Beyond the AAP
This list is not all inclusive, but is representative of program areas that OFCCP commonly investigates during Compliance Evaluations:
EO Clause
Contractors must include the Equal Opportunity clause in every subcontract or purchase order so that the subcontractor or vendor may become aware of its compliance obligations. It is a common practice during a compliance evaluation to be asked for a copy of a current subcontract or purchase order to verify that it contains the current EO Clause or language incorporating it by reference.
EO Tagline
Contractors must include in their advertisements for employment a nondiscrimination statement:
“All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, protected veteran status, or on the basis of disability.”
Note: Other versions of a nondiscrimination statement may also be used.
Invitation to Self-Identify
Self-Identification is the preferred method for obtaining demographic information for applicants and employees. The process is voluntary, and the information is needed for the EEO-1 report, and the AAP. Contractors are required to provide an opportunity for people to self-identify their race/ethnicity, gender, disability, and protected veteran status, during the employment application stage, and post offer/pre-employment stage of the recruitment and selection process.
Notices posted
Pursuant to the provisions of the EO Clause, contractors are required to post notices the Director of OFCCP prescribes. These notices are to be posted in conspicuous places, available to both applicants and employees, in your usual format (electronic and/or paper).
The “Pay Transparency Nondiscrimination Provision,” and “EEO Is the Law” Poster and Poster Supplement are currently required to be posted.