1. Recruitment Practices

2. Training

  • Develop, participate in and/or upgrade training opportunities (on-the-job training, apprenticeships, etc.) to ensure minorities and women are included. (41 CFR 60-4.3(a)7.e.)
  • Document training efforts and track attendees. Download sample Employee Activity Tracking Log
  • Communicate on-the-job training and apprenticeship opportunities to recruitment sources, at least one month prior to accepting applications. (41 CFR 60-4.3(a)7.i.) Download sample Outreach Letter or Email

3. EEO Policy & Implementation- Click here to review EEO Policy Dissemination requirements

  •  Development & Dissemination of Policy
  •  Review of Policy
  •  External Dissemination of Policy                                   
  •  Promotion Policy
  •  Supervisory Performance

4. Personnel Operations

  • Ensure EEO/Affirmative Action policy statement covers maintaining a working environment free of harassment, intimidation and coercion (41 CFR 60-4.3(a)7.a.)
  • Maintain Employee Data (41 CFR 60-4.3(a)7.k.)
  • Monitor all personnel and employment related activities to ensure procedures do not have a discriminatory effect where there is an obligation to do so under 41 CFR part 60-3 (41 CFR 60-4.3(a)7.m. & 41 CFR 60-4.3(a)7.k.)
  • Ensure non-segregation of facilities and document announcement of company activities posted to all employees (41 CFR 60-4.3(a)7.n.)

5. Contracting Activity

  • Document and maintain records of outreach with minority and female owned businesses (41 CFR 60-4.3(a)7.o.)

Additional Requirements

  • Participation Goals for Females & Minorities – Goals are expressed as a percentage of the hours worked by the contractor’s aggregate workforce in each trade on all construction work performed in the geographic area

– Goals for females is 6.9% Nationwide

– Goals for minority utilization are listed in Appendix E of the Technical Assistance Guide for Federal Construction Contractors.

  • Ensure EEO contract and purchase order clauses are up-to-date
  • Maintain a list of all Federal projects, including contract numbers, locations, estimated dollar values, percent completed and projected completion dates as well as a list of non-Federal projects
  • Notify OFCCP of awarded construction subcontracts of $10k or more within 10 business days. Download sample Construction Contract Notification.
  • Ensure compliance with record keeping obligations. We recommend keeping records for 3 years.
  • 503 and VEVRAA written affirmative action program

– 503 – 50 or more employees and contracts or subcontracts of $50k or more

– VEVRAA – 50 or more employees and a contract or subcontract of $150k or more

For more information on Federal construction contractor requirements, please see the Technical Assistance Guide for Federal Construction Contractors.