The most well-known and also the most controversial type of affirmative action program is the target system. For instance, if a company has a history of not promoting women to upper management, it may implement an affirmative action program to recruit and hire more women for top roles. The company can set goals such as, for example, employing a 50% female staff within five years. Courts have ruled that this type of program is legal as long as the targets are goals and not quotas. If the company chooses a qualified woman over a qualified man to help it meet its goal, that decision would be legal. It would be illegal to choose an unqualified woman solely to meet a fixed quota. Another common type of affirmative action program is to change the way the company recruits new employees. For example, a company seeking to hire more women might send representatives to a job fair at an all-female college or might send announcements of new job openings to a woman's organization. A company seeking to recruit more minority applicants would use a similar strategy to reach out to minority groups. Instead of blindly placed advertisements for job openings, companies intending to diversify can target their advertising to particular groups. Another common affirmative action program is to review the company's hiring and promotion policies for any unfair barriers to women or minorities. For instance, if the company tends to promote those who never take sick days or use vacation time or maternity leave, some women may be placed in a position where they must choose between family responsibilities and career goals. It is legal to consider gender as a factor to promote diversity. It is not legal to base decisions solely or primarily on gender.