My program already complies with Equal Employment Opportunity Commission (EEOC) and Office of Federal Contract Compliance Programs (OFCCP) requirements and state laws on discrimination. Is there more I need to do to comply with these regulations?

Equal Employment Opportunity

Yes. All Registered Apprenticeship Programs need to take some additional steps that are not required by EEOC and OFCCP.  These include:

  • Clearly stating that discrimination is prohibited in recruiting, hiring, training, assigning, evaluating, promoting, disciplining, rewarding, or terminating apprenticeship applicants or apprentices on any of the following bases:  race, color, religion, sex (including pregnancy, sexual orientation, and gender identity), national origin, age (40 and older), sexual orientation, disability, and genetic information
  • Posting their equal opportunity pledge; assigning an individual to coordinate Equal Employment Opportunity (EEO); maintaining an outreach and recruitment list; and providing anti-harassment training to all individuals associated with the apprenticeship program, including all apprentices and journeyworkers who regularly work with apprentices

In addition, under 29 C.F.R. 30.4, apprenticeship EEO regulations require sponsors with five or more apprentices to create and maintain an Affirmative Action Program, including a written Affirmative Action Plan.  Sponsors are exempt from this requirement if they can demonstrate that they have an existing compliant Affirmative Action Program covering apprentices, including the use of goals for underrepresented groups, under either (a) Executive Order 11246 and section 503 of the Rehabilitation Act or (b) title VII of the Civil Rights Act of 1964 if the sponsor extends the Affirmative Action Program to include individuals with disabilities.

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