In the event of an OFCCP audit, your actual promotion activity will be reviewed by the OFCCP and it will be compared against the definition you have provided. Any discrepancies in applying the definition to your promotion decisions would be red flagged and result in further investigation.
HR Guide to Promotions for Federal Contractors
About the Author: James Gutierrez
President, Career Resources IncNationally recognized expert on Affirmative Action Plans♦ ADA Web Compliance ♦ Equal Employment Opportunity ♦ Sexual Harassment Prevention Training