PREPARING AN EMPLOYMENT
EQUITY PLAN
A USER’S GUIDE DEPARMENT OF LABOUR Contents
Introduction
Section 1: Context
1.1 Why the Employment Equity Act?
1.2 Did you know that …
1.3 Why should employers implement employment equity?
1.4 Who is affected by Chapter 3?
1.5 What if employee numbers vary from time to time and only occasionally reach the 50 mark?
1.6 What are the duties of employers?
Section 2: Ten steps to preparing and implementing an Employment equity plan
Phase 1 Preparation
2.1 Step 1: Assigning responsibility to one or more senior manager/s
2.2 Step 2: Communication, awareness and training
2.3 Step 3: Consultation
2.4 Step 4: Conducting an analysis
Phase 2 Implementation
2.5 Step 5: Setting objectives and formulating measures
2.6 Step 6: Establishing a time frame
2.7 Step 7: Allocate resources
2.8 Step 8: Communicate the plan
2 Phase 3 Monitoring
2.9 Step 9: Monitoring and evaluating the plan
2.10 Step 10: Reporting to the Department of Labour
Section 3: Reporting to the Department of Labour
3.1 Which forms to use?
3.2 When to report?
3.3 Where to submit reports?
3.4 Others uses for the report form
3.5 Frequently asked questions
Section 4 Where to find us
4.1 Provincial Offices of the Department of Labour
4.2 Employment Equity Registry
4.3 Video: Getting employment equity working for you
4.4 We would like to hear from you
Section 5 Code of Good Practice The preparation, implementing and monitoring of Employment equity plans
1 Objective
2 Legal framework
3 Scope
4 Purpose and rationale for the plan
5 Structure of the plan
3 6 Process for constructing a plan
7 Planning phase
8 Developing the plan
9 Monitoring and evaluating the plan
Section 6 Regulations
6.1 General Administrative Regulations
1 Definitions
2 Collecting information and conducting an analysis (Section 19 of the Act)
3 Duty to prepare and implement an employment equity plan (Section 20 of the Act)
4 Duty to report (Section 21 of the Act)
5 Duty to inform (Section 25 of the Act)
6 Income Differentials (Section 27 of the Act)
7 Proof of submission
8 Enforcement (Chapter 5 of the Act)
6.2 Forms and annexures t the regulations
EEA1 Employee Declaration EEA2 Report Form EEA4 Income Differential Statement EEA8 Demographic Information EEA9 Occupational Levels EEA10 Occupational Categories
4 Introduction
This user’s guide is issued by the Department of Labour to assist employers and employees to better understand the Employment Equity Act and to meet their obligations under the Act, particularly with regard to Chapter 3.
Chapter 3 of the Act, which details a series of steps that employers must take to achieve employment equity, will be effective from 1 December 1999. This means that larger companies have to report for the first time by 1 June 2000 and others by 1 December 2000.
The guide takes users through how to prepare an employment equity plan, how to report to the Department of Labour, and also includes all the required forms and documents that employers and employees will need to comply with the Act.
The following table provides an easy reference to the content of the guide.
The different sections of the guide will refer to the regulations including standard forms, copies of which are in section 6.
Section 1 Section 2 Section 3 Section 4 Section 5 Section 6
Context The 10 steps to Reporting Directory Code of Regulations Developing an - Who - Provincial Good Practice - When Offices Forms Chapter 3 - How - Employment -EEA1 Requirements Equity - EEA2 Registry - EEA4 Where to - Website - EEA8 Who is affected submit your - EEA9 report - EEA10
o Answers to some of your questions
5 Section 1: Context
1.1 Why the Employment Equity Act?
South Africa has a legacy of discrimination in relation to race, gender and disability that has denied access to opportunities for education, employment, promotion and wealth creation to the majority of South Africans.
The Employment Equity Act was passed t address this legacy and has two main objectives:
To ensure that our workplaces are free of discrimination, and To ensure that employers take active steps to promote employment equity.
1.2 Did you know that …
The Breakwater Monitor Report of July 1999 indicates that in Management
White men and women hold 84% of management positions in South Africa Men all races hold 83% of management positions.
With regard to Promotions
White employees still constitute about 74% of management promotions and 54% of skilled promotions.
In terms of Recruitment
General recruitment figures show that black men are most targeted, BUT
Managerial and skilled recruitment figures show that white men are still favoured. For example, managerial recruitment figures show that the recruitment rate for white men is 46% followed by white women at 19% and black men at 18%.
1.3 Why should employers implement employment equity?
Not only is there a legal requirement, but good human resource management is increasingly being regarded as the differentiating factor between businesses.
It follows that to invest in and develop all our people will contribute to business sustainability and future returns.
Having a workforce that reflects the demographics of the country can improve market share, better understanding of markets, and thus the ability to service all current or prospective clients.
6 1.4 Who is affected by Chapter 3?
All designated employees and their employees, particularly those employees from designated groups.
Who are designated employers?
Designated employers include:
Employers who employ 50 or more employees Employers who employ fewer than 50 employees but whose total annual turnover equals or exceed the applicable turnover of a small business in terms of schedule 4 of the Act An employer appointed by a collective agreement Municipalities Organs of the state except for The National Defence Force The National Intelligence Agency The South African Secret Service
Who are designated groups?
Designated groups are
Black people, which means Africans Coloureds Indians
Women People with disabilities
1.5 What if employee numbers vary from time to time and only occasionally reach the 50 mark?
Employers who have 50 or more employees at the date on which reports are due, will be required to comply with the reporting requirements of larger employers.
Similarly employers who have 150 or more employees at the date on which reports are due, will be required to comply with the reporting requirements of larger employers.
Should employers avoid reporting requirements by manipulating employee numbers around these dates, they may be subject to a Director-General’s review.
7 1.6 What are the duties of employers?
Chapter 3 requires that employers take certain affirmative action measures to Achieve employment equity.
These measures are:
Employers must consult with unions and employees in order to make sue that the plan is accepted by everybody
Employers must analyse all employment policies, practices and procedures, and prepare a profile of their workforce in order to identify any problems relating to employment equity
Employers must prepare and implement an employment equity plan setting out the affirmative action measures they intend taking to achieve employment equity goals
Employers must report to the Department of Labour on the implementation of their plan in order for the Department to monitor their compliance
Employers must also display a summary of the provisions of the Act in all languages relevant to their workforce. These summaries will be made available by the Government Printer in due course.
Section 2: Ten steps to preparing and implementing employment equity plan
Drawn from the Code of Good Practice: Preparation, implementation and monitoring of employment equity plans
Phase 1: Preparation
Step 1: Assign responsibility Step 2: Communication, awareness and training Step 3: Consultation Step 4: Analysis
Phase 2: Implementation
Step 5: Corrective measures and objectives Step 6: Time frames established Step 7: Allocation of resources Step 8: Plan communication
8 Phase 3: Monitoring
Step 9: Monitor, evaluate and review Step 10: Report
Some steps may overlap while others, such as communications and consultation continue throughout the process.
Phase 1: Preparation
The preparation phase contains the relevant steps that an employer needs to take in order to produce an employment equity plan.
2.1 Step1:Assigning responsibility to one or more senior manager/s
The first step in the process is to assign responsibility for the development, Implementation and monitoring of the plan to one or more senior manager/s.
These managers should
Be permanent employees Report directly to the CEO Have key employment equity outcomes incorporated into their performance contracts (In fact, all managers should have key employment equity outcomes incorporated into their performance contracts).
And need
The necessary authority or mandate An appropriate budget Time off from other duties and commitments Access to other required resources.
The assignment of responsibility does not relieve the employer of any responsibility imposed by the Act.
The assigned managers could be employed to manage employment equity only or could be managers who have been assigned this role as part of their other responsibilities.
9 2.2 Step 2: Communication, awareness and training
This step should focus on positive outcomes such as
Better utilization of human resources A more diverse and productive workforce A workforce that reflects the relevant labour market.
What should employees know?
All employees should
Be made aware and informed of the content and application of the Act Be sensitized with regard to employment equity and anti-discrimination issues Be informed regarding the process to be followed Understand the importance of their participation in the process Be made aware of the need for participation of all stakeholders
Through a variety of methods which could include one or more of the following
Pamphlets Newsletter Workshops Videos Training sessions
What about managers?
Managers should
Be informed of their obligations in terms of the Act Be offered training in diversity management and related skills Understand that discrimination can be direct, indirect, or as a result of inaction or victimization.
2.3 Step3: Consultation
Consultation should start as early as possible in the process.
How should this happen?
A consultative forum should be established or an existing forum used if this is Appropriate, for example an existing diversity committee, affirmative action or Employment Equity Forum.
10 Who should be included?
All stakeholders such as:
Representative trade unions
Employee representatives from
Designated groups Non – designated groups All occupational categories and levels.
Senior management, including the managers assigned with responsibility.
What is proper consultation?
Proper consultation includes
The opportunity to meet and report back to employees and management Reasonable opportunity for employee representatives to meet with the employer The request, receipt and consideration of relevant information Adequate time allowed for each of the above steps.
Ongoing interaction with and accessibility to senior management with regard to Employment equity issues are critical to the success of this process.
What would be considered relevant information?
Relevant information could include that relating to
The particular business environment and circumstances of the employer The relevant economic sector or industry Relevant local, regional, and national demographic information about the economically active population The anticipated growth or reduction of the employers workforce The internal and external availability for appointment or promotion of suitably qualified people form the designated groups The degree of representation of designated employees in each occupational category and level in the employers workforce Employment policies and practices of the employer.
Relevant information is not limited to information supplied by the employer. Employees may be in a position to provide employers with valuable information that Could be considered in developing an employment equity plan.
11 How often should the consultative forum meet?
This will vary from employer to employer depending on size, sophistication, existing Levels of diversity, and what has already been accomplished in the workplace with regard to employment equity. Meetings should, however, take place regularly and employers should allow time off for these meetings.
2.4 Step 4: Conducting an analysis
Why an analysis?
For two reasons.
Firstly, to assess all employment policies, practices, procedures, and the working environment in order to identify barriers that may
Contribute to the under-utilisation of employees from the designated groups Contribute to the lack of affirmation of diversity in the workplace Adversely affect designated groups
And also
To identify practices or factors that positively promotes employment equity and diversity in the workplace.
Secondly, to determine the extent of under-representation of employees from the designated groups in the different occupational categories and levels of the employers workforce.
a) Review of policies, practices and working conditions
What should be reviewed?
All employment practices such as recruitment, selection, pre-employment testing, and induction Practices related to succession and experience planning, and related promotions and transfers Utilisation and job assignments Current training and development methodologies and strategies, and access to training Remuneration structures and practices Employee benefits arrangements Disciplinary Working conditions The number and nature of dismissals, voluntary terminations and retrenchments
12 Corporate culture Practices relating to the management of HIV/AIDS in the workplace which could be discriminatory Any other practices or conditions that are tabled by the consultative forum.
What to look for?
Factors that adversely affect employees from designated groups Subtle or indirect form of discrimination and stereotyping.
All practices should be checked t see if they are fair and do not result in unfair Discrimination.
Discrimination can take the form of any distinction, exclusion or preference made On the basis of race, colour, sex, religion, political opinion, national extraction or Social origin, which has the effect of reducing equality of opportunity or treatment In employment and occupations.
For example
Consideration should be given to whether pre-employment tests are based on Competency sets generated through job analysis of whether they are tests which could be considered biased in favour of one or more groups?
Another example would be to minitor disciplinery action, to check whether there is consistency in the application among different groups of employees in the Workplace.
b) Workforce profile
How do you establish a workforce profile?
Firstly, by establishing which employees are members of designated groups.
Employers can do this by getting the information from employees themselves using EEA1 of the Regulations, an example of which is included in Section 6 of the Guide.
If employers have alternative and reliable sources of this information, such as the information captured on employment application forms, they may use this as long as employees are able to verify or change such information.
13 Many larger employers will have this information stored on some form of computer System. While they will be able to use this information they will need some mechanism to enable employees to verify and change their personal details.
Secondly, by comparing the number of employees from designated groups With relevant demographics.
There are many sources of information that employers are able to use in order to do this.
At a more general level employers can look at the distribution of the economically Active population in the regions in which they operate and compare this to the distribution of their workforce overall as well as by occupational category and level.
Demographic information is available from Statistics South Africa. Form EEA8 of the Regulations provides information relating to the distribution of the Economically Active population per province. Forms EEA8 and EEA9 of the regulations provide Information regarding occupational levels and categories. Copies of all forms Included in Section 6 of this user’s guide.
The sources and use of more specific information for comparative purposes will Depend on the nature of the organization and its activities. For instance, employers providing professional services will often be affiliated with related professional bodies that have access to information regarding the availability and source of specialized resources.
How do you establish meaningful comparison?
There are a number of bases on which employers can benchmark their diversity profiles.
An employer can compare his workforce profile With those of organizations of a similar size With those of organizations within the same sector or industry With those of organizations which are structurally similar and whose activities are spread over a similar geographic area.
Most employers are willing to share information on a reciprocal basis and there are a number of existing research services in which employers can participate in order to establish comparative information.
14 Meaningful comparisons are not once-off. After an employer has established a Comparative position at a point in time, this should be reviewed on an ongoing Basis and the changes tracked. Sections B and C of the report form EEA2, a copy of which is included in Section 6 of this booklet, are useful in establishing what information employers should collect and track over time.
The Commission for Employment Equity (CEE) is mandated by the Act to do research in order to develop norms and benchmarks for the setting of numerical goals.
Phase 2: Implementation
The second phase contains all the steps that an employer to take to implement the employment equity plan.
2.5 Step 5:Setting objectives and formulating measures
How to go about setting goals and objectives?
The preparation done in phase one should provide employers with:
A snapshot of their organization profile and valuable information on their organization’s profile in respect of race , gender and disability And understanding of which practices or working conditions adversely affect member of designated groups Which practices and working conditions are conductive to diversity Internal statistics regarding the rate of labour turnover at the various levels Internal statistics regarding movements such as promotions and transfers at the various levels Information regarding the profile of the economically active in their region Comparisons between the organization’s workforce profile and those of similar organizations.
This information, together with their business plan, should enable employers to set realistic and achievable goals.
What are affirmative action measures?
Affirmative action measures are those measures that need to be taken tot address those employment policies, practices, and working conditions that were identified step 4 as having an adverse effect on the employment and advancement of members of designated groups.
15 For each specific practice identified, and affirmative action measure or measures need to be formulated and developed.
Some examples are
Where pre-employment psychological tests are found to be culturally biased, employers need to consider introducing acceptable competency based tests
Where there is an unusually high resignation rate of members of designated groups, reasons should be investigated and action taken to address these problems
Where vacancies are inappropriately advertised in terms of distribution to members of designated groups, more suitable media should be found.
Employers might also choose to develop pro-active measures as part of their social responsibility programmes such as
Using community organizations and educational institutions to highlight and promote the development of scarce skills in the community
Using the same institutions to distribute career counseling and information regarding the opportunities and career paths within the industry
Provide a combination learnerships and bursaries to support these initiatives.
Corrective measures will differ form one organization to another depending on the barriers identified.
2.6 Step 6:Establishing a time frame
Duration of a plan
As specified in the Act, the duration of a plan should be between one and five years. Employers should decide on the duration of their plans given their particular circumstances and the timeframe in which they can make meaningful progress.
This time frame should set out more than the duration of the plan. It should be specify milestones and the target dates set for reaching these.
Before the end of the term for a current plan, an employer must prepare a subsequent plan.
16 2.7 Step 7: Allocate resources
What resources?
Budgets should be appropriately allocated in order to implement the agreed components of the plan. Research into best practice indicates that successful programmes have separate budgets designated solely for employment equity purposes.
People such as the manager/s assigned with responsibility
Time off for stakeholders involved in the process
Infrastructure such as a project office or meeting room
Training and information sharing
Any other resources that may be appropriate in the circumstances.
2.8 Step 8:Communicate the plan
The plan should be communicated to all stakeholders.
What should this include?
Communication should inform stakeholders
Who is responsible for the implementation of the plan
Where information regarding the plan can be obtained
Objectives and duration of the plan
Dispute resolution procedures
Roles and responsibilities of the role players tasked with ensuring the success of the plan.
17 Phase 3: Monitoring
Phase 3 contains the steps that an employer takes to monitor and review the implementation of the employment equity plan.
2.9 Step 9: Monitoring and evaluating the plan
What should employers do?
Employers should
Keep records of the plan. They need to be able to review their starting position and track the movements in that position over the duration of the plan
Implement one or more mechanisms to monitor and evaluate the implementation of the plan. These mechanisms may form part of their business monitoring systems. Adequate information systems are very useful in this regard.
Evaluate progress at structured and regular intervals. If this is integrated into business monitoring processes, enough time should be set aside specifically to deal with employment equity issues.
Report on progress to the consultative forum and all stakeholders
Where progress is unsatisfactory of flaws emerge in the plan, review and revise the pan through the consultation process.
2.10 Step 10: Reporting to the Department of Labour
Section 3 of the guide deals with when and how to report to the Department and also deals with some frequently asked questions.
Section 3: Reporting to the Department of Labour
3.1 Which forms to use?
All employers who report must, complete and submit the Employment Equity Report Form EEA2.
All employers who report must, at the same time, complete and submit an Income Differential Statement Form EEA4.
Copies of the forms to be used are appended in Section 6 of the guide. All forms are available from the Department’s provincial office or labour centre. Forms can also be accessed from the website www.labour.gov.za.
18 Alternatively employers may choose to report in their own format which must contain all the information required by Form EEA2.
3.2 When to report?
150 or more employees
Employers who employ more than 150 employees are required to report annually to the Department of Labour on progress made in terms of their employment equity plans.
Reports are due on 1 June 2000 and thereafter annually on the first working day of October.
Complete
Form EEA2 All Sections except Section G (progress report)
Form EEA4 All Sections
From the second reporting cycle onwards Section G of Form EEA2 must also be completed. This section covers progress made in implementing employment equity plans from the initial report to the time of the second report.
Fewer than 150 employees
Employers who employ fewer than 150 employees are required to report every second year to the Department of Labour on progress made in terms of their employment equity plans.
Reports are due on 1 June 2000 and thereafter every second year on the first working day of October.
Complete
Form EEA2 Sections A, B, F and H
Form EEA4 Sections A and D
From the second reporting cycle onwards Section G of Form EEA2 must also be completed. This section covers progress made in implementing employment equity plans from the time of the initial report to the time of the second report.
19 3.3 Where to submit reports?
Reports should be posted, faxed or emailed to:
Employment Equity Registry Department of Labour Private Bag x117 Pretoria 0001
Facsimile: (012) 320 2059/ 322-0413
E-mail: [email protected]
Alternatively reports should be handed in at the Department’s provincial office or labour centre in an envelope clearly marked “Employment Equity Registry”.
You are advised to keep a copy of your report as well as a record that you sent the report. Should your report be mislaid or go astray, the onus will be on you to prove that it was submitted and to provide a copy of the report.
You are also required to display a copy of your most recent report in all workplaces.
3.4 Other uses for the report form
Employers can use the report form to provide them with an information framework to assist them with their employment equity plans.
Section B of Form EEA2 shows what information is required for a workforce profile analysis. Section C, D and E of Form EEA2 requires information from employers regarding recruitment, promotions, terminations, disciplinary action, and skills development. Interpretation of this type of information can alert employers to employment equity barriers and so assist them with their analysis of employment policies and working conditions.
Section F provides a useful checklist for employers to ensure that they have taken all the steps necessary to comply with Chapter 3 of the Act.
20 3.5 Frequently asked questions
Q How will the Department of Labour know that I am designated employer?
The Department has, using a variety of existing data sources, compiled a national data sources, compiled a national database of all employers from whom it expects to receive reports. This database will be updated on an ongoing basis. The Department will follow up on employers from whom reports are expected and who do not report.
Q How do I become a voluntary designated employer?
By submitting a report (form EEA2) to the Department of Labour and indicating on this form in Section A that you are a voluntary designated employer.
By becoming a voluntary designated employer, companies will become eligible for certification which will in turn be required for Government tender applications.
Q What if my employee numbers vary from time to time and only occasionally reach the 50 mark?
If you have 50 or more employees at the date on which the report is due, you will be required to report. Similarly if you have 150 employees at the date on which the report is due, you will be subject to the same reporting requirements as an employer who employs 150 or more employees.
Q Do foreign nationals qualify as members of designated groups? The Act requires that employers compare their workforce profiles with relevant local demographics and strive to be representative of these. Although foreign nationals may be included in the various designated groups reported on by the employer, it would be unacceptable to use these employees as the basis for setting numerical goals.
Q What about employees form temporary employment services?
Temporary employees of an employer who have worked for three continuous months or more must be included in all reports to the Department of Labour even where they have been procured through an employment agency.
Temporary employment services who employ 50 or more employees or whose turnover exceeds the threshold specified in Schedule 4 of the Act are required to report to the Department of Labour. By temporary employment services, also referred to as flexible to as flexible staffing, we refer to agencies who recruit and place employees for their clients on a basis other than permanent
21 These temporary employment services are also required to report to the Department of Labour on their staff complement, even if this would result in a double count of the same employees by the agency and the employer where they are placed.
Q Why different reporting requirements for employers with fewer than 150 employees?
The Department of Labour would like to make it easier for smaller employers to comply with Chapter 3 of the Act and in this regard the following less onerous obligations are placed on these employers:
Reports are due every second year
Only selected sections of forms EEA2 and 4 needs to be completed
Records have t be kept for shorter periods
Non-designated employers, this includes employers with less than 50 employees with an annul turnover less than that specified in Schedule 4 of the Act, do not have to report to the Department of Labour at all, although these companies still have to comply with all other provisions of the Act.
Q What is the status of the Code of Good Practice?
The code does not impose any legal obligations in addition to those in the Act and the failure to observe it does not, by itself, render a designated employer liable in any proceedings, except where the code refers to obligations that are required by the Act.
Q What happens if, for some reason, an employer can’t report on time?
As provided for by Section 21 (5) b, employer may notify the Director-General that they are unable to report. The notification should contain the reason for this request and should be sent to the Employment Equity Registry.
Q What happens if an employer does not report?
The Department of Labour has established a database of employers form which it expects to receive reports. Once initial reports have been received form employers, the Department of Labour will be able to identify those employers who did not report and these employers will be issued with a written undertaking to comply. The routine inspections conducted by the Department of Labour will also include a checklist of employer obligations for the Act.
22 Q How will the Department of Labour use these reports?
Information contained in the reports will create a comprehensive database of employment profiles and patterns. The Department of Labour will use this information, amongst other things, to compliance profiles by industry, region and a range of other demographic factors.
These compliance profiles will assist the Department of Labour to determine appropriate enforcement strategies to ensure employment equity.
Q How does one deal with the qualitative aspects of the report?
Section 19 (1) of the Act requires employers to indicate barriers identified and affirmative action measures adopted to address these barriers. In form EEA2, Section F, an easy tick and cross format is provided for employers to report on these barriers and affirmative action measures. Employers are also required to provide a brief description where this is appropriate.
Q If parties to collective bargaining want access to the income differential statement, what must they do?
They should request this information, in writing, from the employer. It is important to note, however, that this information is subject to section 16 (4) and (5) of the Labour Relations Act 66 of 19995. The employer must notify the party in writing that this information is confidential.
An employer is not required to disclose information:
That is legally privileged
That the employer cannot disclose without contravening a prohibition imposed on the employer by any law or order of any court
That is confidential and, if discussed , may cause substantial harm to an employee or the employer
That is private personal information relating to an employee, unless that employee consents to the disclosure of that information.
Q How will the Department of Labour use the income differential statement?
This information will be used by the Employment Conditions Commission to determine wage gap benchmarks and set norms for each occupational group and level.
23 Q What should public companies publish?
A summary of their report (form EEA2) to the Department of Labour, excluding the income differential statement. It is recommended that companies include at least section B of form EEA2 in the summary.
Q What about employers who became designated employers after the initial reporting dates?
Employers who become designated after the initial report date (June or December) and who should submit a First report, and then only submit a report again in the following year. Regardless of the month in which this employer submits his first report, the second report will only be due in the next year in the case of an employer with more that 150 employees, or two hence in the case of smaller employers.
Q Will the Minister of Labour issue any other codes?
Yes. The Minister plans to issue Codes in relation to employment policies and practices managing disability, and HIV/AIDS in the workplace.
24 Section 4: Where to find us
4.1 Provincial Offices of the Department of Labour
Province Postal Address Telephone Facsimile
Eastern Cape Private Bag X9005, (043) 701-3000 (043) 743- 9719 East London, 5200
Free State P.O Box 522, (051) 430-3001 (051) 447-9353 Bloemfontein, 9300
Gauteng-North P.O Box 393 (012) 309-5000 (012) 323-5449 Pretoria, 0001
Gauteng –South P.O Box 4560 (011) 497-3000 (011) 834-1081 Johannesburg, 2000
Kwazulu-Natal P.O Box 940 (031) 36-1500 (031) 307-6882 Durban, 4000
Northern Cape Private Bag X7263 (013) 655-8700 (013) 690-2622 Kimberley, 8300
Northern Province Private Bag X9368 (015) 290-1744 (015) 290-1670 Pietersburg, 0700
North-West Private Bag X2040, (018) 384-2033 (018) 384-2597 Mmabatho, 2735
Western Cape P.O Box 872, (021) 460-5911 (021) 465-7318
You should contact your provincial office or nearest labour centre regarding:
Queries related to inspections
Queries related to enforcement such as
Undertaking to comply Objectives and Appeals Requests for general information, and documentation.
Getting copies of the Summary of the Act.
25 4.2 Employment Equity Registry
Employment Equity Registry Private Bag X117 Pretoria 0001
Telephone: (012) 309-4000 Facsimile : (012) 309-2059/322-0413 E-mail : [email protected]
You should contact the Employment Equity Registry regarding
Submission of reports Notification if unable to report
4.3 Video: Getting employment equity working for you
The Department of Labour has produced a video called, “Getting Employment Equity Working for you”. The video explains how to prepare, implement and monitor an employment equity plan. It is available form Kagiso Educational Television on the telephone (011) 727-7117 of facsimile (011) 727-7131.
4.4 We would like to hear from you
Visit our website at www.labour.gov.za We would like to know about
Whether you found this guide useful
Any unanswered questions you may have
Any experiences and examples regarding the implementation of employment equity in the workplace you would like to share with others and us.
26 Section 5: Code of Good Practice on Preparation, Implementation and Monitoring of Employment Equity
Notice is hereby given under Section 54 of the Employment Equity Act, 1998, that the Minister of Labour, having been advised by the Commission for Employment Equity, has issued a Code of Good Practice on the preparation, implementation and monitoring of an Employment Equity Plan, as set out in this schedule.
1 Objective
The objective of this code is to provide guidelines of good practice, in terms of the requirements of the Employment Equity Act, 1998 (Act No 55 of 1998) (hereafter referred to as the Act), for the preparation and implementation of an employment equity plan (hereafter referred to as the plan).
2 Legal framework
2.1 This code is issued in terms of Section 54 of the Act, and relates to Section 20.
2.2 This code does not impose any legal obligations in addition to those in the Act and the failure to observe it does not, by itself, render a designated employer liable in ay proceedings, except where the code refers to obligations that required by the Act
2.3 When interpreting the Act, any relevant code of good practice must be taken into account.
3 Scope
3.1 This code is relevant to all employers that are regarded as designated employers in the Act.
3.2 Designated employers and the employee of designated employers should apply the guidelines set out in this code to develop their employment equity plans, taking into account the specific circumstances of their own organisation
3.3 This code may be reading conjunction with other codes of good practice that may be issued by the Minister of Labour.
27 4 Purpose and rationale for the plan
4.1 The plan reflects a designated employer’s employment equity implementation programme.
4.2 The plan represents the critical link between the current workforce profile and possible barriers in employment policies and procedures, and the implementation of remedial steps to ultimately result in employment equity in the workplace.
5 Structure of the plan
5.1 The plan may be a separate document or a component of a broader document such as a business plan.
5.2 In terms of the manner in which it is set out, the plan may closely follow the sections of the Act and the relevant items of the Code, or may be organized differently, as long as the statutory requirements in Section 20 of the Act are reflected in the plan.
5.3 The plan should be accessible and structured in such way that it sis easy to understand.
6 Process for constructing a plan
6.1 The development of a plan should be undertaken as an inclusive process that will result in a documented plan.
6.2 The process of developing a plan has three sequential phases: planning, development, and implementation and monitoring.
6.3 The planning phase of the process should include:
Assignment of responsibility and accountability to one or more senior manager/s A communication, awareness and training programme Consultation with relevant stakeholders An analysis of the existing workforce profile An analysis of relevant demographic information such as that contained in Regulation EEA 8 An appropriate benchmarking exercise, such as comparing the organization’s workforce profile with those of other organizations within the same sector, or the development of other meaningful comparisons.
28 6.4 In the development phase, in consultation with the identified role players, should include:
Objectives set Corrective measures formulated Time frames established The plan drawn up Resources identified and allocated for the implementation of the plan The plan communicated
6.5 Implementation and monitoring is an ongoing process and should continue to include components of the earlier phases, such as consultation, communication, awareness and training. This phase should include:
Implementation Monitoring an devaluating progress Reviewing the plan Reporting on progress
7 Planning phase
7.1 Assignment of senior manager
7.1.1 The planning phase should commence with the assignment of one or more senior managers who should have the responsibility for the development, Implementation and monitoring of the plan. They should:
The employer should also provide the assigned managers with the necessary authority and means, such as an appropriate budget, to perform their allocated functions
The employer is not relieved of any duty imposed by this Act or any other law
The employer should take reasonable steps to ensure that these managers perform their allocated functions. This could be done through the incorporation of key employment equity outcomes in performance contracts of the responsible managers as well as line managers throughout the organization.
7.2 Communication, Awareness and Consultation
7.2.1 All employees should be made aware and informed of:
The content and application of the Act as preparation for their participation and consultation
29 Employment equity and anti-discrimination issues
The proposed process to be followed by the employer
The advantages to employees of participation in the process
The need for the involvement of all stakeholders in order to promote positive outcomes.
7.2.2 Employers are required to consult with regard to conducting an analysis, the preparation an implementation of the plan, and the submission of employment equity reports to the Department of Labour.
7.2.3 To ensure the successful implementation of a plan, employers should make every effort to include employee representatives in all aspects of the plan, especially the planning and development phases.
7.2.4 Managers should be informed of their obligations in terms of the Act, and training should be provided to them where particular skills do not exist. Examples of required training could include diversity management, coaching and monitoring programmes.
7.2.5 The communication of an employment equity strategy should focus on positive outcomes, such as the better utilisation of all the employer’s human resources and the creation of a diverse and more productive workforce.
7.2.6 Communication should also include employees form non-designated groups and focus on the contribution that can be made by them.
7.2.7 Consultation with employees should commence as early as possible in the process.
7.2.8 A consultative forum should be established or an existing forum utilized. The forum should include employee representatives reflecting the interests of employees from both designated and non-designated groups and across all occupational categories and levels of the workforce. Representative trade unions, where these exist, or representatives nominated by such trade unions must be included in the consultation process.
7.2.9 The employer should be represented by one or more members senior management.
7.2.10 Consultation would include:
30 The opportunity to meet and report back to employees and management
Reasonable opportunity for employee representatives to meet with the employer
The request, receipt and consideration of relevant information
Adequate time allowed for each of these steps.
7.2.11 To ensure an informed and constructive consultation process, structured and regular meetings of the consultative forum or forums should be held.
7.2.12 The disclosure of relevant information by designated employers is vital for the successful implementation of the plan. Such information could include:
The particular business environment and circumstances of the employer
Information relating to the relevant economic sector or industry
Relevant local, regional, and national demographic information relating to the economically active population
The anticipated growth or reduction of the employer’s workforce
The turnover of employees in the employer’s workforce
The internal and external availability for appointment or promotion of suitably qualified people form the designated groups
The degree of representation of designated employees in each occupational category and level in the employer’s workforce
Employment policies and practices of the employer.
7.2.13 All parties should, in all good faith, keep an open mind through the process and seriously consider proposals put forward.
7.2.14 Where a representative body of trade union refuses to take part in the consultation process, the employer should record the circumstances, in writing, including those steps that the employer has taken to communicate and initiated the consultation process. A copy of this document should be provided to the representative body of trade union concerned.
31 7.3 Conducting an analysis
The purpose of the analysis is:
a) To assess all employment policies, practices, procedures, and the working environment so as to :
Identify any barriers that may contribute to the under-representation or under- utilisation of employees from the designated groups
Identify any barriers or factors that may contribute to the lack of affirmation of diversity in the workplace
Identify other employment conditions that may adversely affect designated groups
Identify practices or factors that positively promote employment equity and diversity in the workplace
b) To determine the extent of under-representation of employees from the designated groups in the different occupational categories and levels of the employer’s workforce.
While the first type of analysis is of a more qualitative and legal nature, the second is mainly a statistical and data processing exercise.
7.3.1 Review of employment policies, practices, procedures, and working environment
A review of all employment policies, practices, procedures, and of the working environment should be undertaken in order to identify any barriers that may be responsible for the under-representation or under-utilisation of employees form designated groups.
a) The review should include a critical examination of all established policies, practices, procedures and working environment. These would include :
Employment policy or practices, such as recruitment, selection, pre-employment testing, and induction that could be biased, inappropriate, or unaffirming
Practices related to succession and experience planning, and related promotions and transfers to establish whether designated groups are excluded or adversely impacted
Utilisation and job assignments to establish whether designated groups are able to meaningfully participate and contribute
32 Current training and development methodologies and strategies, including access to training for designated groups
Remuneration structures and practices such as equal remuneration for work of equal value
Employee benefits related to retirement, risk, and medical aid to establish whether designated groups have equal access
Disciplinary practices that may have a disproportionately adverse effect on designated groups and that not be justified
Working conditions that may not accommodate cultural or religious differences, such as the use of traditional healers and observance of religious holidays
The number and nature of dismissal, voluntary terminations and retrenchments of employees from designated groups that may indicate internal or external equity- related factors contributing to such terminations.
Corporate culture, which may be characterized by exclusionary social and other practices
Practices relating to the management of HIV/AIDS in the workplace, to ensure that people living with HIV/AIDS are not discriminated against
Any other practices or conditions that are tabled arising out of the consultative process. b) All practices should be assessed in terms of cross-cultural and gender fairness. c) The review should take into account more subtle or indirect forms of discrimination and stereo-typing which could result in certain groups of people not being employed in particular jobs, or which could preclude people form being promoted. Examples would include pregnancy, family responsibility, exclusionary social practice, sexual harassment, and religious or cultural beliefs and practices.
7.3.2 Workforce profile a) The first step in conducting an analysis of the workforce profile is to establish which employees are members of designated groups. This information should be obtained from employees themselves, either form a declaration as provided for in Regulation 2 (1) or from existing and dependable sources. An example of an existing and dependable source would be an employer’s database that contains the information required on employment application forms. If such existing records are utilized for this purpose, each employee should have the opportunity to verify or request changes to this information.
33 b) An analysis of the workforce profile should provide a comparison of designated groups by occupational categories and levels to relevant demographic data. Regulation EEA8 contains some demographic data for this purpose, but there are many other sources of information that could be utilized and might be more relevant.
c) In addition to the demographics, both the availability of suitably qualified people from designated groups in the relevant recruitment area, as well as the internal skills profile of designated employees, should be taken into account. The relevant recruitment area is that geographic area form which the employer would reasonably be expected to draw or recruit employees.
d) Recruitment areas may vary depending upon the level of responsibility and the degree of specialization of the occupation. Usually, the higher the degree of responsibility r specialization required for the job, the broader the recruitment area.
e) The standard occupational classification as defined in Regulation EEA10 should form the basis for determining occupational categories. Occupational levels could be determined by any of the professional job grading systems (Paterson, Peromnes, Hay etc) or their equivalents as detailed in Regulation EE9. In the absence of a formal job grading system, designated employers may use equivalent occupational levels as the basis for the workforce analysis.
f) Sections B and C of the Employment Equity Report as defined by Regulation EEA2 should guide employers in establishing information requirement to develop a plan, and provide the basis for developing a workforce profile.
8 Developing the plan
8.1 Duration of the plan
The duration of the plan should be for a period that will allow the employer to make reasonable progress towards achieving employment equity. This period should be no shorter than one year and no longer than five years, as specified in the Act.
8.2 Broad objectives of the plan
The broad objectives of the plan should be specified and a timetable developed for the fulfillment of each objective. These objectives should:
34 Take into account the output of the planning phase
Take into account the particular circumstances of the employer
Be aligned with and included in the broader business strategy of the employer.
8.3 Affirmative action measures
8.3.1 Affirmative action measures, to address the barriers identified during the analysis, should be developed to improve the under-representation of designated group members. Such measures relate to, but are not limited to the following:
Appointment of members form designated groups This would include transparent recruitment strategies such as appropriate and unbiased selection criteria and selection panels, and targeted advertising.
Increasing the pool of available candidates Community investment and bridging programmes can increase the number of potential candidates.
Training and development of people from designated groups These measures include access to training by members of designated groups, structured training and development programmes like learnerships and internships, on the job mentoring and coaching, and accelerated training for new recruits. Where required, diversity training should be provided to responsible managers as well as training in coaching and mentoring skills.
Promotion of people from designated groups This could form part of structured succession and experience planning and would include appropriate and accelerated training.
Retention of people form designated groups Retention strategies would include the promotion of a more diverse organizational culture, an interactive communication and feedback strategy, and ongoing labour turnover analysis.
Reasonable accommodation for people form designated groups These measures include providing an enabling environment for disabled workers and workers with family responsibilities so that they may participate fully and, in so doing, improve productivity. Examples of reasonable accommodation are accessible working areas, modifications to buildings and facilities, and flexible working hours where these can be accommodated.
35 Steps to ensure that members of designated groups are appointed in such position that they are able to meaningfully participate in corporate decision-making processes A conscious effort should be made to avoid all forms of tokenism. Candidates must be appointed with commensurate degrees of authority.
Steps to ensure that the corporate culture of the past is transformed in a way that affirms diversity in the workplace and harnesses the potential of all employees. Such steps could include programmes for all staff, including management, contextualizing employment equity and sensitising employees with regard to the grounds of discrimination such race, diversity, gender, disability, and religious accommodation.
Any other measures arising out of the consultative process
8.3.2 All corrective measures to eliminate any barriers identified during the analysis should be specified in the plan.
8.3.3 The employer is under no obligation to introduce an absolute barrier relating to people who are not from designated groups, for example having a policy of not considering white males at all for promotion or excluding them from applying for vacant positions.
8.4 Numerical goals
8.4.1 Numerical goals should BE developed for the appointment and promotion of people form designated groups. The purpose of these goals would be to increase the representation of people from designated groups in each occupational category and level in the employer’s workforce, where under-representation has been identified and to make the workforce reflective of the relevant demographics as provided for in Regulation EEA8.
8.4.2 In developing the numerical goals, the following factors should be taken into consideration:
The degree of under-representation of employees from designated groups in each Occupational category and level in the employer’s workforce
Present and planned vacancies
The provincial and national economically active population as presented in Regulation EEA8
The pool of suitably qualified persons form designated groups, form which the
36 Employer may be reasonably expected to draw for recruitment purposes
Present and anticipated economic and financial factors relevant to the industry in which the employer operates
Economic and financial circumstances of the employer
The anticipated growth or reduction in the employer’s workforce during the time Period for the goals
The expected turnover of employees in the employer’s workforce during the time Period for the goals
Labour turnover trends and underlying reasons, specifically for employees from Designated groups
8.5 Consensus
In setting objectives and developing corrective measures, parties to the consultative process should attempt to reach consensus on what would constitute reasonable progress over the duration of the plan.
8.6 Resources
Resources, including budgets, should be appropriately allocated in order to implement the agreed components of the plan.
8.7 Assignment of responsibility.
Responsibility for implementation and monitoring of the plan, as assigned during the planning phase, should be confirmed and noted.
8.8 Dispute Resolution
8.8.1 Internal procedures for resolving any dispute about the interpretation and implementation of the plan should be agreed and specified.
8.8.2 The use of existing dispute resolution procedures should be encouraged provided that they are appropriate, and if necessary adapted to the needs of employment equity.
8.8.3 Alternatively, a mechanism with appropriate representation for employer and employees may be established in order to address and resolve such disputes.
37 8.9 Communication
8.9.1 The plan should be appropriately comprehensively communicated to employees. This communication mechanism should indicate the parties responsible for the implementation of the plan and the agreed dispute resolution procedures. Information about the plan should be easily accessible to all levels of employees.
9. Monitoring and evaluating the plan
9.1 Records should be kept to effectively monitor and evaluate the plan.
9.2 Mechanisms to monitor and evaluate the implementation of the plan should be agreed and include benchmarks that would permit assessment of reasonable progress.
9.3 The plan should be evaluated at regular intervals to ensue that reasonable progress is made. This evaluation should be integrated into mechanisms that the employer normally utilises to monitor its operations.
9.4 The consultative forum(s) should continue to meet on a regular basis, and should receive progress reports. Progress should be recorded and communicated to employees. Such meetings should take place at reasonable intervals to ensure feedback and inform the ongoing implementation process.
9.5 The plan should be reviewed and revised, as necessary through consultation.
9.6 Reporting
9.6.1 Larger employers, with 150 or more employees, will be required to submit first reports by 1 June 2000 and thereafter annually on the first working day of October, starting in 2001.
9.6.2 Smaller employers, with fewer than 150 employees, will be required to submit their first reports by 1 December 2000 and thereafter every second year, on the first working day of October, starting in 2002.
9.6.3 The reporting format for employees is contained in the Employment Equity Report as defined in Regulation EEA2.
9.6.4 Designated employers whose operations extend across different geographical areas, functional units, workplaces or industry sectors may elect to submit either a consolidated or a separate report for each of these. This decision should be made by employers after consultation with the relevant stakeholders
38 Footnotes
Section 3 (c) of the Act See the definition of designated employer in the Act See section 24 of the Act See sections 16 and 17 of the Act See the definition of designated groups in the Act See section 19 of the Act. See the definition of family responsibility in the Act See section 20 (20) (e) of the Act See section 15 and 20 (2) (b) of the Act See the definition of reasonable accommodation in the Act See section 20 (2) (c) of the Act See section 21 of the Act.
Section 6: Regulations
6.1 General Administrative Regulations
1 Definitions
In these regulations any expression that is defined in the Employment Equity Act, 1998, has that meaning and unless the context indicates otherwise:
a) Director – General as it appears in sections 14 and 21 of the Act means the Director – General of Labour, Employment Equity Registry, Department of Labour, Private Bag X117, Pretoria, 0001.
b) Director – General as it appears in sections 34, 37, 39, 40, 42, 43, 44, and 45 of the Act, means the Provincial Director of the Department of Labour:
In the province of the Kwazulu Natal, the Provincial Director, Department of Labour, P O Box 940, Durban, 4000, Tel (031) 336-1500, Fax (031) 307-6882
In the Province of the Northern Cape, the Provincial Director, Department of Labour, Private Bag X5002, Kimberley, 8300, Tel (053) 838-1500, Fax (053) 832-4798
In the Northern Province, the Provincial Director, Department of Labour, Private Bag X9368, Pietersburg, 0700, Tel (015) 290-1744, Fax (015) 290-1670
In the Province of North – West, the Provincial Director, Department of Labour, Private Bag X2040, Mmabatho, 2735, Tel (018) 384-2033, Fax (018) 384-2597
39 In the Province of Eastern Cape, the Provincial Director, Department of Labour Private Bag X9005, East London, 5200, Tel (043) 701-3000 Fax (043) 743-9719
In the Province of Mpumalanga, the Provincial Director, Department of Labour Private Bag X7263, Witbank, 1035, Tel (013) 655-8700, Fax (013) 690-2622
In the Province of Free State, the Provincial Director, Department of Labour, P.O Box 522, Bloemfontein, 9300 Tel (051) 430-3001, Fax (051) 447-9353
In the Province of Gauteng – South : in the Magisterial Districts of Alberton, Boksburg, Brakpan, Germiston, Heidelberg, Johannesburg, Kempton Park, Oberholzer, Randburg, Roodepoort, Vanderbijlpark, Vereeniging and Westonaria, the Provincial Director Department of Labour, P.O Box 4560, Johannesburg, 2000, Tel (011) 497-3000, Fax (011) 834-1081
Gauteng – North: in the Magisterial Districts of Benoni, Bronhorstspruit, Cullinan, Krugersdorp, Nigel, Pretoria, Randfontein, Soshanguve 1,Soshanguve 2, Springs and Wonderboom, the Provincial Director, Department of Labour, P.O Box 393, Pretoria, 0001, Tel (012) 309-5000, Fax (012) 309-5449
In the province of the Western Cape, the Provincial Director, Department of Labour, P.O Box X872, Cape Town, 800, Tel (021) 460-5911 Fax (021) 465- 7318
c) “The Act” means the Employment Equity Act, 1998 (Act No. 55 of 1998).
2 Collecting information and conducting an analysis: (Section 19 of the Act)
2.1 When a designated employer collects information about individual employees for the purpose of compiling a workforce profile to determine the degree to which employees from designated groups might be under-represented, the employer must either:
Request each employee in the workforce to complete, on a voluntary basis, a Declaration that must be in the form of EEA1 or contain the information required by that form, or
Use existing dependable records of the employer, containing the information Required by form EEA1.
2.2 If the designated employer uses form EEA1, all employees who complete the form must at any time be able to make changes to the form at their request.
2.3 If the designated employer elects to use a source of information referred to in sub regulation (1) (b), each employee has the right to verify any information
40 relating to that employee, and to request that changes be made to that information.
2.4 A designated employer may use section B of form EEA2 to develop the workforce profile of the employer’s employees as required by section 19 (2) of the Act.
2.5 When a designated employer conducts the analysis required by section 19 (1) of the Act, the employer may refer to -
EEA 8 Annexure 1, for the recording of demographic data,
EEA 9 Annexure 2, which contains a definition of occupational levels , and
EEA 10 Annexure 3, which contains a definition of occupational categories.
2.6 A designated employer may refer to the Code of Food Practice: Preparation, Implementation and Monitoring of Employment Equity Plans as a guide when collecting information and conducting the analysis required by section 19 of the Act.
3 Duty to prepare and implement an employment equity plan: (Section 20 of the Act)
3.1 A designated employer may refer to the Code of Good Practice: Preparation, Implementation and Monitoring of Employment Equity Plans when preparing the Employment equity plan required by section 20 of the Act.
3.2 A designated employer must retain the employment equity plan for a period of three years after the expiry of the plan, unless the employer employs fewer than 150 employees, in which case the plan must be retained for 2 years.
3.3 The employment equity plan must contain a description of the measures taken by the designated employer to ensure non-discrimination in relation to HIV/ AIDS in that employer’s workplace.
4 Duty to report: (Section 21 of the Act)
4.1 Each designated employer must submit a report in terms of section 21 of the Act, which must be in the form of EEA2 or contain the information required by that form.
41 4.2 A designated employer whose operations extend across different geographical areas, functional units, workplaces or industry sectors may elect to submit a consolidated or separate report for each of these.
4.3 A designated employer must retain a copy of the report for a period of three years after it has been submitted to the Director-General, unless the employer employs fewer than 150 employees, in which case the report must be retained for 2 years.
5 Duty to inform: (Section 25 of the Act)
5.1 Each designated must display the notice required by section 25 (1) of the Act in the form of EEA 3, in all the official languages spoken in that employer’s workplace.
5.2 If there are employees in the workplace who are unable to read this notice, the employer must inform those employees verbally about the provisions of the Act.
5.3 The notice referred to in sub-regulation (1) is available in the following forms, each in the official language as indicated:
EEA 3 English EEA 3A Xitsonga
6 Income differentials: (Section 27 of the Act)
6.1 Each designated employer must submit a statement of income differentials required by section 27 of the Act in the form of EEA4, or in a document that contains the information required by that form.
6.2 When completing the statement, designated employers may refer to EEA 10 for a definition of occupational categories.
6.3 Designated employers must submit the statement to: Employment Conditions Commission, c/o Employment Registry, Department of Labour, Private Bag X117, Pretoria, 0001
6.4 Designated employers must retain a copy of the statement for a period of three years after it has been submitted to the Employment Conditions Commission, unless the employer employs fewer than 150 employees, in which case the statement must be retained for 2 years.
42 7 Proof of submission
7.1 Whenever a person is required to satisfy any other person that a copy of any document required or prescribed by the Act or these regulations has been submitted to another party, that person may do so by providing:
A copy of the proof of mailing the document by registered post of the other party,
A copy of the telegram, telex or e-mail, including proof of transmission, communicating the document to the other party,
A copy of a receipt signed by the other party or on that party’s behalf if the document was delivered by hand, or
A statement confirming delivery signed by the person who delivered the document.
8 Enforcement: (Chapter 5 of the Act)
8.1 Securing an undertaking: (Section 36 of the Act)
Any undertaking secured by a labour inspector in terms of Section 36 of the Act must be in the form of EEA 5 or contain the information required by that form.
8.2 Compliance order: (Section 37 o f the Act)
A compliance order issued by a labour inspector under Section 37 of the Act must be in the form of EEA 6 or contain the information required by that form.
8.3 Objectives to a compliance order: (Section 39 of the Act)
An objection lodged by a designated employer under Section 39 of the Act must be in the form of EEA 7 or contain the information required by that form.
The objection must be lodged with the Provincial Director at any provincial office of the Department of Labour listed in regulations 1 (3).
43 6.2 Forms and annexures to the regulations
EEA 1 Employee Declaration
EEA 2 Report Form
EEA 4 Income Differential Statement
EEA 8 Demographic Information
EEA 9 Occupational Levels
EEA 10 Occupational Categories
44