How to conduct an Employment Equity Barrier Analysis (2)

3.2  Practices related to the management of employees

Most companies employ labour lawyers and other experts to draw up employment policies. It is much more likely that you will find employment equity barriers in the practices of the organisation. The fact that a company have very good employment policies, does not mean that all managers and employees in the organisation behave accordingly. These behaviours, which deviate from the company’s policies and procedures, could lead to unfair discrimination.

In order to find employment equity barriers, your company has to identify practices which may be employment equity barriers. Since the root cause for the barriers may be the behaviour of individual managers, it is recommended that information is collected from as big a population of employees as possible.

Today online surveys are very common and a good, cost-effective way to involve all employees in the process to identify employment equity barriers. Since not all workplaces are suitable environments for online surveys, focus groups may also be employed to involve as many employees as possible in the identification of employment equity barriers. The Department of Labour usually suggest that at least 10% of all employees must be involved in focus group discussions.

Form EEA 12, the report on analysis, include the following categories for employment equity barriers:

  • Recruitment
  • Advertising positions
  • Selection criteria
  • Appointments
  • Job classification and grading
  • Remuneration and benefits
  • Terms & conditions of employment
  • Training and development
  • Performance and evaluation
  • Succession & experience planning
  • Disciplinary measures
  • Budget allocation in support of employment equity goals
  • Retention of designated groups
  • Reasonable accommodation
  • HIV & AIDS prevention and wellness programmes
  • Assigned senior manager(s) to manage EE implementation
  • Time off for employment equity consultative committee to meet

Whatever data collection methodology you choose to identify practices which may be employment equity barriers in your company, it has to include the above categories as a minimum requirement. You also have to identify the root cause of any barriers that are identified – policy, procedure or practice.

3.3  Employee records

The workforce profile is based on employee records. The regulations include form EEA1 which gives every employee the opportunity to declare their designated status voluntarily. The declaration includes race, gender, nationality and disability status. In addition to these four variables, the regulations also define occupational levels in form EEA9.

Combining all of the above definitions for every employee results in an employee profile:

Occupation Level result form to be filled

4.  Analysis

The purpose of the analysis is to identify under-representation of designated employees in the workforce profile and the reasons for this. Since the barrier analysis is a matter for consultation we recommend that you include the project team and as many as possible of the employment equity forum members in this process.

Convene a one day workshop to review the information collected for the analysis. The workshop typically start with the presentation of the workforce profile analysis to highlight the areas of under-representation of designated employees in the organisation.

Then the categories (as per form EEA 12) are used as a framework to analyse the collected data and formulate employment equity barriers. We recommend that you invite between 15 and 20 project team and employment equity forum members to this workshop. If you have sufficient numbers, you can divide the participants into three or four groups who can each work on different parts of the data to speed up the analysis process.

4.1  Policy and procedures

This Code provides a good standard against which you can do a desk audit of your company’s current policies and procedures. The scope of policies in the Code also provides a good framework of the policies and procedures to be audited as part of the barrier analysis.

Below is an example of how you could compare your own policies and procedures to the Code of Good Practice.

example of how you could compare your own policies and procedures to the Code of Good Practice.

When auditing your company’s policies and procedures, keep the following in mind:

  • The company is not required by law to have every policy or procedure covered by the Code of Good Practice. Note the policies you don’t have. If there are barriers found relating to any employment issues for which you do not have a policy,
    this could be one of the affirmative action measures that you will include in the plan.
  • The same goes for gaps that you find when you compare your company’s policies to the Code of Good Practice. The fact that you policy does not conform 100% to the Code of Good Practice does not mean it is automatically an employment equity barrier. If you find further corroborative evidence when you analyse practices, then the gap in the policy could be the root cause of any employment equity barriers that you find that you find.

4.2  Practices related to the management of employees

From the survey and focus groups you will have a lot of issues that were raised by employees. The workshop should (and original survey design) should classify the issues into the categories of form EEA 12 of the regulations.

The workshop participants should consolidate similar issues and also classify these into employment equity barriers and general human resources issues. The employment equity plan should only include barriers which cause the under-representation of designated employees in the workforce profile. Any other issues which are raised by the analysis should be referred to the human resources department for further action and not be included in the employment equity plan.

For each of the issues that are identified as employment equity barriers, the workshop participants should agree on the root cause (policy, procedure or practice).

Depending on the root cause, workshop participants may also propose affirmative action measures to be included in the employment equity plan.

Example of data collected from an employment equity survey

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