It is accurate that if you are covered by the affirmative action law for individuals with disabilities, you must make all parts of that AAP except the data components available for review to applicants or employees. It is also accurate that if you are covered by the affirmative action law for protected veterans, you must make all parts of that AAP except the data components available for review to applicants and employees. You are not required to provide copies of the AAPs to applicants or employees, and you are not required to provide the data components of the AAPs to anyone except OFCCP. Executive Order 11246 does NOT have a parallel provision requiring the disclosure of information in that AAP. It may be good practice to make your affirmative action/equal opportunity policy statement available to applicants and employees, and there may be other policies associated with the Executive Order AAP that you might want to make available to demonstrate your commitment to affirmative action and equal opportunity. However, you are technically not required to make ANY part of the Executive Order AAP available to applicants or employees or outsiders of any kind other than OFCCP. You should tell the minority group that has approached you that the Executive Order AAP contains a variety of trade secrets and other information by law, and thus you are not in a position to provide the AAP to them.

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.