Legal interface - Affirmative Action Plans

Please note and put in a file for me regarding Enron AAPs. That obviously will be of significance to me in my new role. Thanks. MHC

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Michelle Cash
Enron North America Corp.
1400 Smith Street, EB 3823
Houston, Texas 77002
(713) 853-6401
michelle.cash@enron.com

This message may contain confidential information that is protected by the attorney-client and/or work product privileges.
----- Forwarded by Michelle Cash/HOU/ECT on 06/09/01 12:26 AM -----

Rick Johnson/ENRON@enronXgate 06/01/01 12:43 PM To: Andrea Yowman/ENRON@enronXgate, Michelle Cash/HOU/ECT@ECT, Sharon Butcher/ENRON@enronXgate, Kriste Sullivan/ENRON@enronXgate cc: Sandra Lighthill/ENRON@enronXgate, Valeria A Hope/ENRON@enronXgate Subject: Legal interface - Affirmative Action Plans

Andrea, in response to Michelle's concerns about legal review of our Affirmative Action Plans, Please consider the following:

Background:
? Affirmative Action Plan development is supported by specific software that was implemented in January 2000.
? The Plans consist of two primary elements, the narrative portion and the statistical portion.
? Narrative was reviewed for legal merit in January 2000 by George Chaffee, Attorney at Law, Littler Mendelson, Walnut Creek, CA and by a local consultant, George Pharis, President, Strategic Direction Resources Inc.
o Recommended changes were incorporated into the FY 2000 AAPs. The narrative section of an AAP is generally the same each year with few changes necessary.
? The statistical portion requires an intense amount of labor each year. The database of the plan has to be confirmed for accuracy
? Plans are reviewed against the previous year's AAP for continuity
? Once we have drafts of the AAP (narrative and statistical portion) for a business unit:
o Draft plan and a memo are sent to the business unit HR head for review
o HR head requests any changes and confirms their buy-in before the plan is finalized and distributed to their organization
o Execution signatures are obtained
o Plans are distributed to management level employees to guide their hiring/promotion and termination decisions throughout the course of the plan year.
o Quarterly utilization reports are completed and sent to the business units to allow them to track their progress achieving AAP goals
o If a "new goal" is warranted from quarterly reports, it is highlighted for the business unit to consider as they move forward through the rest of the year

Recommendations:

? 02 Plan narratives drafted and reviewed by appropriate legal counsel. (Complete no later than Y/E 2001)
o OFCCP changes to regulations became effective December 13, 2000. New Regs have reduced some narrative
requirements however underlying responsibilities are still implied
? AAP Plan drafts provided to HR Head and respective legal counsel for review, change, and approvals before being submitted for execution signatures
? OLER to revise and communicate new execution milepost to get AAPs completed. Earliest data access date is Jan 15 - (reflecting Y/E promotions, terms etc)

OLER is committed to supporting an effective AAP process for client units. Please assist us by sharing you interests and perspectives on the recommendations offered.

Regards, Rj.

file: oler-core060101
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