Sample EEO Policy and EO Clause Language

Federal affirmative action regulations mandate that Federal contractors include an Equal Opportunity (EO) clause in all contracts, subcontracts and purchase orders.  The intent is to make the nondiscrimination and affirmative action provisions of Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, the Vietnam Era Veterans’ Readjustment Assistance Act, and the Jobs for […]

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If my company falls under AAP regulations but my business unit or location does not have any federal contracts do I still need an AAP for that location?

A separate business or organization without Government contracts may be covered under the laws enforced by OFCCP based on an integrated relationship or “single entity” status with a Government contractor. OFCCP uses a five-factor test for determining whether such a relationship exists. The test requires OFCCP to consider whether: the entities have common ownership; the […]

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What are affirmative action good faith efforts?

Good faith efforts can be described as goal-setting efforts to eradicate and prevent discrimination in the hiring process.  One way of accomplishing this is through outreach.  This entails developing targeted, meaningful relationships with different organizations that can assist in getting job openings in front of a diverse applicant pool.  We have provided a couple of tools to […]

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How do I document outreach?

If it isn’t documented, it didn’t happen.  That is the short answer as to why it is important to document all outreach efforts.  Outreach logs will also allow us to perform analytics to more closely understand which of your outreach efforts is providing qualified applicants and which ones are not.

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What forms do I need for applicants to self-id?

Affirmative action employers are required to give all applicants who meet the OFCCP’s definition of applicant the opportunity to self identify race, gender, veteran, and disability status.  If an applicant chooses not to self identify any or all of these categories the employer has still met their tracking obligations and needs to do nothing further. […]

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What are best practices in affirmative action recruiting and hiring?

To have a successful recruiting strategy, we must create a clearly defined Recruitment and Hiring Process utilizing a multi-step process. Steps may include: Advertising our open positions to attract a diverse candidate pool, including: Professional Organizations Publications Associations representing diversity groups Job Fairs The Department of Labor website Utilizing our professional networks Evaluate all open […]

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What is the OFCCP definition of an internet applicant?

Office of Federal Contract Compliance Programs (OFCCP) regulations require covered federal contractors and subcontractors to collect information about the gender, race, and ethnicity of each “applicant” for employment. The final rule modifies OFCCP applicant recordkeeping requirements to address challenges presented by the use of the Internet and electronic data technologies in contractors’ recruiting and hiring […]

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How should a federal contractor post jobs?

As a federal contractor there are some guidelines for posting open positions. Let’s start by reviewing the basic posting requirement.  Under VEVRAA, Federal contractors are required to post “all employment openings” with the appropriate Employment Service Delivery Systems (ESDS) where the job opening occurs.  In this context, “all employment openings” means all job openings with […]

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Can we use a third party for state job postings?

An entire industry has sprung up around fulfilling these job posting requirements.  OFCCP’s regulations have been updated to account for the use of these private, 3rd party job listing services.  Use of such services will be considered satisfactory as long as the 3rd party service is posting in a “manner and format permitted by the […]

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