Have you ever gotten that call from the Office of Federal Contract Compliance Programs (OFCCP) asking how you are doing on your affirmative action plan? Were you prepared for your affirmative action plan to be reviewed? If not, here are some steps that may help you get your affirmative action plan in order.
When the OFCCP comes calling, their claimed purpose is to review a company’s minority and female utilization and compliance with the EEO clause in your contracts. Of course, the OFCCP will not simply accept your word that you are complying. Instead, you must show your compliance through documentation.
Probably the most significant request from the OFCCP is compliance with 41 C.F.R. 60-4.3(a)(7)A-P. These sixteen steps require contractors to not only take action, but document that they have complied with a number of the affirmative action steps. A few of these requirements include:
- Ensure and maintain a working environment free of harassment;
- Establish and maintain a current list of minority and female recruitment sources;
- Maintain a current file of the names, addresses, and telephone numbers of each minority and female off-the-street applicant; and
- Develop on-the-job training opportunities and/or participate in training programs for the areas which expressly include minorities and women.
Annually maintaining documentation supporting each of the regulation’s requirements will go a long way in satisfying the OFCCP that you not only have, but practice non-discriminatory hiring and working practices.