All designated employees are expected to submit their Employment Equity (EE) reports annually to the Department of Labour between the periods of the first working day of October 2017 and 15 January 2018 in the case of electronic reports.
The reports must be completed by employers using the EEA 2 and EEA 4 forms to reflect the progress made against the employer’s EE Plan. Public companies must also include their workforce profile in their financial report using the EEA 10 form.
It is important to note that the Department of Labour (DOL) views the plan as a designated employer’s employment equity implementation programme. It also represents a critical link between the current workforce profile and possible barriers in employment policies, practices and procedures, and the implementation of remedial steps that ultimately result in employment equity in the workplace.
Equally important is the structure of the plan which should be easy to understand and follow as in the SMART principle: Specific, Measurable, Attainable, Relevant and Time-bound. The development of a plan should be an inclusive process involving representation at all levels in the organisation followed in sequential phases: planning, development, implementation and monitoring.
The responsibility for overseeing these four phases should be assigned to a permanent senior employee. All employees should be made aware and informed through a representative forum of the activities relating to Employment Equity.
The EE Plan must be developed using the EEA 13 form and must be informed by the detailed analysis in the EEA 12 form. The duration of the plan should be for a period that will allow the employer to make reasonable progress towards achieving employment equity, and the period should be no shorter than one year and no longer than five years.
Numerical goals need to be developed for the appointment and promotion of people from designated groups. The purpose is to increase the representation of people from designated groups in each occupational category and job level where under-representation has been identified.
Internal procedures for resolving any disputes around the interpretation and implementation of the EE Plan should be agreed and specified in the EE Plan, with the CEO of the organisation preferably being the last point of call for resolving disputes. It is evident from the code that simply submitting reports to the DOL once a year is not fully complying with the Act.
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