Do We Need an AAP?

Some employers choose to develop an Affirmative Action Plan (AAP) simply because they know it is a useful tool for organizational analysis. Most, however, develop a comprehensive affirmative action program (of which an Affirmative Action Plan is a critical part) because they do business with the federal government -- and it's the law.

If you are an employer with a federal contract or subcontract, you are obligated to comply with federal nondiscrimination and affirmative action laws and regulations.

Your company must maintain a written Affirmative Action Plan for each of its establishments if your company or its parent corporation is a federal contractor or subcontractor with 50 or more employees AND:

• has a federal contract or subcontract of $50,000 or more; or
  
  
• is a financial institution that is an issuing and paying agent for U.S. Bonds and Savings Notes; or
  
  
• serves as a depository of federal Government funds in any amount; or
  
  
• has government bills of lading that in any 12-month period, total or will likely total $50,000 or more.
  

The Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) administers a number of laws, each with a distinct set of obligations for companies with contracts and subcontracts with the federal government. Before you gear up the compliance forces, we recommend that you verify:

• the dollar amount of your company's federal contracts and/or subcontracts;
  
  
• the number and location(s) of domestic employees in your company;
  
  
• any parent or subsidiary relationships between your company and another with a government (sub)contract;
  
  And then:
  
  
• visit the Department of Labor's "eLaws" website to determine your company's basic compliance obligations.

Or, if you'd prefer, feel free to call us for guidance.

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