NT Lakis attorneys and non-attorney professionals are pleased to present the next guide in our “AAP Tune-Up” series designed to provide employers with actions they can take during their annual affirmative action plan (AAP) cycles to help ensure compliance with the regulatory requirements enforced by the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP). Our “Tune-Up” guides focus on things a federal contractor can do that are not required by OFCCP regulations, but which if implemented can help minimize problems that might otherwise arise in the event of an OFCCP compliance audit.
In this latest memo, we focus on “good faith efforts,” the outreach and recruitment initiatives that OFCCP expects a contractor to undertake in order to address underrepresentation of women or minorities in its workforce. By way of a “mini-audit,” we suggest actions a contractor can take to evaluate the sufficiency of its good faith efforts.
Members of the Equal Employment Advisory Council (EEAC) can read more here.