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Affirmative Action Plan and OFCCP Guidelines

Anonymous - Oct 14, 2020
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Our entities fall under one parent company, however our entities are all still separate legal entities under the parent company. We have one federal entity under the main umbrella, the other entities are commercial/industrial and do not have any federal work involvement. Should our AAP efforts be focused on our Federal contractor with regards to the 16 AA steps to compliance? Or it includes our non federal entities as well?

My second part of the question is our federal entity is a construction contractor and we do work for more than $100,000 so I know we should be maintaining and updating our 16 steps to AA compliance, but do we need to have separate AAP’s in place for VEVRAA, and Section 503? If so, are we able to combine plans into 1? Are there helpful resources on how to compile those specific plans if can be combined?

Also to confirm a separate AAP for EO 11246 is only applicable for non construction federal contractors correct?

Thank you

1 Answer

Our Experts

Comprised of former OFCCP directors and respected thought leaders in OFCCP compliance, affirmative action, and EEO.

Ahmed Younies

President and CEO, HR Unlimited, Inc.

Alissa Horvitz, Esq.

Member Attorney, Roffman Horvitz, PLC

Allen Hudson, PHR, SHRM-CP

CEO, HudsonMann

Beth Ronnenburg, SPHR, SHRM-SCP

President, Berkshire Associates

Bill Osterndorf

President and Founder, HR Analytical Services

Carey Freitag

Human Resources Manager, Circa

Carla Irwin, Esq.

President, Carla Irwin & Associates, Inc.

Craig Leen

Board Member, Circa

David Cohen

President and Founder, DCI Consulting

Ellen Shong-Bergman

Former Director, OFCCP and Retired President, Ellen Shong & Associates,

Josh Roffman, Esq.

Managing Attorney, Roffman Horvitz, PLC

Lisa Kaiser, Esq.

Managing Partner, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

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