Joanna Nolte, a manager of equal opportunity and U.S. diversity and inclusion for Shell Oil Co. of Texas, was attending a symposium sponsored by the OFCCP Institute in Washington May 4 when she bumped into Bloomberg BNA.
The institute provides training programs for federal contractors on how to remain in compliance with equal opportunity, nondiscrimination and affirmative action laws enforced by the Office of Federal Contract Compliance Programs.
Nolte, who sits on the institute’s advisory board, spoke with Bloomberg BNA during the event’s luncheon and provided a glimpse into her regulatory compliance duties. She responded to follow-up questions via e-mail.
Bloomberg BNA: What are your main job duties as manager of equal opportunity and U.S. diversity and inclusion at Shell Oil Co., especially as it relates to OFCCP compliance?
Nolte: My role is focused on several key areas for Shell in the United States. First of all, I maintain robust and updated affirmative action plans (AAPs) for 43 business units covering more than 20,000 U.S.-based employees.
At Shell, we ensure quality AAPs by evaluating our progress regularly throughout the year with the business’s human resources teams, and we work with those teams to develop new or revised initiatives.
For example, such initiatives could include more focused outreach efforts to attract candidates, targeted leadership development programs or providing training to key stakeholders, such as human resources and line leaders.
My group is also responsible for investigating and responding to any claims of discrimination or harassment, managing our internal employee diversity and inclusion networks, periodically evaluating and recommending improvements for our people processes to ensure fairness and equity and working with external partners to bring best practices back to Shell.
Some examples of this include working with Springboard Consulting to undertake a comprehensive review of our culture and environment with respect to individuals with disabilities; participating in the Secretary of Defense Corporate Fellows Program to host active duty military personnel for a year at Shell, which helps us learn more about improving the transition from military to the private sector; partnering with the Human Rights Campaign to help ensure our benefits programs are supportive of LGBT [lesbian, gay, bisexual and transgender] employees; and providing unique leadership development opportunities to those in underrepresented groups through organizations such as the National Hispanic Chamber of Commerce and Southern Methodist University partnership, or the Executive Leadership Council.
Bloomberg BNA: What are some programs or initiatives at Shell, which relate to OFCCP compliance, that you and your team believe are successful measures that other contractors may want to consider or learn from?
Nolte: In addition to what I have mentioned, one other area to highlight has been Shell’s outreach to students, teachers and parents to help attract more women and minorities to STEM (science, technology, engineering, and math) careers in the energy industry.
These efforts are focused mainly on middle and high school level students. We sponsor competitions, provide educational materials and host summer camps focused on STEM content. For parents, we help raise awareness of the career opportunities in our industry for both two- and four-year degrees.
And for teachers, we help to foster professional development around all forms of energy by providing training materials and recognizing excellence through special awards and by providing needed lab equipment. In 2015, our education efforts reached more than 225,000 students, 90,000 parents and 145,000 teachers.
Bloomberg BNA: Why did you decide to join the board of the OFCCP Institute?
Nolte: I really feel honored to have been asked to be a part of such a quality organization, which officially formed its board last month. The learning offered by the OFCCP Institute is top notch, and I appreciate the chance to help this organization grow and share its knowledge with other federal contractors.
Bloomberg BNA: Although the institute isn't affiliated with the agency, Debra A. Carr, director of the OFCCP's Division of Policy and Program Development, attended and spoke at the conference. She said, "I would like our compliance officers to truly engage you. During a compliance audit, we have to talk to one another. I want to start changing the way we think about compliance; it’s interactive and conversational.” What did you think of her presentation? Did any of her remarks stand out to you?
Nolte: I appreciated Ms. Carr’s candor, her willingness to engage with the contractor community and her viewpoint that the agency and contractors can have a constructive dialogue to achieve our mutual objectives.
Bloomberg BNA: Any final thoughts about OFCCP or its compliance programs?
Nolte: There has been a tremendous amount of change in the past few years for federal contractors. It is so important that companies understand the new regulations and how they can practically address the challenges and ensure compliance. Especially in times like these, it is helpful to get the guidance and perspectives of experts as we navigate through new territory.
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