What needs to be in a sponsor’s written Affirmative Action Plan?

Equal Employment Opportunity

The written Affirmative Action Plan must include the following components:

Workforce analyses for race, sex, and ethnicity (comparing the workforce and availability analyses)
Utilization goals for race, sex, and ethnicity (if necessary)
Utilization goals for individuals with disabilities
Targeted outreach, recruitment, and retention activities (if necessary)
Review of personnel processes
Invitations to self-identify as an individual with a disability

Each of these components requires a sponsor to examine different elements of its apprentice workforce, document its review, and determine whether any element of its program is adversely impacting individuals within certain groups. A guide preparing sponsors to develop their plans is available on the Create Your Plan Equal Employment Opportunity webpage.

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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
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Sponsors required to develop Affirmative Action Programs must conduct an annual review of their personnel practices to help ensure the program is free from unlawful discrimination. This must be a careful, thorough, and systematic review of all aspects of the program, including, but not limited to:
- Qualifications of apprentices
- Application and selection procedures
- Wages
- Outreach and recruitment activities
- Advancement opportunities
- Promotions
- Work assignments
- Job performance
- Rotations among all work processes of the occupation
- Disciplinary actions
- Handling of requests for reasonable accommodations, and
- The program’s accessibility to individuals with disabilities
The written Affirmative Action Plan must include a description of the review the sponsor undertook, and any modifications made to its practices as a result of the review.
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No. Each sponsor simply needs to maintain an up-to-date plan and make it available to the Registration Agency upon request, including during its compliance review.
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The Affirmative Action Program is the general activities that sponsors engage in to support equal opportunity in recruitment and hiring of all qualified individuals.

The Affirmative Action Plan is the written documentation of these activities. Sponsors do not need to submit the Plan to the Registration Agency but must make it available upon request, including during compliance reviews.
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What needs to be in a sponsor’s written Affirmative Action Plan?

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