CREATIVECOUNT is an accounting services firm which operates in all 50 states and has over 10,000 employees. They are proposing the below HR policy. Where does the policy violate law and/or practical management?

A continuous improvement evaluation and layoff policy is written as: Each year, you will be evaluated by your immediate supervisor. Evaluations will occur, over time, on the basis of seniority, with those of greater seniority being evaluated before those with lesser seniority. Layoffs will be based solely on the basis of the most recent evaluation and seniority will not be considered at all during the layoff decision making process.