Tag Archive for: DEI

Rethinking Unpaid Internships: Equity Upon Entry to the Workforce

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Authors: Joelle Min and Sarah Crawford

Young people across the country often pursue internships with hopes of return offers and greater career opportunities once graduation comes along. In 2022, internships are of greater importance as the height of the pandemic last year canceled almost half of internship opportunities. Often, students are expected to be grateful and willing to take up any internship opportunity, even if it means foregoing monetary compensation. This Harvard Business Review article reports that 43% of internships by for-profit companies are unpaid. However, despite their ubiquity, unpaid internships are unfair, inequitable, and exploitative of young students, many of whom lack the bargaining power to fight for fair working terms and conditions. Many companies justify unpaid internships by arguing that they provide educational and professional development opportunities that they would not otherwise offer as paid positions. This ignores the financial implications of doing unpaid work that especially burdens young, low-income, and first-generation students of color.

Internships help set the stage for career success

It is clear that internship experience can give candidates a leg up in the job market, but those who cannot afford to take unpaid internships lose out on opportunities to gain that experience. The Washington Post reports that “nearly two-thirds of college graduates who complete paid internships receive job offers upon graduating, compared with just 35 percent of recent graduates who do not have internship experience.” 

Even though the Fair Labor Standards Act of 1938 requires covered employers to pay employees for their work, a 1947 Supreme Court case Walling v. Portland created a carve-out for unpaid “trainees.” In this case, the Supreme Court decided that participants in a weeklong training program for potential railroad brakemen were trainees rather than employees and did not need to be paid. Under the Fair Labor Standards Act, the Court held that “the definition of an employee cannot be interpreted to make a person whose work serves only his own interest an employee of another who gives him aid and instruction.”

Walling v. Portland offered the legal foundation for a theoretical defense of the educational benefits of uncompensated work. Although organizations are not obligated to pay interns where the interns receive more benefit from the relationship than the organization, organizations must pay interns who function more as employees. The Department of Labor offers a seven factor “primary beneficiary test” to determine whether an intern or student must be paid as an employee. This test includes factors relating to expectations about compensation, the type of educational training provided, whether the intern receives academic credit, whether the intern’s work complements or displaces paid employees, whether the internship is expected to lead to a paid job, etc. 

Paid internships lead to stronger career opportunities for all than unpaid internships

Too often, the claimed benefits of skill-building and professional development used to justify uncompensated labor fall short and they also may fail  to account for the actual financial costs of the individual seeking work. In many cases, the educational benefits that students receive from the internship program are mainly work experience, from which the company can profit. Additionally, since young people enter the workforce with minimal to no experience, they tend to have little knowledge of their bargaining power in seeking internships. 

Some students end up taking on an additional service job to pay bills, while others have the financial freedom to accept unpaid jobs at high-profile organizations, setting them on a more profitable career path. For students ranging from 17 to 25, the summer internship search tends to value generational wealth – in terms of financial dependence and nepotism – over talent, contributing to a job market where critical career-building opportunities more often go to those who can depend on their family’s wealth. Take, for instance, an internship opportunity and two student applicants: Student A with a financial safety net provided by their parents to cover expenses like rent, groceries, and gas, and Student B with student debt and no financial support from family. Student A can immerse themselves completely into the role, as they do not have many more obligations outside of completing the internship. Student B, on the other hand, must find additional work to fund their current financial situation, carrying the weight of two full-time jobs. Often, they would not even get the opportunity to work in an unpaid internship due to its financial burden, as the risk cannot guarantee employment and causes immediate financial burdens.  

Paid internships help to level the playing field and open opportunities, regardless of the candidate’s financial background.  As a recent blog post on the DEI impacts of unpaid internships explains, “paid internships are the best way for students of color to have the same opportunities as white students, especially as higher education in the U.S. becomes more demographically diverse and the percentage of undergraduate students from low-income households rises.” Unpaid internships only compound financial insecurity for students who are already taking on student debt. 

The importance of DEI in considering student professional development

The urgency of a student’s current financial situation should not be compromised for the future opportunity for employment. Unpaid internships can shut out these students from entry-level experiences in certain fields, which then result in long-term deficits of diverse talent and perspectives in all sectors. A stark example of these concerns is internships in government and public affairs. Many times, those who are shut out of unpaid internships due to financial strain are the people who could really make a difference in the policymaking and government with an internship opportunity. While colleges have taken measures to offer class credits or stipends to students for unpaid internships, these alternatives do not absolve the financial burdens of unpaid positions and are not sustainable for already cash-strapped schools and students. As diversity, equity, and inclusion have become a priority for businesses stemming from the social pressures of 2020’s overdue racial reckoning, it is of vital importance to find solutions to equity of opportunity not only in hiring but also the step that precedes that stage: student professional development. 

DEI in the workplace requires equitable access to internship and employment opportunities. Unpaid internships further marginalize emerging BIPOC and low-income workers from industry pipelines. As newbies in the job market, many marginalized students have minimal bargaining power. In many cases, interns are doing actual work that an otherwise paid regular employee would be doing. There are many companies that care and provide for their interns as a moral practice of what they should be doing. Legal precedent should not be the only justification or direction of companies’ interactions with young people seeking to enter into the job world. Businesses should break the cycle of exploiting students. Paid internships provide important opportunities for those entering the job market  to realize their potential and for employers to diversify their workplaces. 

About the Lead Author

Joelle Min
Joelle Min was an undergraduate paid intern with Working IDEAL from June of 2021 to August of 2022. She is currently a junior at Claremont McKenna College studying a dual major in Politics, Philosophy, and Economics and Public Policy and currently interning (in a paid position) on Capitol Hill. She has worked closely in local politics, electing the youngest trustee in California, as well as running sexual harassment education programs in her hometown.

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Working IDEAL provides trusted and innovative advice on inclusive workplaces, diverse talent, and fair pay. Our audits and assessments apply the best thinking on how to promote gender, race and other forms of equity in your pay practices. Our robust quantitative and qualitative reviews go beyond basic compliance to align effective compensation strategy. Contact us for more details. 

5 Reasons Why First-Generation College Students Should be a Target Population in Diversity, Equity, and Inclusion Efforts in the Workplace

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Authors: Xavier Walker, Cherrie Bucknor, and Pam Coukos

First-generation college students/professionals are a unique population of people who are an increasing focus for diversity, equity, and inclusion efforts at colleges and universities, and that should become a formal part of workplace DEI programs. To be a first-generation student typically means one’s parent(s)/caretaker(s) did not obtain a bachelor’s college degree or higher – rather, their highest education can range from a high school diploma/GED to an associates/some college, or in neither. Given the criteria, we realize just how easily members of this group can get swept under the rug if not properly recognized by an organization; we cannot account for first-gen populations solely through primary diversity characteristics (race, ethnicity, gender, sexuality, disability, etc.). In fact, a study done by The U.S. Census Bureau on behalf of the Office of Civil Rights at the Department of Commerce, found that there are barriers to workplace inclusion and career advancement unique to first-gen populations – so more needs to be done.

Recruiting and retaining first-generation candidates should be standard practice as they are talent who could help any company go far. While research is still in an emerging phase, there is evidence that first generation students can make critical contributions at work based on their ability to navigate the challenges of college without the level of support continuing generation students may receive. Some qualitative studies have identified examples of several characteristics first-generation students may possess that can make them an asset in the workplace, such as: perseverance, social intelligence, proactiveness, optimism, goal-directedness, curiosity, graciousness, and much more. The potential to develop a generation of professionals that garner an immense amount of loyalty and commitment toward your organization is an opportunity that should not be missed.

Furthermore, first generation students are a population that could contribute significantly to Diversity, Equity, Inclusion and EEO as they exist today – especially in regard to racial diversity. The majority of first-generation students identify as people of color and make up the majority of minority-serving institutions’ student body. So, keeping first-gens in mind could ultimately lead to improved diversity within your organization which is extremely important for company success.

Here are 5 reasons why first-generation students/professionals should be targeted in Diversity, Equity, and Inclusion efforts and recommendation on how to improve chances of hiring and retaining this population:

1. A Person of Many “Firsts”

The challenges of first-generation students do not start and stop at being a student. Several indicators make this population especially disadvantaged in comparison to their non-first-gen counterparts. It has been found that on average, first-generation students come from lower socioeconomic backgrounds, which makes parent(s)/caretaker(s) less likely to be able to support the financial demands of college and the transition into early adulthood. First-generation students are more likely than their peers to be the first to generate their own wealth. This means early in their career, they are more likely to lack accessible funds or family wealth to aid in instances of relocation, emergency, or just mere leisure; these students are often incurring heavy expenses and debt much earlier than their peers (funding education, housing/rent, transportation, monthly expenses, etc.). Finally, these students may also become  first-generation professionals (FGPs) – first to earn a 4-year degree and/or obtain a higher level professional position than one’s parent(s)/caretaker(s).

In many cases, it’s a great feeling to get your first car and secure your first apartment, but as a first-generation professional, that typically comes with you having to spend your own money on every payment and expense of the way. While this can be an issue for many college graduates starting out, first-generation professionals are particularly likely to fall into this category. When living check to check, things can get difficult, quickly, so here’s how employers can help:

Recommendation #1: Provide financial assistance to support your entry-level employees as they transition to the workplace. When a company is willing to provide relocation assistance as well as payment for travel expenses (for interview and/or visit), then one’s talent pool can become much broader as you’ve eliminated the logistical barriers for any applicant who’d otherwise have to look the other way. This is particularly true where expenses are paid directly by the employer, rather than requiring the candidates to pay then seek reimbursement.

2. Pressure to find Employment

First-generation students can feel strong  pressure to find employment post-graduation due to losing the financial safety net of their institution. For some students, attending a 4-year university can be a means of living. The financial support provided by their university – whether that be in the form of scholarship (academic and/or sport), financial aid, and/or loans – is easily considered income for these students; these funds are used to pay for housing (dorm or rent), food/meal plans, transportation, etc. So as these years come to an end and the need to find employment comes around, these students may be more susceptible to having a necessity-driven (vs. opportunity-driven) approach to their job search. 

With the idea that your next stream of income needs to pay the bills, one could undermine considerations such as: searching for a job vs. beginning a career, or thinking your first job offer is going to be your best or only offer. First-generation students tend to expedite their job search which can result in them taking a job unrepresentative of their credentials. Kickstarting your career deserves a considerable amount of time and patience with minimal interference from outside factors, so, here’s how employers can help alleviate these pressures:

Recommendation #2: As we know, many colleges and universities do a phenomenal job at identifying first-generation populations so organizations should take steps to partner with institutions’ first-generation programs to support these students’ early career development and potential for job security prior to graduation. Programming may consist of opportunities such as: specialized recruitment, internships, research, shadowing, seminars, career fairs, etc. It is imperative that we let these students know that there are avenues to explore in their job search and allow them to find opportunities best for them. 

3. Psychological Challenges

There are several psychological challenges first-generation students may experience that can possibly carry over as they enter the workforce. It can be a strange feeling landing a job and knowing that you make more than your parent(s)/caretaker(s) who’ve been making ends meet to take care of you thus far. Unfortunately, with that may come feelings of guilt and betrayal because no one wants their family to feel like they’re being left behind by their child who’s off living comfortably on their substantial income – even if it may not be the case.

Furthermore, in settings perceived as competitive – much like the workplace – first-gen professionals may be more susceptible to imposter syndrome – feelings of being a fraud or undeserving of one’s position. Needless to say, for any employee that’s been evaluated as experienced and qualified for their job, these sentiments should not persist. So, here’s how employers can help:

Recommendation #3: To provide additional support  first-generation employees may need, companies should establish Employee Resource Groups (ERGs) for this population. In doing so, employers can develop a culture in which first-generation professionals feel integrated, supported, and recognized. It’s important to create these spaces so that first-gens can connect with one another and have a platform in which they can highlight areas of need which may have gone unnoticed.

4. Thin Network

Where does networking start for new college graduates? With their family, perhaps their university. Well for first-generation students, access to professional and/or alumni connections through family isn’t usually an option. How much do we hear “It’s not about what you know, it’s about who you know”? The weight one’s network has on their employability is undeniable, and good references and letters of recommendations are essential to improving candidacy. Employers should take steps to address the inequity that first-gen students face in this aspect by thinking carefully about references and referral programs (which have their own DEI concerns). Here is one recommendation:

Recommendation #4: Include “first-generation student/professional” in self-ID rubrics. You should offer applicants the chance to share whether they identify as a first-generation student and/or professional. This is even more important if you ask “Do you have or ever had a relative that worked for one of our services/companies?” Like all self-identification questions, it should be voluntary and subject to appropriate privacy protections. These measures can help contextualize third-party application materials and/or questions and allow employers to track outreach to and engagement with this particular demographic.  

5. Misunderstanding of Work Experience

For recent grads, employers like to see experiences such as internships, research, and organizational leadership to determine employability – but there are more kinds of experience that can prepare someone to be successful in the workplace. While in school, first-generation students may have an increased need to support themselves; research has shown that first-gen students tend to work jobs outside of their institution and much longer hours than non-first-gen students. A focus solely on internships or specific pre-hire experiences could disadvantage first-generation students that perhaps worked at their local grocery, or were baristas at Starbucks — rather than working an unpaid internship or in research labs. Experience working in retail, hospitality, or many other kinds of jobs can yield valuable skills in problem-solving, interpersonal relationships, and responsibility. Focusing too narrowly on certain kinds of qualifications could limit the pool of talent being considered. Here is our final recommendation:

Recommendation #5: Employers should 1) explicitly ask entry-level applicants to list “all work experience” and 2) understand the value different experiences bring. These adjustments will allow you to gauge the full value of your talent pool. It is important to give entry-level applicants a chance to share  their transferable skills and experiences and consider what they might bring to your organization.

About the Lead Author

Name: Xavier Walker

Position: Undergraduate Intern, Summer ‘22

School: Texas A&M University

“As a first-generation student and having friends that are as well, I knew there were challenges we faced going into the workforce that I really wanted to unpack. Interning with Working IDEAL allowed me to learn a lot about how Diversity, Equity, and Inclusion translates into the workplace and therefore helped me formulate where the problem areas were for first-gen students. I am grateful for the expert team at Working IDEAL because they understood the need, and immediately worked with me on this project.”

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Working IDEAL provides trusted and innovative advice on inclusive workplaces, diverse talent, and fair pay. Our audits and assessments apply the best thinking on how to promote gender, race and other forms of equity in your pay practices. Our robust quantitative and qualitative reviews go beyond basic compliance to align effective compensation strategy. Contact us for more details. 

7 Ways to Promote Diversity, Equity, and Inclusion in Hiring

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Authors: Ahmmad Brown and Sarah Crawford

In today’s competitive job market, employers can deploy a range of strategies to attract and recruit diverse talent. The following recommendations – broken into the recruitment, candidate evaluation, and process maintenance phases – offer best practices and considerations to develop a recruitment and hiring protocol to ensure diversity, equity, and inclusion (DEI) throughout the process.

Apply a DEI Lens to Your Recruitment. The work of retaining top talent begins before you even post your job. In most cases, the job description (along with your website and other marketing materials) is one of the first interactions potential candidates will have with your organization. 

1. Update job descriptions and requirements to attract a diverse applicant pool.

Before advertising a job opening, evaluate the position description and requirements to reduce bias and increase the pool of talent that could apply and compete. Unnecessary experience and education requirements will limit your ability to attract a wide array of talent and bring new skills, experiences, and perspectives into your organization. Consider the job description, especially if you have not updated competencies and requirements lately. What skills and competencies are required to be successful in executing the role and responsibilities? How much experience is needed, and how broadly can experience be described? For technical roles, are there options to train high-potential candidates for specific technical requirements? Pay close attention to how you define qualifications and competencies and the use of tests and other evaluations for hiring. Is the language inclusive and designed to attract a diverse candidate pool? Have you avoided phrasing and words that tend to discourage women and people of color from applying?

2. Be intentional about outreach and recruiting strategies.

DEI objectives should be a part of every step in the recruitment and hiring process and should specifically include outreach to diverse communities and organizations. Identify organizational needs–such as languages, relationships to different immigrant communities, communities you aspire to serve. Then build recruitment strategies designed to fill those needs. Recruit explicitly to reach diverse audiences. Go beyond personal contacts, word of mouth, and usual posting avenues. Use recruitment firms and platforms that can reach more broadly. Develop sustained relationships with diverse communities, industry associations, and affinity-based networks to seek out talent from underrepresented groups. Deploy strategies specific to the roles you are recruiting for rather than using generalized DEI posting tactics for all jobs.

Make Your Screening and Interview Process Fair and Equitable. Racial, gender, and other biases can arise in candidate evaluation – as human resources professionals and hiring managers across industries know well. You can counteract these biases by implementing hiring processes that emphasize inclusivity and avoid the pitfalls of groupthink.

3. Establish a diverse hiring committee and provide necessary training.   

Establish a hiring committee that is charged with handling all steps of the process, including outreach, recruitment, interviews, and selection. Ensure that the committee’s membership is diverse, for example, by race, gender, function, and level. A committee can serve the organization as a whole – for all hires over a certain period of time — or can be specifically developed to fill a job opening. The committee should follow a consistent process and be involved in initial screening, interviews, and evaluation. Make sure that the committee members have training and tools to fairly screen, interview, and evaluate candidates based on objective criteria – including an understanding of how to identify and disrupt bias in hiring.

4. Implement a diverse interview slate policy.

A diverse interview slate policy ensures that the “slate” of finalists receiving interviews with the final decision maker is diverse. This is more than just ensuring an overall diverse applicant pool. Define the diverse interview slate in advance. For example, a diverse interview slate might be defined as a pool of interview candidates that includes multiple women and multiple people of color to ensure the default does not favor white men. A human resources official can review the candidates included on the interview slate and determine whether the slate satisfies the policy. The hiring committee should not have access to self-identification data, nor should they “guess” or assume identity. If the slate does not reflect the policy, take steps to expand the interview slate.

5. Hiring committees should use objective evaluation criteria and avoid groupthink.

Consider options to remove names and other identifying information from applications and resumes before the committee reviews them. Require that all individuals involved in interviews use standardized, behaviorally-anchored questions that relate to the job. Panelists should evaluate candidates independently using objective criteria before conferring. Ensure that screening, evaluation, and interview practices are equitable and inclusive and provide fair opportunities to all qualified applicants. Ensure consistency and accountability across the organization for hiring managers to practice the same protocols – there can be no exceptions, which can lead to disparities and perceptions of unfairness.

Create Accountable and Effective Tools to Keep Your DEI Goals On Track. Achieving DEI goals requires commitment and attention to DEI outcomes and DEI processes. Your work does not end with the completion of any single hire or recruitment cycle. Rather, you will want to track your organization’s progress over time in relation to clearly defined DEI by creating an infrastructure and processes to collect data at all stages of your hiring process. Remember to be transparent with your key internal and external stakeholders about your progress over time. This will build trust with your current employees, and indicate your commitment to DEI for future candidates.

6. Conduct a barrier analysis on each step of the hiring process.

Conduct an analysis to determine whether any step in the hiring process favors or disfavors candidates based on gender, race, ethnicity, or other criterion.
Evaluate measures of representation at different phases of hiring: – Who are the applicants?
– Who are the applicants who meet minimum qualifications?
– Who is selected to proceed past the initial screening?
– Who passes any tests or other steps?
– Who is included on the interview slates?
– Who receives offers?
– Who is hired?

Use metrics for each step of the process to ensure there is no adverse impact in your selection practices. Each step of the selection process should use job-related factors and criteria. If there is no adverse impact of any step in your process, the individuals selected at each phase should generally reflect the demographics of the job applicants in the pool. Ask applicants to self-identify and track demographics of applicants and hires, including who passes initial screening, who the finalists are, who receives an offer and who accepts and is hired. For individuals you reject, use disposition codes to track the reasons they did not advance. If you see a significant disparity between the demographics of the applicant pool and the candidates who are selected for hire, determine what is happening at each step, what criteria are being used, who the decision-makers are, and any tests or requirements that may be leading to particular groups being screened out at a particular step. In other words, identify barriers that may be causing the disparities, and determine whether changes to the hiring process could help to ensure equity.

7. Use benchmarking to set transparent goals and evaluate hiring over time. 

Regularly analyze your workforce demographics by department and level within the organization: – Where does your workforce reflect the diversity of the available talent pool, and where does it fall short? 

– Who is in entry level positions?
– Who is in leadership?
– Who are your highly compensated employees?
– Who are your low wage employees? 

– Are there unexplained gaps?
– Who declines offers and why? Are they disproportionately women and/or people of color? What are their reasons? 

Get feedback from staff on what is working well in your hiring process, and what is not working and make improvements. In setting hiring benchmarks, evaluate the appropriate measure of the qualified, available applicant pool. Consider aspirational measures, such as having your organization reflect the constituencies it represents. Benchmarks typically vary by job group and may include national measures for jobs you recruit nationally for, and also potentially your local labor markets. The Census and other data sources provide demographic data by occupation, industry, geographic area, etc. Growing numbers of employers are moving toward public reporting of workplace demographics to build in greater transparency and accountability for meeting DEI benchmarks. As the old saying goes, what gets measured gets done.

When employers are intentional, transparent, and accountable in efforts to implement best practices like these, they can make great strides to promote diversity, equity, and inclusion within their organizations through improved hiring protocols.

 

Working IDEAL provides trusted and innovative advice on inclusive workplaces, diverse talent, and fair pay. Our audits and assessments apply the best thinking on how to promote gender, race and other forms of equity in your pay practices. Our robust quantitative and qualitative reviews go beyond basic compliance to align effective compensation strategy

How the Rooney Rule Can Advance Equal Opportunity

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Author: Cyrus Mehri

As football fans gear up to watch the Rams and the Bengals clash in the Super Bowl this weekend, there’s another showdown happening off the field: the debate on how to best combat racial discrimination in the NFL. 

It’s a debate that has implications that extend beyond the football field and into board rooms across corporate America. Football, like many other industries, faces a glaring problem: despite diversity and inclusion efforts, many companies have failed to adequately increase racial diversity in their senior ranks.

The NFL’s hiring practices have come under intense scrutiny after a racial discrimnation lawsuit by Coach Brian Flores. Specifically, some advocates have called on the NFL to abolish the Rooney Rule, a rule that requires NFL teams to conduct in-person interviews with a diverse slate of candidates when hiring head coaches and general managers. 

Versions of the Rooney Rule have been adopted across many industries, so this discourse has significant implications and represents an ongoing debate: how do companies best establish equitable and inclusive practices that will increase diversity? 

As one of the creators of the Rooney Rule, I’m intimately familiar with this debate. I, along with late Johnnie L. Cochran Jr, advocated for the creation of the Rooney Rule starting in 2002 in response to the dearth of Black coaches in the NFL. And the Rooney Rule has had success.

Before the Rooney Rule, there were only a handful of Black head coaches in the NFL’s 80 year history. In the 19 years since the creation of the Rooney Rule, a person of color has been selected as an NFL head coach 27 times, including twice this month. That’s infinitely better than it was before, but it’s also significantly below where it should be. 

Clearly, the NFL still has a lot of progress to make. But abolishing the Rooney Rule would be a huge backslide. The Rooney Rule has taken the NFL from an abysmal situation to a better one, and it has the potential to truly transform the NFL — and other industries — if utilized in the right way. 

In my work across companies and across industries as a civil rights litigator, consultant and a reformer, I have learned a number of lessons on how the NFL, and other industries, can do the Rooney Rule the right way: 

Accountability Matters: First and foremost, accountability is key. This is the NFL’s current biggest area for improvement. In the early years of the Rooney Rule, the NFL strongly enforced the rule, but recently, it has turned a blind eye to blatant violations. No policy can be successful without enforcement.

Diverse Slates of Finalists, Not Diverse Pools of Applicants: Saying you have a “Rooney Rule” isn’t enough. Several major companies such as Facebook have established weak or symbolic versions of the Rooney Rule, like having a diverse pool of applicants while saying nothing about the finalists. The Rooney Rule requires interviewing a diverse slate of candidates for the final round. Don’t be fooled by what some companies say — if it’s not a finalist interview slate, it’s not likely to move the needle.

Address Bias in the Pipeline: There’s a bias in the pattern of NFL teams excluding coaches of color from the QB position coach and offensive coordinator, which results in those coaches also being excluded from the head coach pipeline. Programs dedicated to developing a diverse talent pipeline, such as the Arizona Cardinals QB Coach fellowship, and strong recruitment programs can help avoid a situation where companies claim there aren’t any outstanding candidates of color. 

Use Multiple Candidates from Underrepresented Groups: A study in the Harvard Business Review showed that when there are two or more candidates of color, a candidate of color is over 190 times more likely to be hired. The Rooney Rule has been updated to include multiple underrepresented candidates in the final interview pool, and with that modification, there are signs of success with women and people of color gaining ground as team presidents and other key positions. Any company using a Rooney Rule type policy should do the same. 

Start with Leadership, Then Expand: Companies should be strategic about which jobs should have a diverse interview slate requirement – starting with the key leadership positions where they are less likely to have diversity now and where the impact of each hire is greatest. At first, the NFL kept it just to Head Coach, then added General Manager. Now it extends throughout the League office and the Club levels to all senior leaders and now coordinators and it is reaping the benefits in many key areas. Changing how a company selects its leaders — and who they select – creates critical buy-in at the top and establishes this as part of organizational values.   

Use Diverse Interview Panels: Many companies use diverse interview panels as part of the decision making process with great success. The NFL has not done so and should.

Use Better Selection Criteria: Diversity is stymied unless decision-makers expand their talent pool by expanding the criteria used for a key position. There are a lot of skill sets and experiences that can lead to success, even if they’re not the ones traditionally used to fill a position. Continuing to select the talents a company already has actually reduces the overall quality of its hires, especially if the criteria have not been reconsidered recently. Use an open mind and open up the process. 

Use Common Sense Guidelines: The first year of the Rooney Rule, Jerry Jones interviewed a white candidate for two days in person and a Black candidate by phone for just half an hour. We called on the League to develop common sense guidelines and they did. There is still room for improvement to ensure that interviews are being held as genuine interviews, not just to tick boxes. 

Whether in the NFL, or in companies large or small, we can achieve a level playing field and an inclusive economy if we stick to the principles of fair competition and implement the Rooney Rule the right way. 

 

Photo credit: REUTERS / Alamy

 

Building a Culture Code to Promote Respect in the Workplace

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Authors: Sarah Crawford and Christian Andres Alfaro

A strong culture code—which alternatively may be called a code of conduct or civility code—sets expectations about how employees should interact in order to create a healthy workplace culture. A culture code can help to foster a safe and constructive working environment in which all employees feel accepted and supported to better serve the mission of the company. A code also bolsters accountability at all levels within the organization. 

A culture code should communicate the company’s mission, vision, goals, values, and norms. The code also can build community and describe the spirit and traditions of the organization through quotes, lighthearted anecdotes, and stories. For example, the code could tell the story behind the founding of the company, stories of individual customers and clients, or of accomplishments both big and small.

A culture code establishes expectations for employees to be respectful and accepting of others who may come from different walks of life and have different lifestyles and beliefs. A code can set expectations about positive behaviors by encouraging employees to act as allies to confront bias, to serve as a mentor, to utilize best practices to promote diversity in hiring, etc.

The code also should provide examples of bias and behavior that will not be allowed or tolerated in the workplace, such as microaggressions, harassment, discrimination, and retaliation. The code should address behavior directed toward anyone, regardless of whether they are colleagues, supervisors, junior staff, interns, volunteers, independent contractors, customers, clients, etc. The code should set out policies and processes for individuals to bring forward concerns and formal complaints and identify key personnel to handle those concerns and complaints. 

The code should address conduct that occurs not only in the workplace, but also offsite and online, for example expected behavior at conferences and respectful communication on social media and text messages. The code should also address conduct during and outside of regular work hours, for example conduct at a work-related social event or with a colleague after normal working hours. 

During the process of drafting a culture code, employees should be involved in providing input and feedback on the content. This may be accomplished by convening a working group that includes employees representing various levels, departments, job functions, and locations. This is particularly useful to identify key concerns, gaps, and solutions for the organization. The code should be written in plain language that is easily understood and uses examples tailored to the workplace. 

Leadership should review, approve, and endorse the code before it is finalized. An introduction from the head of the organization can communicate the importance of the code and the core values to the day-to-day operations and to make clear that inappropriate behavior will not be tolerated. It is also critical for those at the top of the organization to model the positive behaviors described in the code.

When rolling out a new culture code, employees should participate in interactive training to review the content, to reinforce how the expectations about behavior relate to the organization’s mission and core values, to teach skills, and to provide opportunity for meaningful discussion. The code, policies and procedures, contact information for key personnel to handle complaints and concerns, and any other related information should be easily accessible to all employees, either online or in writing. 

To reinforce the principles on an ongoing basis, the code should be integrated with the onboarding process and regular training programs. Employees could be asked to sign a statement that they have read and agree to follow the code. A poster in the breakroom could highlight the key aspects of the code, such as core values, expected behaviors, and contact information for key personnel to handle concerns and complaints. At events, remarks and written materials could include a reminder of behaviors that are encouraged and behaviors that will not be tolerated, consistent with the culture code. 

Building a strong workplace culture requires the efforts of every employee in the organization. By setting expectations about employee behavior, a culture code can provide a powerful tool to promote a respectful workplace that is key to fulfilling the mission of the organization.

Resources and Sample Codes:

Racial Equity Assessment Can Change Your Company for the Better – If You Get It Right

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Authors: Pamela Coukos and Ahmmad Brown

If 2020 was the year of big, visible corporate commitments to racial equity, 2021 is the opportunity to make sure those commitments deliver on their promises.

In the aftermath of the murder of George Floyd and the increased impact of the Movement for Black Lives, companies promised to take meaningful action and deploy substantial financial resources to address racial inequity and injustice. This spring BlackRock responded to shareholder advocacy and agreed to undertake a comprehensive racial equity audit of internal structures and policies, and the external impact of their products and services. Last fall, JP Morgan made a $30 million commitment to advance racial equity. In the technology industry, at least a dozen companies have made commitments to racial equity specifically. McKinsey estimates that organizations have made as much $200B in investments to support racial justice efforts since May 2020.

Although public commitments to support racial equity and justice are laudable, there are three ways these programs can fail to live up to their promises. 

First, vague appeals to morality and justice are not enough – an organization needs a clear reason to take action and a defined goal they seek to achieve. Otherwise their response may be more symbol than substance.

Second, organizations must establish accountable, transparent structures and processes to evaluate their actions and ensure that they are on track to meet those goals. Lack of follow through can erode trust and credibility among key stakeholders and undermine the benefits of the work they seek to accomplish.

Third, many organizations take the easier path of surface-level questions and avoid deeper issues of racial justice, hostile culture, and structural barriers to equity. Expanding the representation of people of color in candidate pools and recruitment pipelines is important, but cannot build sustainable change without tackling the fundamental question of whether the organization’s core structures and processes are equitable and inclusive for current and future Black, Indigenous, and People of Color (BIPOC) employees and other stakeholders. 

Racial equity assessment is a set of tools that addresses these pitfalls and can increase the chances that commitments to racial equity generate deep and lasting success for the organization and its people. 

An assessment helps keep a program on the path of substance over symbols. It starts by identifying the organization’s goals, in order to decide how to measure progress and evaluate impact.

A well-designed assessment ensures accountability through key practices that build trust and ensure credibility including:

  • an external independent assessment team;

  • an objective and neutral inquiry process based on a sound methodology;

  • appropriate transparency to all stakeholders;

  • a demonstration that the information sharing process is safe and can be trusted.

Finally, an experienced and effective assessment team will encourage clients to go deeper, and are equipped to evaluate structures and practices, not just outcomes.

And they will pay off in actionable recommendations, strategic plans to meet important goals, and all the benefits of inclusive and equitable organizations — more innovative products and services, a more engaged and productive workforce, stronger and more sustainable financial performance and most importantly, the trust that comes from knowing an organization’s practices live up to its values. 

Customers, investors and employees who value racial equity have growing expectations of the companies they do business with. Showing that commitments are meaningful and have an impact is the best way to meet this moment.

Working IDEAL provides trusted and innovative advice on inclusive workplaces, diverse talent, and fair pay. Our audits and assessments apply the best thinking on how to promote gender, race and other forms of equity in your pay practices. Our robust quantitative and qualitative reviews go beyond basic compliance to align effective compensation strategy with mission and values. Contact us to learn more about the services we offer.

About the authors:
Ahmmad Brown is a Senior Advisor at Working IDEAL, Executive Director and co-founder of EBDI Consulting, and currently completing doctoral work in organizational behavior at Harvard.
Pamela Coukos, JD, PhD, is CEO and co-founder of Working IDEAL

10 Steps Toward Equal Pay: A Call to Action for the Biden Administration

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March 24 will mark another Equal Pay Day, which signifies how far into the year women must work to earn what men earned in the previous year. Pay gaps for women of color are even greater. Without decisive action, these persistent pay gaps will not close for decades. To move the dial on equal pay, the Biden Administration should take these critical steps:  

1. Support passage of the Paycheck Fairness Act.

Passage of the Paycheck Fairness Act, which was first introduced in 2014, is long overdue. This legislation would prohibit retaliation against employees who discuss pay with coworkers and eliminate the perpetuation of pay discrimination caused by employers’ consideration of prior salary. The law would make it easier to challenge systemic pay discrimination through class action lawsuits, require legitimate, job-related reasons for pay disparities, and provide the same remedies that are available to employees who file similar civil rights claims.

 2. Reinstitute the collection and analysis of pay data.

The Equal Employment Opportunity Commission (EEOC) should reinstitute pay data collection in line with revisions made to the EEO-1 Survey during the Obama Administration. Pay data should be used to identify significant problems and target enforcement efforts, considering specific challenges and different approaches in particular industries. Aggregate pay data should be published, in keeping with existing practices to identify trends within industries and for particular demographics.

3. Ensure equal pay in federal contracting.

The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) should take critical steps to ensure equal pay by federal contractors. OFCCP could issue executive orders or initiate rulemaking to promote equal pay in a variety of ways. OFCCP could require federal contractors to include compensation analyses in affirmative action plans, publish pay ranges on job postings, include an equal pay certification in affirmative action plans, or make public disclosures about aggregate pay information. Contractors also could be prohibited from considering salary history in setting pay.

4. Require public companies to disclose gender and race pay ratios.

The Securities and Exchange Commission (SEC) can build in sunlight by requiring public companies to disclose gender and race pay ratios and other compensation data on an annual basis. The SEC already requires many publicly held large companies to report on the pay ratio between the CEO’s annual earnings and the median annual compensation for all employees. Such disclosures would empower investors and customers to make informed choices about where to spend their money. The SEC also could provide guidance to companies regarding voluntary reporting on pay equity to investors.

5. Promote best practices and compliance with employers. 

Private sector employers play a critical role in reducing the pay gap, and there are many ways that they can and should take action to ensure equal pay. The Administration should work with high road employers to promote best practices, building on commitments made by employers that signed the Equal Pay Pledge during the Obama Administration. The Equal Pay Pledge includes a commitment to  conducting an annual company-wide gender pay analysis across occupations; reviewing hiring and promotion processes and procedures to reduce unconscious bias and structural barriers; embedding equal pay efforts into broader enterprise-wide equity initiatives; and pledging to take these steps as well as identify and promote other best practices that will close the national wage gap to ensure fundamental fairness for all workers.

The Administration should re-engage with Employers for Pay Equity, a consortium of nearly 40 leading employers committed to collaborating to eliminate the national pay and leadership gaps. These employers come together to share best practices in compensation, hiring, promotion, and career development as well as develop strategies to support other companies’ efforts in this regard.  

6. Conduct outreach to human resources organizations, job search websites, shareholders, and investment firms.

The Administration also should engage with management-side organizations like the Society for Human Resource Management and job search websites like Indeed, LinkedIn, Glassdoor, CareerBuilder, Monster, Google for Jobs, etc. Many of these organizations are taking action on pay equity. This collaboration could promote best practices such as encouraging employers to publish pay ranges, discouraging employers from requesting pay history information, and minimizing discrimination in salary negotiation.

Shareholders also have mounted efforts to request public companies to report the median gender pay gap, equal pay policies, and reputational, competitive, and operational risks, including risks related to recruiting and retaining female talent. Shareholder resolutions have helped to promote pay equity in many sectors and leading corporations. 

7. Reinstitute an equal pay task force to ensure coordination and enforcement of the law.

The Administration should ensure interagency coordination by reconstituting an equal pay task force, including the EEOC, the Department of Labor, the Department of Justice, the Office of Personnel Management, the Government and Accountability Office, and the Securities Exchange Commission. Interagency coordination on outreach, education, and enforcement efforts will maximize the effectiveness of existing authorities. The task force should meet regularly and establish a detailed strategic plan with accountability measures to adhere to established timetables and deadlines for implementation. Each member agency should convene internal working groups focused on promoting equal pay through outreach, education, and enforcement.

8. Ensure that the federal government leads the way as a model employer.

The federal government wields tremendous influence as the employer of millions of workers across the country. The Administration should continue to study causes of the pay gap in the federal workforce, including the impact on women of color, as well as pay gaps within different agencies, industries, and types of jobs. The Administration should identify problematic practices that perpetuate pay discrimination, such as use of prior salary in requesting an exemption to the usual starting salary. The Administration should also implement promising practices that combat pay discrimination. Cutting edge innovations in the private sector should be adopted in the public sector. The Administration should consider implementing bold changes.

9. Reinstate the protections that were provided by the Fair Pay and Safe Workplaces Executive Order.

The Fair Pay and Safe Workplaces Executive Order was rescinded by the Trump Administration and has since rolled into the Fair Pay and Safe Workplaces Act of 2020, which would require prospective federal contractors to disclose labor law violations and give agencies guidance on how to consider labor violations when awarding federal contracts.

10. Issue reports from the National Council of Economic Advisers

Issues of gender and racial equity should be a focus of the Council of Economic Advisers. The Council should issue briefs and reports about trends, causes, and effects of the pay gap, as the Council did during the Obama administration.

Working IDEAL provides trusted and innovative advice on inclusive workplaces, diverse talent, and fair pay. Our audits and assessments apply the best thinking on how to promote gender, race and other forms of equity in your pay practices. Our robust quantitative and qualitative reviews go beyond basic compliance to align effective compensation strategy with mission and values. Contact us to learn more about the services we offer.

Author: Sarah Crawford

Best Practices to Increase Engagement, Productivity, Retention, and Innovation | Excerpts from Diversity, Inc.

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It’s been over a year since noted journalist and scholar Pamela Newkirk published Diversity, Inc., an essential account of the promises many companies made to strengthen diversity, equity and inclusion, the billions spent on programs and initiatives over five decades, and the huge gap that still remains in fulfilling those promises. This acclaimed book, which Time Magazine declared a “must-read”, is a deep study of how the most popular responses to calls for justice and equity at work have not only failed to make progress, but even led to declining numbers of Black leaders in Corporate America, a continued racial wealth gap and pay gap, and persistent discrimination in the workplace. Her book also highlights the rare examples of successful progress and the lessons from social science about what actually works to move the needle on workplace equality. 

In the wake of George Floyd’s murder last summer, companies again, as they have many times in the past, made statements and pledges to do more. While some of the responses are more symbolic, others have greater potential for meaningful impact – from shifts in corporate giving and community support to belatedly addressing longstanding criticisms of images, names and branding, recognizing the need to invest in changing systems and practices, and making concrete commitments to hiring benchmarks or other specific and potentially meaningful policy changes. But as Professor Newkirk shows, Corporate America’s track record on racial justice is not promising. Just as longstanding approaches to sexual harassment were more symbolic compliance than meaningful intervention, the world of diversity consulting is a story of as much as $8 billion a year spent with little to show for it.  So what can companies do that can actually make a difference?

In the new paperback edition of Diversity Inc., Professor Newkirk included a series of best practices provided by Working IDEAL — ways that companies can make good on their promises by applying best practices based on social science research and our experience with organizations large and small across multiple industries. 

Here are a few of those recommended practices that Working IDEAL recommends to our clients to hire and retain great people and increase engagement, productivity, retention, and innovation.  Want the whole list?  Get the book!

Expand Recruitment Through Intentional Outreach. For example, work to build relationships with programs in your field, industry and community to access talent, and then tailor recruitment plans to identify the best sources of diverse candidates for specific jobs or groups of jobs. 

Identify and Remove Barriers in Hiring, starting with how you identify and evaluate skills and criteria. Education and specialized training requirements can serve as unnecessary barriers to increasing diversity in key entry-level and higher-level positions, especially when there are equivalent or alternative skills and experience that may add value, or the potential to invest in on-the-job training.

Institute a “Rooney Rule” diverse slate policy but also take steps to ensure its success. This means defining diverse slates to require consideration of multiple women and people of color, and providing the training and tools for hiring managers and holding them accountable to follow the policy. 

Make information on pay practices transparent and accessible to employees.  Instead of guessing about what candidates will accept, or trying to underpay those with less market power or information, affirmatively provide starting salary information to job candidates.  Ensure employees can freely share information about pay — in most cases it’s legally required.

Measure your results like any business process, auditing your hiring, pay and promotion practices — and your culture and developing metrics to track them going forward. You can use anonymous tools like surveys, and internal discussions across functions and levels, to identify issues and source responses. Track attrition and understand why some groups of employees are more likely to leave. And make sure to regularly share all that information with leaders and decision-makers and use it to hold them accountable. 

Don’t ignore problem behavior. Have safe and accessible options to report, address, and resolve workplace problems, and make sure you act quickly to address toxic or harmful workplace culture at any level of the organization. 

Give people in your organization the power to make change.  If you have named an internal DEI leader or officer, make sure they have the information, access, and power needed to successfully carry out their responsibilities. If you are using an internal committee, resource group or affinity group to support and engage employees, provide the resources and processes that empower them to deliver meaningful value and support to leadership.

Working IDEAL provides trusted and innovative advice on inclusive workplaces, diverse talent, and fair pay. Contact us to learn more about the services we offer.

Author: Pam Coukos

How the SEC Can Harness Shareholder Power to Support Racial and Gender Equity Through a DEI Index

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On its very first day, the Biden-Harris Administration made racial justice and equity, and principles of nondiscrimination and equal opportunity, top priorities on its agenda.  The first of the 17 Day One Executive Orders committed to advancing racial equity and support for underserved communities across the federal government.  The EO requires a review of federal programs and regulatory processes to incorporate equity principles – while rescinding the Trump Administration’s anti-DEI Executive Order. It also includes improvements to data collection, which is a key practice of accountability. Other actions include:

The Administration could bolster this by leveraging the SEC’s  power to regulate publicly traded companies. A Diversity, Inclusion and Equity Index could harness shareholder power to ensure our publicly-traded companies make good on their their commitments to equality. A standard set of disclosures about hiring, representation, leadership and pay would empower customers and investors to make informed choices about where to spend their money. Workers could use this information to find jobs at places that offer true opportunity for all. Companies would compete to show their progress and we could all have a clearer sense of who is living up to their stated values. Competition would be the engine behind genuine, long overdue progress.

All large publicly traded companies should disclose standard information on key measures of DEI performance.

First, demonstrate Board Accountability for DEI, by sharing Board representation, whether the Board uses key best practices to foster diverse membership, and whether the Board provides effective oversight of People and Culture programs to address workplace harassment and promote inclusive culture.

Next, provide data on Leadership Diversity, including how the top 200 highest compensated individuals identify (by gender, race, ethnicity, and if available, by disability and sexual orientation).

Third, disclose Workforce Diversity and Pay Equity metrics, including companywide EEO-1 representation data and standard pay equity benchmarks similar to those already reported in the UK, and corporate performance on its own diversity metrics over time. 

Lastly, share progress on Inclusive Workplace Practices, including whether the company has developed and implemented key best practices to address workplace harassment and promote inclusive culture.

We already recommended that the SEC impose this type of requirement, but there are plenty of other ways this could come about. Indexes could make this a listing requirement. Institutional investors could use it as a factor for their portfolio decisions and federal, state and local agencies could use it as a benchmark in awarding contracts. And companies could voluntarily commit to these disclosures as a way to demonstrate leadership. 

The biggest winners will be the companies themselves. The research we shared with the SEC supports the view that diverse teams can provide key benefits, like increasing productivity and innovation. Strengthening DEI can lead to stronger and more sustainable financial performance.

Indeed, that is exactly the reason that this information is material to shareholders. The traditional view of shareholder disclosure is only aimed at information relevant to short-term shareholder gain. But the modern view includes any matters material to other stakeholder long term interests including investing in employees and fostering diversity, inclusion, dignity and respect, an approach championed by the Business Roundtable.

Despite the benefits, too many companies have not made DEI enough of a priority. Reviewing a typical corporate annual report or 10-K will show frequent touting of corporate physical assets, new product lines, mergers and acquisitions, but see very few, if any, words touting new investments in people and culture, or new efforts to develop, retain and strengthen the workforce. Most annual reports to shareholders virtually ignore the companies’ most important asset: its workforce.

We learned that to create change in a company, someone has to own and drive the change, which means the Board should have a specific subcommittee focused on oversight of People and Culture programs, with regular reporting from management on goals and measures. Through increased transparency of key measures of leadership and workforce DEI, we can use the market to move stalled progress on glass ceilings and wage gaps for people of color as well as for women. 

We want to motivate companies to invest in diversity and inclusion, people and culture, growth and retention. It’s good business that can yield an enormous competitive advantage and allow companies to make good on their commitments to equity.

Working IDEAL provides trusted and innovative advice on inclusive workplaces, diverse talent, and fair pay. Contact us to learn more about the services we offer.

Authors: Pam Coukos and Cyrus Mehri

A Just and Inclusive Workplace is Essential to Sustain Our Democracy

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In 2017, the increased public visibility of the #MeToo movement made clear we were not doing enough to make the workplace safe from sexual harassment. In 2020, #BlackLivesMatter organizing similarly forced a broader and overdue reckoning with how deeply racial inequity runs in many institutions — including our nation’s workplaces, which need to be more inclusive.

The images of the first week of 2021 – a Confederate flag carried through the halls of Congress, people in the crowd breaking into the Capitol wearing shirts emblazoned with slogans about genocide of the Jewish people, a Black police officer against a mostly white crowd of insurrectionists – reinforce the urgency of our work to build a just and inclusive society.

As Cyrus said in December, in a recently-published interview in the Wall Street Journal, “Our democracy is not sustainable if don’t embrace equal opportunity.” 

But to do that we need truly innovative approaches. We must expand our thinking about what the barriers are and how to break through them.  As we welcome a new Administration that has committed to make racial justice and economic empowerment top priorities, and a new Congress that can move this agenda forward, we want to highlight some key innovations in government policy and workplace practices that can have the biggest impact.

1. Have the Security and Exchange Commission require transparency on diversity and inclusion. All large, publicly traded companies should make standard disclosures about hiring, representation, leadership and pay. As Cyrus explained to the Journal:

Merge SEC disclosures—annual reports, 10Ks—with advancing equal opportunity. For example, require companies to disclose race and gender data for their top 200 highest-paid employees. It’s a way to understand where the glass ceiling is. Do it by total compensation so it includes stock options. It’ll tell you who’s in the decision-making pool of the company. 

And as we explained in our 2016 proposal to the SEC, this empowers investors, workers, customers and community stakeholders  to make informed choices about where to spend their money.

2. Make your default hiring practices more inclusive, by ensuring you interview multiple women and people of color.  Cyrus explains why this disrupts default assumptions:

If you have one woman versus two women on a slate, when you go to two women, it’s 79 times more likely that a woman will be selected [than if there was only one woman in the pool]. When you go from one to two people of color, the number goes up like 190 times. If there are multiple diverse candidates, they’re multiple times more likely to be hired. Why is that? When you have isolated, coveted jobs, you need to do something to change the norms because the presumptions and stereotypes are so deeply rooted. 

Congress can lead the way by adopting the Rankin-Chisholm rule for its own hiring (a “Rooney Rule” for the Representatives), and by encouraging members to practice #CampaignEquity when they run for re-election.  

3. Make our nation’s first civil rights law a more effective tool for racial justice, so it can work to close the racial wealth gap, ensure real equal access to credit, capital, employment and economic participation. Amending Section 1981 would enable it to live up to its promise.

4. Understand how building racial justice at work includes ensuring fair pay. As Pam shared in an online presentation last fall:

Make equity a top priority when you make decisions, take actions, design programs and measure results. Gender, race, sexual orientation, disability, or any aspect of your identity should not determine your outcomes in the workplace – including pay.

The Administration can do its part by reinstating and expanding pay data collection and reinvigorating equal pay enforcement – and by ensuring that we do not just talk about the gender pay gap. We must recognize and address pay gaps based on race and ethnicity and the particular impact of both on women of color.

5. Promote an inclusive workplace culture free of harassment, bias and discrimination – starting with the people who do the people’s work in our federal and state governments.  Assessing culture, ensuring inclusive policies and practices, and acting quickly to address disrespectful behavior before it becomes toxic should be standard practice. President Biden should consider an Executive Order directing all federal agencies to adopt effective initiatives to promote equal employment opportunity and inclusive workplaces, and revoking a series of anti-DEI actions from the fall.

At the end of the day, Cyrus’ observation from December of 2020 seems even more true in January of 2021: 

There is a moral case for diversity and inclusion. And there’s a business case: long-term value is tied to diversity and diversity is tied to innovation. But the last few years have told us there is a democracy case, too.

 

Working IDEAL provides trusted and innovative advice on inclusive workplaces, diverse talent, and fair pay. Contact us to learn more about the services we offer.

Authors: Pam Coukos and Cyrus Mehri