1. Recruitment Practices
- Establish and document outreach efforts
- Maintain Applicant Flow Log, including walk-in applicants
- Notify OFCCP if union(s) referral process has impeded efforts to meet obligations (41 CFR 60-4.3(a)7.d.)
- Document encouragement of employee referrals. (41 CFR 60-4.3(a)7.j.) Download sample Employee EEO & AA Notification and Employee Activity Tracking Log
- 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.)
- 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.