, maintaining, and successfully implementing the EEOP. B. Complete progress reports regarding the status of goal achievement. C. Take action to prevent harassment of or discrimination against employees. 2. Assign employees to significant jobs that might lead to greater personal growth and value, and counsel them with respect to what is needed for upward mobility within the employment structure. 3. Ensure that all interviews, offers of employment and/or wage commitments are consistent with the CITY OF PETALUMA's policy. 4. Implement internal promotion and transfer consistent with EEOP goals and objectives. 5. Assist in identifying problem areas and provide needed information for establishing and meeting department equal opportunity action goals and objectives. City Employees All City employees are responsible for creating and maintaining a work environment that is conducive to achieving equal employment opportunities and that is free of any form of discrimination or harassment and being aware of and understanding the County's policies and procedures that prohibit discrimination in the workplace. CHAPTER 9: IDENTIFICATION OF PROBLEM AREAS Based on analyses of each job group, areas of concern have been identified and are discussed below. In addition to comparing incumbency to availability within job groups, review of its selection procedures (i.e., hires, promotions, and terminations), including by organizational unit, has been undertaken to identify problem areas in each. City of Petaluma will continue to monitor and update these reviews during each Equal Employment Opportunity Plan year. In each case where potential problem areas have been identified, Equal Employment Opportunities, as appropriate, will be taken consistent with any of the action - oriented programs described in Chapter 10 of this Equal Employment Opportunity Plan. 41 C.F.R. & 60- 217(b)(1)• Workforce by Organizational Unit and Job Group An analysis of the demographics within each organizational unit was accomplished by a thorough investigation of the Workforce analysis. See the Workforce Analysis by organizational unit. Exhibit 1 An analysis of utilization within each job group was accomplished by a thorough investigation of the Comparison of Incumbency to Availability reports. See the Comparison of Incumbency to Availability reports for each job group. Exhibit 4 41 C.F.R. 4 60- 2.17(b)(2): Personnel Activity Information on applicants, hires, promotions, and terminations was collected and analyzed by job group. An analysis of selection disparities in personnel activity between men/women and whites /minorities was accomplished by a thorough examination of transaction data. See the Personnel Transaction Report for each job group. Exhibit 5 41 C.F.R. & 60- 2.17(b)(3): Compensation Systems Compensation analyses were conducted by comparing the mean salaries for men v. women, and whites v. minorities in each job title. See the Compensation Equity Analysis Report for each job title. Exhibit 6 CHAPTER 10: ACTION- ORIENTED PROGRAMS The CITY OF PETALUMA tailors our action - oriented programs each year to ensure they are specific to the problem identified. Action - Oriented Program: The Action - Oriented Programs designed to address identified underutilization are listed below. These Action - Oriented Programs will be carried -out throughout the EEOP year. The Director of Human Resources/Equal Opportunity Officer, with the help of the department heads, managers, and supervisors, will be responsible for ensuring that the following are implemented. Recruitment: The CITY OF PETALUMA will place advertisements on job opportunities through local job service offices. The local job service office will be notified concurrent with the placement of appropriate advertising. 2. Due to the extensive technical education and experience required for some positions, the CITY OF PETALUMA will also continue to place job opportunity announcements on the organization website, and in regional, state and/or national publications when appropriate. The CITY OF PETALUMA will advertise in publications that reach underrepresented groups, as appropriate. 4. The CITY OF PETALUMA will continue to reach out to career services and recruit at universities, community colleges, and other post -high school educational institutions in the region, such as Police Academies. The CITY OF PETALUMA identifies educational institutions based in part on the make up of its student body and inclusion of underrepresented groups. 5. Advertisements and newsletters will always carry the Equal Employment Opportunity clause. 6. All applicants will be considered for all positions for which they are qualified. 7. The CITY OF PETALUMA will participate in job fairs if there are sufficient numbers of openings to warrant participation. 8. The organization will continue to offer and develop internship opportunities for students to work during the summer and /or part-time during the school year. 9. The CITY OF PETALUMA will continue to publish recruiting brochures, as well as in other organizational literature, that reflect a commitment to hiring a diverse workforce. 10. The City acknowledges that the expertise and services of an outside recruitment agency may be required. When a recruitment is assigned to an outside recruitment firm, the City Manager and Human Resources are responsible for monitoring the recruitment activities to ensure that the intent of the Equal Employment Opportunity principles are observed throughout all phases of the recruitment. 11. Where underutilization has been noted, the City of Petaluma will attempt to get information about the makeup of the applicant pool of other agencies in the North Bay to determine whether the City of Petaluma applicant pool less diverse, and if so, identify why. Job Specifications /Selection Process: 1. Develop position descriptions that accurately reflect position functions, and are consistent for the same position from one location to another. 2. Develop job or worker specifications that contain academic, experience, and skill requirements that do not constitute inadvertent discrimination. Develop specifications that are free from bias with regard to age, race, color, sex, sexual orientation, gender identity, religion, national origin, disability or veteran status. 3. The CITY OF PETALUMA will continue to use only worker specifications that are job related, free of discriminatory provisions and artificial barriers, and reflect the actual work requirements of the essential job duties. 4. The CITY OF PETALUMA will continue to carefully select and counsel all personnel involved in the recruiting, screening, selection, promotion, disciplinary, and related processes to eliminate bias in all personnel actions. 5. The CITY OF PETALUMA will reflect diversity in its interview panels when possible. 6. The City will review all recruitments after a selection has been made to identify effective practices, potential deficiencies and possible improvements in the hiring process Job Advancement: 1. Employees reflecting the diversity of the labor market will be made available for participation in Career Days, Youth Motivation Programs, and related activities in the community, when possible. 2. The CITY OF PETALUMA will continue to post or announce job opportunities outside the Human Resources Department and on the Human Resources Department's website. Within available resources, the City has a long -term goal to establish, formal career counseling programs to include attitude Development, education, aid, job rotation, buddy system, and similar programs. v� 4. The Human Resources Department will continue to require management and supervisory personnel to submit justification when seemingly more qualified employees are passed over for seemingly less qualified employees. 5. Encourage managers and supervisors to discuss their employee's career goals and help develop and record plans for them to achieve them. 6. Encourage the promotion and overall career development of qualified employees without regard to their gender, race, disability, age, and all other characteristics protected by law. 7. The CITY OF PETALUMA will continue to use our formal employee evaluation program. The performance Appraisal is used for annual reviews for all employees. Tuition reimbursement is offered to all City employees in accordance with the City's Education and Tuition Reimbursement Policy. Separations and Terminations: 1. Exit interviews will be conducted for all terminating employees. The process, form, and content of such exit interviews shall be established by the Human Resources Department and shall be designed to identify artificial barriers to success and equal opportunity. CHAPTER 11: INTERNAL AUDIT AND REPORTING Inherent in the EEOP is the need for periodic self - assessment of problems encountered, corrective action taken, and progress made. Self- evaluation requires complex record keeping systems on applicants, employees, and components of the EEOP itself. Periodic reports from supervisors, department managers, the Director of Human Resources/Equal Opportunity Officer, and other relevant persons are required. The objective of all record keeping systems to be implemented is to assess the results of past actions, trends, the appropriateness of goals and objectives, the appropriateness and relevancy of identified solutions to problems, and the adequacy of the Plan as a whole. In addition, a further objective is to identify the proper corrective actions to be made to all components. In order to fully achieve the objectives of such a record keeping system, the results of it must lead to follow -up through feedback to managers, supervisors, and staff, through reallocation of resources, through modifications to plans and the record keeping system itself, through appropriate recognition of personal achievements as well as punitive actions for discriminatory acts. For any identified deficiencies, appropriate corrective action will be identified and implemented. The records that are maintained are the basis for updating the equal employment opportunity plan, including revising the availability data and establishing annual goals. The internal audit and reporting system is used as the basis for evaluating systemic, results- oriented programs and affir- mative action efforts. The CITY OF PETALUMA auditing and reporting system periodically measures the effectiveness of its total equal opportunity program. The Director of Human Resources/Equal Opportunity Officer: 1. Monitors records of all personnel activity, including referrals, placements, transfers, promotions, terminations, and compensation, at all levels to ensure the nondiscriminatory policy is carried out; 2. Requires internal reporting on a scheduled basis as to the degree to which equal employment opportunity and organizational objectives are attained; 3. Reviews report results with all levels of management; and 4. Advises top management of program effectiveness and submit recommendations to improve unsatisfactory performance. Every City Department will annually collaborate with the Human Resources Director/Equal Opportunity Officer to update Action Programs specific to their departments. Included in this review will be: 1. Department's Organizational Profile — The organizational profile is a detailed chart of the department's organizational structure. The display will also indicate total number of employees by job title, race and gender. 2. Comparison of incumbency to availability within each job group. 3. Analysis of Progress — The analysis of progress is a comparison of incumbency to placement goals as provided in the City's Equal Opportunity Plan: 4. Action - Oriented Programs — Efforts the department has undertaken or will undertake to recruit, hire, promote, and retain qualified individuals without regard to any protected status. 5. Personnel Activity — The data is only from the reporting year and will include personnel activity for each job group. 6. Any discrimination complaints filed in the prior year. Annual Status Report of the Equal Opportunity Plan Progress An annual status report, including a summary of the above information and an evaluation of the progress, problems, and trends in the EOP, shall be presented by the Human Resources Director/Equal Opportunity Officer to the City Manager in February of each year. The report shall be augmented by recommendations to address any identified areas of concern. This report shall be presented to the City Council as soon as practicable following City Manager review. After consideration of the comments and/or recommendations made, the City Council may in its discretion direct the City Manager to review and/or revise the Equal Opportunity Plan's goals and objectives, as well as the annual Department Equal Opportunity plans in accordance with particular priorities set by the City Council. The Council shall consider the fiscal implications and staff time requirements of any such action. [Reference: 41 C.F.R. 60 -2.23; 60 -2.25; 60 -250; 20 -741 60- 2.17(d).]