Suzy B Software 2/Suzy B Software CD-ROM 2 (1994).iso/extras/textfile/glass/glass.txt

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                               Report of
                     THE GLASS CEILING INITIATIVE

     "I believe the glass ceiling is real, that it destroys
     morale, and that though we have made some progress, we
     are a long way from shattering it."

                              Evan Kemp
                              Chairman
                              Equal Employment Opportunity
                              Commission



     "From firsthand experience I recognize the difficulty
     of this problem.  We have begun to address the issue at
     CSX and are making a concerted effort to deal with it.
     While the situation will not be rectified overnight,
     it's clear that progress is possible when top
     management addresses the importance of women and
     minorities in a straightforward manner with real
     commitment to finding answers...."

                              John W. Snow
                              President and CEO
                              CSX Corporation



     "I was asked about the role the Federal Government
     should have in helping to 'break through the glass
     ceiling.' ... the Federal Government does and should
     have an important role.  Indeed most of the companies
     hailed as great places for women and minorities to work
     had a strong push from the government a few years ago."

                              Dee Soder, Ph.D.
                              President
                              The Endymion Company, Inc.



                        TABLE OF CONTENTS


FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . .  1

EXECUTIVE SUMMARY. . . . . . . . . . . . . . . . . . . . . . .  3
     The Initiative. . . . . . . . . . . . . . . . . . . . . .  3
     The Pilot Study . . . . . . . . . . . . . . . . . . . . .  3
     The Findings. . . . . . . . . . . . . . . . . . . . . . .  4

INTRODUCTION AND STATEMENT OF THE PROBLEM  . . . . . . . . . .  6

STRATEGY OF THE INITIATIVE . . . . . . . . . . . . . . . . . .  8
     Internal Educational Effort . . . . . . . . . . . . . . .  8
     Corporate Management Reviews. . . . . . . . . . . . . . .  9
     Encourage Voluntary Efforts . . . . . . . . . . . . . . . 10
     Public Recognition and Reward . . . . . . . . . . . . . . 10

DESIGN OF CORPORATE
     MANAGEMENT REVIEW PROCESS . . . . . . . . . . . . . . . . 12

BASIC FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . 13
     If Not A Glass Ceiling, A Plateau . . . . . . . . . . . . 13
     Lack of Corporate Ownership of
          Equal Opportunity Principles . . . . . . . . . . . . 14
     Lack of Monitoring of Appraisal and
          Compensation Systems by Corporate Management . . . . 15
     Placement Patterns Consistent With Research . . . . . . . 16
     Inadequate Recordkeeping. . . . . . . . . . . . . . . . . 17

BARRIERS IDENTIFIED BY THE PILOT STUDIES . . . . . . . . . . . 18
     Recruitment Practices . . . . . . . . . . . . . . . . . . 19
          Reliance on Networking--Word of Mouth. . . . . . . . 19
          Reliance on Networking--Employee Referrals . . . . . 20
          Corporate Use of Executive Search and Referral
               Firms . . . . . . . . . . . . . . . . . . . . . 20
     Lack of Opportunity to Contribute and
          Participate in Corporate Developmental Experiences . 21
     General Lack of Understanding That EEO Is
          Not One Person's Responsibility. . . . . . . . . . . 23

CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . 24                            FOREWORD

In 1987, the Department of Labor published a report -- Workforce
2000 -- that brought dramatic attention to changes taking place
in our economy and in the composition of our workforce.
Significant among these was the increased importance of
minorities and women to the competitive status of the American
economy.

Since the publication of Workforce 2000, ample evidence has been
gathered to show that minorities and women have made significant
gains in entering the workforce.  But there is also significant
evidence from research conducted by universities, non-profit
organizations, executive recruiters, and the Department of Labor
that documents a dearth of minorities and women at management
levels -- the so-called "glass ceiling."

The Department of Labor found itself in a unique position. Our
Office of Federal Contract Compliance Programs (OFCCP) is
responsible for ensuring that all businesses with Federal
Government contracts do not discriminate in employment decisions
on the basis of race, sex, color, religion, national origin,
disability or veterans status.  And our Women's Bureau is the
only Federal agency with a congressional mandate to promote the
welfare of working women.  The Bureau has extensive experience in
helping women maximize opportunities with programs designed, for
example, to obtain careers in non traditional fields like
aerospace and construction.

While individuals and organizations have developed various
definitions of the glass ceiling, the Department of Labor has
concluded that the glass ceiling is most clearly defined as those
artificial barriers based on attitudinal or organizational bias
that prevent qualified individuals from advancing upward in their
organization into management level positions.

The symptoms of this problem are manifest.  Qualified minorities
and women are all too often on the outside looking into the
executive suite.  What the Department set out to do beginning in
the fall of 1989 was to investigate the glass ceiling in
corporate America to see if there was a problem, what were the
causes, and if there was a problem then how this problem could be
fixed.  This effort combined compliance reviews of nine different
corporations, with an evaluation of independent research, and
lengthy discussions with representatives from business, labor,
women's and civil rights organizations.This report is a synopsis of this effort to date. What we found
gives us new insight into why the glass ceiling exists and how
the Department of Labor, working with the private and public
sectors, can best fulfill its mandate to identify, investigate,
and ultimately eliminate, any artificial workplace barriers.  My
hope is that this report and the Department's ongoing focus will
also act as a catalyst for a continuing dialogue among all the
affected parties.

The glass ceiling, where it exists, hinders not only individuals
but society as a whole.  It effectively cuts our pool of
potential corporate leaders by eliminating over one-half of our
population.  It deprives our economy of new leaders, new sources
of creativity -- the "would be" pioneers of the business world.
If our end game is to compete successfully in today's global
market, then we have to unleash the full potential of the
American work force.  The time has come to tear down, to
dismantle -- the "Glass Ceiling."




                                                Lynn Martin
                                             Secretary of Labor                         EXECUTIVE SUMMARY


A.   The Initiative


The goals of the glass ceiling initiative are:

  ■  To promote a quality, inclusive and diverse workforce
     capable of meeting the challenge of global competition;

  ■  To promote good corporate conduct through an emphasis on
     corrective and cooperative problem-solving;

  ■  To promote equal opportunity, not mandated results; and,

  ■  To establish a blueprint of procedures to guide the
     Department in conducting future reviews of all management
     levels of the corporate workforce.

These goals speak to not only what is right and just in our
society, but what makes good economic sense as the private and
public sectors seek to work together to achieve an ever improving
quality of life for all Americans.

The initiative has, to date, been a four-pronged effort: 1)  An
internal educational effort within the Department of Labor; 2) A
pilot study looking at nine individual companies; 3) Public
awareness to the issue and encouragement of voluntary efforts;
and, 4) An effort to recognize and reward publicly those
companies which are independently removing their own glass
ceiling.


B.   The Pilot Study

Nine Fortune 500 establishments were selected randomly for
review.  The companies represented a broad range of products and
services and were located in five of the Department's 10 regions.
The reviews were conducted by senior officials from the national
and regional offices of the Department.

After numerous meetings with various organizations, along with an
extensive research effort, a blueprint for the process was
developed. The organizations included business, trade and
professional associations, human resources officials and leaders
and representatives from organizations representing minorities
and women.

The process was designed to produce three basic results: 1)
Identify systemic barriers to the career advancement of
minorities and women; 2) Eliminate these barriers through
corrective and cooperative problem solving; and 3) Further the
Department's and the employer community's understanding of how to
identify and eliminate discriminatory and artificial barriers.

In accordance with the legal requirements Federal contractors are
required to follow, companies were reviewed to ensure that they
do not discriminate on the basis of race, sex, color, religion,
national origin, disability or veteran status; and that they take
affirmative action to actively recruit qualified workers from all
segments of the labor force, and to provide training and
advancement opportunities for all employees.


C.   The Findings

It should be pointed out that none of the nine companies in the
pilot study has been cited for discrimination at the upper levels
of their workforces.  That's the good news. Yet a number of the
pilot companies did not live up to the good faith efforts to meet
all affirmative action requirements.

This said, The Department recognizes that the results of nine
pilot reviews do not present a scientific sample that can
describe, with any confidence, the practices and policies of
corporations beyond those examined in the pilot study.  The Labor
Department believes that attitudinal and organizational barriers,
as identified, are an indication that the progress of minorities
and women in corporate America is affected by more than
qualifications and career choices.

The pilot project also revealed several general findings that
applied to all nine companies, despite the vast differences that
existed between them in terms of organizational structure,
corporate culture, business sector and personnel policies.

  ■  If there is not a glass ceiling, there certainly is a point
     beyond which minorities and women have not advanced in some
     companies.

  ■  Minorities have plateaued at lower levels of the workforce
     than women.

  ■  Monitoring for equal access and opportunity, especially as
     managers move up the corporate ladder to senior management
     levels where important decisions are made, was almost never
     considered a corporate responsibility or part of the
     planning for developmental programs and policies.

  ■  Appraisal and total compensation systems that determine
     salary, bonuses, incentives and perquisites for employees
     were not monitored.

  ■  Placement patterns were consistent with research data.

  ■  There was a general lack of adequate records.


Among the attitudinal and organizational barriers identified
were:

  ■  Recruitment practices involving reliance on word-of-mouth
     and employee referral networking; the use of executive
     search and referral firms in which affirmative action/EEO
     requirements were not made known.

  ■  Developmental practices and credential building experiences,
     including advanced education, as well as career enhancing
     assignments such as to corporate committees and task forces
     and special projects -- which are traditional precursors to
     advancement -- were often not as available to minorities and
     women.

  ■  Accountability for Equal Employment Opportunity
     responsibilities did not reach to senior level executives
     and corporate decision makers.

             I.INTRODUCTION AND STATEMENT OF THE PROBLEM

During the past 25 years, shifting demographics -- coupled with a
changing, more global business environment and the practice of
equal employment opportunity and affirmative action -- have
resulted in greater participation of minorities and women in the
workforce.

Minorities and women have made significant gains at the entry
level of employment and into the first levels of management. Yet,
they have not experienced similar gains into the mid and senior
levels of management, notwithstanding increased experience,
credentials, overall qualifications, and a greater attachment to
the workforce.

The Department analyzed data from a random sample consisting of
94 reviews conducted of corporate headquarters of Fortune 1000
sized companies over the past three years.  Four Department of
Labor regions were included in the sample.  Those data indicate
that:

  ■  Of 147,179 employees at these companies, women represent
     37.2 percent of all employees and minorities represent 15.5
     percent.

  ■  Of the 147,179 employees, 31,184 were in all levels of
     management, from the supervisor of a clerical pool to the
     CEOs and Chairmen.  Of this number, 5,278 or 16.9 percent
     are women and 1,885 or 6.0 percent are minorities.

  ■  Of 4,491 managers at the executive level (defined as
     assistant vice president and higher rank or their
     equivalent), 6.6 percent are women and 2.6 percent are
     minorities.

Beyond the Department's own findings, a number of surveys and
studies tracked the results indicated above.  The absence of
minorities and women in higher corporate levels was highlighted
in a 1990 survey done by the UCLA Anderson Graduate School of
Management and Korn/Ferry International, an executive search
firm.  According to that survey, during the last 10 years there
has been only a slight increase in the representation of
minorities and women in the top executive positions of our
nation's 1000 largest corporations.  Minorities and women now
hold less than 5 percent of these managerial positions, up from
less than 3 percent in 1979.

The barriers to the upper rungs of the corporate ladder for
minority women appear to be nearly impenetrable according to a
report by Heidrick and Struggles, an executive search firm.
Minority women make up 3.3 percent of women corporate officers
who in turn make up only one to two percent of all corporate
officers.

Even where minorities and women made gains, the picture may be
misleading.  Titles are not consistent throughout all businesses
and industries, and salary levels are not consistent with titles.
Catalyst, a New York group whose specialty is women-in-business
issues, did a recent study of "Women in Corporate Management"
that showed larger percentages of women at all levels of
management -- including senior management -- in the financial
services industry than in either durable or nondurable
manufacturing.

The Department of Labor's Women's Bureau also provided research
pointing to a glass ceiling problem. The preliminary findings of
a study, funded by the Department's Women's Bureau, show that in
terms of job and career attitudes, female executives were very
similar to their male peers in terms of job satisfaction,
commitment to the organization, and job stress.  But, when it
came to expectations of being promoted, the findings varied
significantly between female and male executive peers -- with
women having lower perceptions of their own future promotability
than their male counterparts.

These findings led the Department to conclude that a greater
understanding of what was affecting the career advancement of
qualified minorities and women was necessary for the Department
to fulfill its responsibility to ensure equal opportunity in
employment among Federal contractors.  It was on this basis that
the Department announced that it was undertaking nine corporate
management reviews and that it was seeking a greater
understanding of what was affecting the career advancement of
qualified minorities and women.
                 II.STRATEGY OF THE INITIATIVE


The Department's strategy for implementing the glass ceiling
initiative has had four principal components:  First, to educate
its own officials in the intricacies of corporate human resource
issues; Second, to conduct several pilot reviews having a glass
ceiling component; Third, to serve as a catalyst to foster
voluntary efforts within the corporate community to remove any
barriers which may exist to the advancement of minorities and
women into upper level management positions, and Last, to give
public recognition and rewards to those contractors demonstrating
particularly exemplary efforts.


A.   Internal Educational Effort

Before any pilot reviews were initiated, senior members of the
Department met with business, trade and professional
associations, human resource officials and leaders and
representatives from a number of organizations representing
minorities and women to establish communications and a working
dialogue on the issues surrounding the glass ceiling initiative.

These meetings were especially helpful in strengthening the
Department's understanding of related business practices and what
might be involved to obtain a corporate commitment to revamp its
policies on recruiting, hiring, developing and promoting
qualified minorities and women at higher levels of the
organization.

In general, the thoughts and concerns from representatives
attending these meetings focused on five basic messages.

   ■ A strong commitment of the chief executive officer and
     senior level officials of the corporation would be required
     to ensure a diverse workforce of qualified individuals;

  ■  The corporate information necessary to conduct such reviews
     would have to be kept confidential;

  ■  To completely and thoroughly conduct such a review, the
     Department's reviewing officials would have to become fully
     aware of the culture that exists in the corporation under
     review;
  ■  The reviews would have to be conducted with corporate
     officials at higher levels than the EEO director in order to
     be responsive; and,

  ■  In spite of these cautions, addressing the glass ceiling was
     an issue whose time had come, and was worthy of Departmental
     attention.


B.   Corporate Management Reviews

The second phase of the initiative was to conduct pilot reviews
of contractors.  In the fall of 1989 the Department's Office of
Federal Contract Compliance Programs (OFCCP) began investigating
the glass ceiling phenomenon through these focused reviews.  The
agency's mandate is to ensure that Federal contractors do not
discriminate on the basis of race, sex, color, religion, national
origin, disability, or veteran status, and that contractors
actively recruit qualified workers from all segments of the labor
force, and assure that training and advancement opportunities are
equally afforded to all employees.

The companies were selected for review using the OFCCP Equal
Employment Data System, or EEDS.  The EEDS is based on the
Employer Information Reports (EEO-1) submitted annually to the
Joint Reporting Committee, a cooperative effort between the
Department and the Equal Employment Opportunity Commission.  The
EEO-1 reports provide race, sex and national origin data on the
incumbent employees of most employers, shown by broad categories
of occupational groups.

The selection of a contractor for a compliance review is done
objectively, non-arbitrarily and based on neutral standards.  An
effort was made to have the companies reviewed represent diverse
products and services.  In addition, different geographic areas
of the country were chosen.  Senior members of the Department,
regional management staff, as well as local compliance officers
conducted these reviews.

In doing so, the OFCCP worked closely with the contractors to
safeguard the confidentiality of information.  During the pilot
reviews, only information relevant to the requirements of the
inquiry were requested and, where possible, information was
reviewed and analyzed on site.

The reviews of the nine Fortune 500 contractors' corporate
offices sought to determine if artificial barriers existed that
prevented or slowed the upward mobility of certain individuals;
whether these barriers were discriminatory; whether these
companies had initiated voluntary action to remove such obstacles
to the extent they existed; and, how best to develop guidance for
conducting corporate compliance reviews in the future.


C.   Encourage Voluntary Efforts

Recognizing that only a small portion of contractor facilities
can be reviewed by the Department, emphasis was placed on
stressing to corporate leaders that voluntary actions were in
their own self interest.  Realizing the importance of
communication among corporate America, the workforce, the Federal
Government and advocacy groups, the Department began creating a
broad-based public awareness effort through formal and informal
meetings, conferences and roundtables; through the media; with
support from coalition constituent groups; and, from academic and
research organizations.

Senior members of the Department participated as speakers or
panelists in conferences, conventions and seminars to explain the
goals and dimensions of the initiative.  During these forums, the
Department stressed the importance which employers must attach to
full utilization of all of its employees and potential employees
in order to stay competitive, particularly given the demographics
of the workforce in the next decade and beyond.


D.   Public Recognition and Reward

The last ingredient in the initiative consists of recognizing and
rewarding those companies who have undertaken a particularly
creative and effective program to assure equal opportunity.  The
Department annually honors outstanding Federal contractors and
contractor associations that have demonstrated innovative efforts
to increase employment opportunities for minorities, women,
individuals with disabilities and veterans.  The OFCCP Exemplary
Voluntary Efforts (EVE) Awards are presented for highly
successful good faith efforts action programs.

In addition, the Secretary of Labor has an annual award that
recognizes one U.S. firm each year that has implemented
comprehensive workforce strategies to ensure equal employment
opportunity and affirmative action in building a workforce for
the year 2000.  This award is the Secretary's Opportunity 2000
Award.

The Department uses annual awards such as the Secretary's
Opportunity 2000 Award and the Exemplary Voluntary Efforts (EVE)
Awards to publicly honor companies which are working to remove
artificial barriers to career advancement in their workforce.

Last year, for instance, Digital Equipment Corporation of
Maynard, Massachusetts was honored with this award.  Digital was
recognized for preparing itself for the employment challenges of
the 21st century by ensuring that its workforce maintains


the cultural diversity needed to serve its community, and that it
is equipped with the skills needed for the changing technological
demands of the marketplace.  It has implemented early
intervention programs, scholarships, counseling, work-study, and
pre-employment programs.  In addition, it has established an
affirmative action committee of senior level executives who are
responsible to plan for increased representation of minorities
and women at the most senior levels of corporate management.
                    III.DESIGN OF CORPORATE
                   MANAGEMENT REVIEW PROCESS



The corporations in the pilot project ranged in size from fewer
than 8,000 employees to more than 300,000 employees, were from
seven broad industry groups and were located in five geographic
regions of the country.  The majority had international
operations.

The pilot reviews involved teams of senior executives in the
Department from the national offices of OFCCP and the Office of
the Solicitor, supported by OFCCP regional field office managers
and compliance officers.

These reviews differed from standard compliance reviews in their
emphasis and, to some degree, in their technique.  Specifically,
much time was spent with senior level corporate officers to learn
about the particular corporate culture of the company under
review.  It was vital for the OFCCP to become acclimated to the
environment of the company at the outset of a review.

The pilot reviews took significantly longer to complete than
regularly scheduled reviews, partially because the areas being
explored, such as total compensation programs and succession
planning, were generally unfamiliar to the review team members.
In addition, the contractors themselves caused delays, often due
to the unavailability of corporate executives whose participation
was essential to these types of reviews.

The Department focused considerable attention on corporate
policies and practices.  In the pilot reviews, there was less
reliance on broad statistical analysis because at the management
levels the agency focused on jobs which tended to be unique and
the number of candidates from any group was relatively small.
Analysis was performed on the procedures, or lack thereof,
governing movement across facilities, particularly movement into
corporate headquarters from lower levels of facilities'
management staff where minorities and women were located.

The reviews included a thorough examination of how potential
managers came to the attention of officials in promotional
authority.  While the reviews were focused on glass ceiling
issues, all areas covered in a standard compliance review were
investigated.  All deficiencies, whether glass ceiling or
otherwise, found at the corporation were identified and remedied.
The reviews were closed with standard official closing documents:
Letters of Compliance, Letters of Commitment, or Conciliation
Agreements; the latter two detailing the actions each corporation
would be taking to address the problem areas identified.                          IV.BASIC FINDINGS


As the Department conducted its pilot studies of the nine Fortune
500 companies, it became very apparent how different each company
was with regard to its corporate culture and corporate practices.

Each company had its own policies and procedures for developing
mid and senior level management.  Each placed different degrees
of importance on tenure, educational disciplines, and forms of
recruitment as well as reliance on human resource plans to
obtain, identify and develop high potential employees.

As part of the review process, the Department sought to
understand, as fully as possible, the particular corporate
culture of the company under review and to channel inquiries and
recommendations within the boundaries of that culture.  The
Department was not seeking to change a company's way of doing
business (as long as it was non discriminatory), but only to
encourage approaches that might improve advancement opportunities
for qualified minorities and women.

While each company was very different, some of the same
stereotypes and misperceptions documented by researchers and
authors were found.  At one company, for example, a female with
an MBA was identified in a non-managerial career path.  When
asked why she was not slated for management experience in a lower
level facility like her peers, the Department was told, "Well,
she moved here for personal reasons, so we assumed...."

Even though the organizational culture of the nine companies was
quite different, there were five common findings.


A.   If Not A Glass Ceiling, A Plateau

All of the companies reviewed had a level beyond which few
minorities and women had either advanced or been recruited, and
minorities tended to be found at lower levels of management than
women.

The OFCCP initially anticipated concentrating on the executive
suite and the highest levels of management.  As the pilot project
progressed, however, the reviewing team discovered that much of
the investigative questioning and many areas of prospective
analysis became irrelevant because there were no minorities and
women at these levels. To put it plainly, the glass ceiling
existed at a much lower level than first thought.

Because of this, the Department at times had to shift its focus
from the highest levels of the corporate structure to an analysis
of the pipelines to the top.

As the reviews identified management levels where minorities and
women tended to cap-out, the highest placed woman generally was
at a higher reporting level to the CEO than the highest placed
minority in the majority of the companies.  An exception was in
high-tech or scientific areas where certain minorities had
special training or an advanced degree.

Reporting levels, however, can be quite misleading.  While
employees may be only a few reporting levels from the chief
executive officer, they may have little or no interaction with
the CEO or senior level executives.


B.   Lack of Corporate Ownership of Equal Opportunity Principles

Most companies in the pilot study had elaborate systems to
identify and develop key employees as a business necessity to
ensure the continuity of their management staff and corporate
culture.  Such individuals were de facto corporate property and
their careers were monitored by senior level corporate officials.
However, almost all of the companies reviewed exhibited the same
lack of corporate ownership when it came to the principles of
equal employment opportunity and access.

Almost none of the companies reviewed compiled centralized
records on their employees with regard to internal and external
training and development, participation on task forces or
committees or special projects and assignments.  As a result,
there was no formal system of tracking or monitoring
developmental opportunities and credential building experiences
with high level exposure to ensure all qualified employees were
given consideration.

Companies in the pilot were reminded of their existing legal
requirements as a Federal contractor to ensure equal access and
participation of all qualified individuals in all forms of
employment, development and training, and that these obligations
did not stop at a certain level in the workforce.

As a result of their review, one company's commitment to the
Department was to name an individual on the management staff who
"will ensure that additional corporate programs which may impact
executive career progression in the future, such as training
programs, developmental job rotation, committee assignments,
etc., are offered on a representative basis to minorities and
females."


C.   Lack of Monitoring of Appraisal and
     Compensation Systems by Corporate Management

All of the companies had appraisal and compensation systems which
determined salary, bonuses, incentives, and perquisites for
employees.  Some companies used a formal evaluation system as
part of their management evaluation, others had several formal
systems for determining forms of compensation that took place at
different times in the year; while others relied less on a formal
system of rating performance.  For example,

  ■  One company used a narrative performance appraisal system
     for employees at certain levels with no guidelines or
     standards to follow.  This subjective appraisal system left
     much to the rating official's discretion.  While evaluations
     of men were directed toward performance, female appraisals
     at times were stereotypical.  One woman remarked she never
     knew how she was doing because her appraisals had such
     things as "happy," "friendly," and "gets along well with
     others."  This company voluntarily changed this rating
     process to ensure that the appraisals were more objective.

Some corporations extensively used bonuses, stock options and
other incentives to send signals to their key employees, but in
other companies these were restricted only to the highest ranking
officers.

While compensation decisions were well-documented by executive,
by salary grade, and by title, not one of the corporations in the
pilot study reviewed their total compensation packages to ensure
non discrimination.  This is particularly important because
evidence has been assembled through independent studies that
raters evaluate job performance of blacks less favorably than the
job performance of whites, especially when the raters are
themselves whites.  Additionally, because their numbers are
limited, women at high management levels are constantly tested
and scrutinized.

While all companies were aware they had to monitor salary data
for EEO to ensure non discrimination, companies were cited for
lack of oversight of other forms of reward and compensation, and
were required to ensure that all forms of compensation were being
distributed in a non discriminatory fashion.
D.   Placement Patterns Consistent With Research

Much of the research data and literature in print today suggests
that there are fields or functions in which minorities and women
are more likely to have difficulty in obtaining employment.  A
Business Week article noted that "some black middle managers feel
they are being shunted into human resources and public
relations -- jobs that often spell 'dead end' in the
corporation."

Statistics show that minorities and women are less likely to
obtain positions in line functions -- such as sales and
production -- which most directly affect the corporation's bottom
line, and are considered the fast track to the executive suite.
Instead, many minorities and women find it easier to obtain work
(or are steered) into staff positions, such as human resources,
research or administration.  The findings of the pilot reviews
were consistent with these assertions.

Almost all of the companies had few, if any, minorities and women
at the highest levels of management.  When they were present,
they were almost always in staff functions.

Moreover, the preponderance of minorities and women in the feeder
positions for mid and upper level management positions also were
in staff functions.  Few minorities and women were found in such
line professions as defense systems, electronics, commercial
lending and sales.

Advancement opportunities can also vary in staff and line
functions according to corporate culture.  For example, a high-
tech organization might lean towards individuals with advanced
and scientific degrees, while a consumer products company looks
to its sales and marketing divisions for future senior
executives.

Companies that were found to have an absence of minorities and
women in line positions were asked to audit their placement
patterns to ensure that they were non discriminatory.

One theory often cited to explain why women are concentrated in
staff positions is that they do not possess leadership qualities,
but instead have more inclusive manager-style qualities.  The
theory goes on to state that the qualities found in leader-style
managers are necessary to give direction to a large corporation
and that women generally are not believed to possess these
qualifications.
A recent study by Russell Reynolds Associates, Inc. refutes this
assertion.  That study found that a majority of women in both
line and staff positions had leader-style management skills.
Moreover, a greater proportion of women in staff positions than
men in line positions displayed a leadership orientation.  In
contrast, male executives were pretty much as expected:  leader-
style in line positions and manager-style in staff positions.


E.   Inadequate Recordkeeping

While all of the companies held major Federal Government
contracts, and were well-versed in their recordkeeping
requirements for other government agencies, there was an
inadequate assembly of records by most regarding EEO/Affirmative
Action responsibilities concerning recruitment, employment and
developmental activities for management-type positions.

As a Government contractor, a company assumes an obligation to
monitor its employment activities to ensure all employees and
applicants are treated in a non discriminatory manner.
Contractors are expected to compile records of applicant flow,
rates of hire and other personnel actions, not only because of
legal requirements, but because such records are essential to
adequate monitoring of the contractor's implementation of their
affirmative action programs.

           V.BARRIERS IDENTIFIED BY THE PILOT STUDIES


While some assert that minorities and women have neither been in
the workforce long enough, nor have the needed credentials, the
vast majority of available research information points to
artificial barriers as a significant cause for why minorities and
women have not advanced further in corporate America.

Developing and retaining a diverse and qualified workforce at all
levels is the challenge corporate America faces.  In The Black
Manager, Floyd and Jacqueline Dickens wrote:  "...we need
additional management techniques to include those different needs
and motivations to reach members of minority cultures and
capitalize on their potential.  We cannot afford to lose these
valuable resources in today's organizations."  Ensuring that
there were no discriminatory barriers to advancement is an
integral part of that process.

A case in point is a recent survey by Catalyst, a New York group
whose specialty is women-in-business issues.  Catalyst found that
79 percent of Fortune 500 chief executive officers conceded that
there are identifiable barriers to women getting to the top.

The pilot studies revealed policies and practices that can
individually hinder the advancement of qualified minorities and
women, and when taken together, can result in a workforce with a
scarcity of minorities and women in its mid and upper level
ranks.

While many selection procedures may be informal and subjective,
and therefore more difficult to identify and analyze than other
traditional processes, the Department's efforts were to ensure
that any corporate practice used was not excluding qualified
minorities and women either unintentionally or intentionally.

Additionally, while corporate practices for employee development,
exposure and experience are generally aids to individual
advancement, if such practices are not inclusive of all qualified
human talent, they can serve as barriers to those overlooked.A.   Recruitment Practices

It is generally understood that most larger companies fill
management vacancies from within.  The pilot studies confirmed
this.  In looking at recruitment practices used in these pilot
audits, the Department understood the reality that tenure would
explain why many corporations have few minorities and women at
the most senior levels of management.  In these instances, the
review focused on ensuring qualified minorities and women were in
the pipeline (e.g., lower level positions in the company); where
present, were not passed over for discriminatory reasons; and
where there was an absence, that the contractor was making good
faith efforts at outreach to bring in a diverse pool of talent.

  ■  For example, one company's senior level executives were
     almost exclusively "home grown." Almost all executives had
     over 25 years with the company, which helped explain the
     absence of minorities and women in their management ranks.
     As a result of this review, the company initiated summer
     internship and scholarship programs for women and minority
     students.  In his closing letter to the Department the CEO
     wrote, "Most of these actions are designed to increase the
     flow of qualified minority and female candidates into the
     'pipeline.'  This is critical to us, as you know, because of
     our very strong promotion from within policy."

When no internal candidate was deemed qualified for advancement,
the pilot reviews found several mechanisms to fill vacancies.  At
times these mechanisms posed a barrier to qualified minorities
and women being considered for management positions.

In general, senior level positions were not filled by minorities
or women through the recruitment practices used in the majority
of the reviews.  In those instances where companies that did not
meet their legal obligations to make good faith efforts to
consider a diverse pool of qualified candidates, they were
informed of such.

Generally, candidates for management were recruited to the
companies in the pilot review through three sources:


  1. Reliance on Networking--Word of Mouth

     In some companies mid and upper level positions were filled
     by senior executives through word of mouth referrals.  In
     some of these instances, corporate executives had learned of
     individuals, interviewed them casually (luncheons/dinners),
          and made them an offer, outside the formal recruitment
          process.

     The net result of these activities was a diminished
     opportunity for the career advancement of minorities and
     women.  All such contractors were reminded that they are
     required to use good faith efforts to recruit minorities and
     women with the requisite skills and to consider them on an
     equal basis for positions at all levels and in all segments
     of the their workforce.


  2. Reliance on Networking--Employee Referrals

     In one company, an elaborate employee referral system was in
     place.  Employees were paid for referring individuals who
     were subsequently hired.  This company, again, did not keep
     records (and was cited for not doing so) on who was referred
     through this process.

     While the review team could not establish if this system was
     discriminatory, there were no minorities and women hired
     into mid and upper levels of the company through this
     process.  Moreover, there were no minorities and women in
     the positions doing this referring.  This problem was
     resolved with a commitment to make good faith efforts as in
     example #1 above, and to internally audit their system to
     ensure it was non discriminatory.


  3. Corporate Use of Executive Search and Referral Firms

     While all companies reviewed used such firms during the
     period under review, one company appeared to fill almost
     every upper level management position through the use of
     search firms.

     The majority of the companies in the review failed to make
     executive recruitment firms aware of their equal employment
     and affirmative action obligations under the law.
     Specifically, when a request was made by the contractor to
     these agencies for a candidate pool, many of the companies
     reviewed had not made any efforts to ensure that the search
     firm reached out to identify qualified minorities and women.

     Additionally, in those instances where the search firm sent
     forward a slate with an absence of minorities and women, the
     contractors did not demonstrate any good faith efforts to
     broaden the pool of candidates.  Many of the companies were
     cited for not making good faith efforts to ensure that
     qualified minorities and women were considered through
     external recruitment.  Contractors also were reminded that
     their affirmative action obligations as a Federal contractor
     were not met if the search firms used did not refer a
     diverse pool of qualified candidates.

It should be noted that the pilot companies are aware of their
obligations as Federal contractors to seek out qualified
minorities and women when using employment services for lower
level positions.

In some pilot reviews, vacancies were posted up to a certain
level, above which employees were not made aware of advancement
opportunities.  Their only hope was reliance on networking.
Additionally, while the personnel director and EEO director are
directly involved in the staffing of lower level positions, in
some companies above a certain level those individuals do not
appear to have a very substantive role in the hiring process.

In addition to the type of recruitment used, the recruitment
process itself can, at times, be a barrier for women.  A
Wellesley College Center for Research on Women study found that
holding interviews for perspective sales representatives in hotel
rooms was intimidating especially for women, and reduces the
probability of finding qualified women applicants.  As an
alternative strategy for hiring sales representatives, managers
and professionals, some corporations have developed comprehensive
and sophisticated recruitment programs for attracting promising
candidates to the corporations.


B.   Lack of Opportunity to Contribute and Participate in
     Corporate Developmental Experiences

In general, many corporations identify key employees -- often
early in their careers -- and oversee their career advancement
through yearly appraisals and needs assessments.  Such assessment
systems may include identification of such individuals as "high
potentials" and include forms of internal development (including
rotational assignments, mentoring and training), external
development (including graduate studies, executive development
programs), international assignments, and highly visible
positions (such as special assistants to senior executives, and
assignments to corporate task forces and committees).  These
serve as available means to give key contributors experiences to
enhance their academic and work-related credentials.

While these practices generally benefit the corporate employee,
they can serve to impede the advancement of qualified minorities
and women if they are not inclusive of all human talent.
  ■  For example, one company left individual managers to groom
     their own successor.  Such a process allowed the manager to
     provide developmental opportunities to an identified
     successor.  Under this system, where there were few minority
     and female managers at mid and upper levels of the corporate
     workforce, opportunity for advancement was reduced for
     minorities and women despite their presence in the feeder
     pipelines.

  ■  In another company, mentoring took place in the form of
     upper level managers choosing individuals from a list of
     those identified as high potentials to "sponsor."  When an
     inquiry was made into what sponsoring denoted, the response
     was to "make it happen" for that high potential employee.
     Thus, at this company, even being earmarked as high
     potential was not enough to ensure that there is an
     opportunity for advancement.

A Russell Reynolds Associates study showed that the overwhelming
majority of executives felt that mentoring contributed to career
advancement.  In a study of black and white managers in one
predominantly white corporation, David A. Thomas found that 82
percent of his black respondents had mentors or sponsors at some
point in their career.

While viewed often as a business strategy by the highest levels
of the corporation in the pilot reviews, these developmental
policies and procedures were not monitored to ensure equal
opportunity and equal access.

As a remedy, the companies were required to internally audit
their systems to ensure they were inclusive of all qualified
human talent.

Additionally, as found in one pilot review, minorities and women
can be found to plateau in companies that have systems to develop
their employees internally, if they recruit externally for mid
and upper level positions from a pool of candidates with an
absence of minorities and women.

C.   General Lack of Understanding That EEO Is Not One Person's
     Responsibility

As stated earlier, the EEO director is generally included in, and
actively participates in, the filling of vacancies below the
management level.  However, as these pilot reviews demonstrate,
and has been reaffirmed to the Department by many EEO directors
in the corporate world, they are not generally included in the
recruitment process for mid and upper level positions.  Often,
they do not even know who was being considered for these
positions until after they have been filled.

Additionally, these reviews revealed that managers at the entry
levels are often given training and made aware and sensitive to
the EEO/Affirmative Action values and commitment of the company.
However, as managers move up the corporate ladder to senior level
positions where key decisions are made, there was a general lack
of continued awareness building or reaffirmation of corporate
values regarding equal employment opportunity and equal access.

Departmental staff has worked with these pilot companies to
ensure that equal employment and access issues are not solely one
person or division's responsibility, but rather integrated
throughout the workplace in all aspects of employment:
recruitment, promotion, developmental experiences, and
compensation.

One CEO's company under review voluntarily established an EEO
Overview Committee to "provide ongoing review of the corporate
EEO program and efforts, as well as to develop future plans and
encourage their enthusiastic acceptance."

                        VI.CONCLUSION


From the very outset of the glass ceiling initiative, the
Department's aim was to encourage industry that it is in its own
best interest to provide equal career advancement opportunities
to minorities and women so as to best develop all of their human
resources -- to identify and voluntarily resolve any impediments
to equal opportunity which may exist.

We know that many companies are aware of and concerned about the
heightened attention to glass ceiling issues. And, while there
may be many reasons behind their interest, we have been
encouraged by how positive the responses from industry has been
since the outset of this effort.  Not only the participating
companies, but many others have voluntarily advised the
Department of the efforts they are undertaking to identify and
correct any unfair impediments which may be keeping minorities
and women from advancing in their corporations.

Importantly, chief executive officers have become personally
involved.  Special studies and task forces to identify glass
ceiling issues are being directed by top executives to give these
efforts high profile and to communicate a corporate commitment.

For instance, one large defense contractor briefed the
Department's executive staff of their efforts.  With the strong
support of the CEO and other corporate officers this company has
determined to aggressively recruit minorities and women through
external recruitment efforts, including executive searches; make
"deputy" assignments, when possible, using these positions as
training grounds for developing minorities and women as "high
potential" managers; executives mentoring and sponsoring high
potential or high performing minority or female managers and
professionals; increase executive accountability and
responsibility for cultural changes at every level through a
creative incentive compensation plan.

Another company, again with the CEO's personal involvement has
developed monitoring programs to measure the corporation's
personnel development, retention and advancement efforts.  As a
long-term goal, the company is committed to minority and female
participation in officer ranks in the same proportion as their
participation in lower management ranks.  To meet this goal,
assignments, educational opportunities, and evaluations are
carefully monitored throughout management.  High potential
minorities and women are identified early in their careers and
tracked to assure they are given the same opportunities for
development as their peers.

These examples represent only a small portion of the voluntary,
aggressive efforts on the part of industry that have come to the
attention of the Department.  However, they give us some
indication, and some reassurance, that American businesses are
beginning to understand that their bottom line success may well
depend on recruiting, training, and retaining the best possible
workforce. And given today's demographics, that means recruiting
minorities -- including the physically handicapped -- and women.
Unfortunately, not all corporations have been enlightened, either
about their legal commitments or workforce realities.  That is
why the Department of Labor will continue to meet its mandate to
ensure that minorities and women have the opportunities
guaranteed under the law.

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