The concept of enterprise-wide enforcement has been around in one form or another for years at OFCCP. In the late nineties it took the form of “global agreements,” in the early 2000’s the concept emerged in initiatives to “connect the dots” and in the present administration it has surfaced under the term “enterprise-wide” enforcement. In addition to resolutions specifically tagged as part of these initiatives, there have always been multiple facility settlements. The common denominator is the attempt to resolve similar enforcement problems at several of the contractor’s facilities using a single negotiation process.
The purpose of this article is to explore the issues that arise in the context of enterprise-wide agreements. Specifically, it will discuss how a contractor is selected for an enterprise-wide enforcement effort, what the agreements are designed to achieve, how these agreements are negotiated and what structures could be put in place to enhance the process.
Currently there is no separate, special selection procedure for identifying targets for enterprise-wide enforcement. The