We'll wait to hear how this all shakes out. In the meantime it's a good reminder that if you have affirmative action obligations, like Google, it's critical you maintain a compliant affirmative action plan. Being out of compliance can be costly.
Do You Have Affirmative Action Obligations?
If you, your suppliers, or your customers do business with the federal government, you could be subject to federal affirmative action requirements. You could be a covered federal contractor if your organization:
Has at least 50 employees; and
Does at least $50,000 in business with a federal agency or with that agency’s customers or suppliers.
If so, then federal regulations require you to prepare a written affirmative action plan (AAP) and comply with all of the requirements for recruiting, keeping records, analyzing hiring activity, reviewing job duties, comparing compensation, and more.
Not Sure if You Are a Covered Federal Contractor?
Contact Karen Davis, our Senior Employment Attorney and Affirmative Action Director.
Risks of Not Complying
The Office of Federal Contract Compliance Programs (OFCCP) conducts random affirmative action audits of covered employers and also accepts complaints from applicants and employees. The OFCCP can review your employment records going back up to two years. As we regularly report in our newsletter, the OFCCP obtains financial settlements from employers whose hiring activity or compensation shows unexplainable differences based on race or gender. The agency also requires affirmative action outreach and recordkeeping for protected veterans and people with disabilities.
Get Help Now
We've been helping employers with affirmative action compliance for over 40 years now. Learn about our affirmative action services available to members (at a discounted rate), and non-members. And, watch out for an invitation to our May 23, 2017, affirmative action update webinar.
This website presents general information in nontechnical language. This information is not legal advice. Before applying this information to a specific management decision, consult legal counsel.