Recently the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has been issuing Notices of Violation to and subsequently settling cases with contractors based on the allegation that the contractors have been involved in “steering” their applicants or employees. In these cases the OFCCP alleges that the policy or practice of the contractor directed or steered one group of applicants (women) to take a certain targeted job and directed or steered another group of applicants (men) to take another targeted job. If the pay in one of these targeted jobs is higher than the other targeted job, then the OFCCP argues that the policy or practice has been discriminatory.

On November 4, 2013, the OFCCP announced that G&K Services Co. had agreed to settle a steering alle