The EEOC has published its draft strategic plan for fiscal years 2012 - 2016. A quick
Ctrl-F for the word "systemic" reveals 16 different hits in this relatively
"Systemic" cases, according to the EEOC, are those that
"address a pattern, practice or policy of alleged discrimination and/or class
cases where the alleged discrimination has a broad impact on an industry,
profession, company, or geographic area." The identification, investigation,
and litigation of this category of cases remains a "top priority" of the
agency. When the EEOC publishes the final version of its strategic plan, expect
to see a target percentage of systemic cases in the agency's litigation
What does this mean for employers? It means that
company-wide policies that have the potential affect certain groups more than
others very much remain on the EEOC's enforcement radar. What are some of these
issues for employers to heed:
Keep an eye on these issues, because you can bet the EEOC
will be (at least for the foreseeable future).
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