The OFCCP uses a questionnaire to determine when a subsidiary company's government contracts implicate the parent or a subsidiary company's government contracts implicate other sister subsidiaries. https://webapps.dol.gov/elaws/ofccp/fcca/assessment.asp This typically requires the employer to gather the facts in response to the questions and then seek a legal opinion about whether the facts support a single entity conclusion. If there is any way for you to take this question out of the public forum and ask it privately, I would encourage you to do so.
You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.
