As a federal supply and service contractor or subcontractor, you are required by 41 CFR Part 60 to develop and monitor a written Affirmative Action Program if you meet the following criteria:

The company employs 50 or more people on a regular basis.

Total contracts/subcontracts or bills of lading in a year are valued at $50,000 or more.

The AAP must fulfill all requirements from the Executive Order 11246 (women and minorities), Section 503 of the Rehabilitation Act of 1973, Vietnam Era Veterans Readjustment Assistance Act of 1974 (VEVRAA), and Americans with Disabilities Act of 1990 (ADA).

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Covered federal contractors must comply with the Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, and the Vietnam Era Veterans Readjustment Assistance Act of 1974, while federally-assisted contractors must comply with the Executive Order 11246 only. To comply with the Executive Order, contractors must demonstrate good faith efforts to meet their affirmative action goals for the employment of minorities and females in the workforce.Who is a covered contractor under Executive Order 11246? A company that has:

  • A Federal construction contract or subcontract of over $10,000;
  • A federally-assisted construction contract or subcontract of over $10,000;
  • A construction contract or subcontract of over $10,000 with a Federal non-construction contractor or subcontractor, if the construction contract/subcontract is necessary in whole or in part to the performance of the Federal non-construction contract or subcontract;
  • Multiple contracts or subcontracts that when totaled for a twelve month period, are greater than or equal to $10,000.
  • Contractors or subcontractors are covered under Section 503 if the have a federal construction contract or subcontract in excess of $50,000.
  • A contractor or subcontractor is covered under VEVRAA if they have a federal construction contract or subcontract of $100,000 or more.

Federally and federally assisted construction contractors and subcontractors who are subject to OFCCP requirements have contractual obligations to comply with the applicable OFCCP-administered laws governing equal employment opportunity and affirmative action. Additionally, covered contractors and subcontractors must comply with these regulations at all company work sites, not just the federal construction sites. See our Construction Contractor Compliance Obligations page under Products and Services for more information about Construction Obligations.

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Personnel Activity Monitoring

As a federal contractor, several analyses must be periodically conducted, such as utilization reports and statistical analyses including an impact ratio analysis. We suggest these be done quarterly to monitor for adverse impact or other potential indications of discrimination.  Dyas HRD is experienced in conducting these analyses and interpreting the results.  We have the capability to fulfill all self-monitoring obligations.  We provide you with scheduled reports so that you can stay on top of your company's EEO and affirmative action profile, allowing you to make changes promptly when needed and be aware of where you are doing well. 

Report Filing

Contractors must file an annual EEO-1 Survey (Standard Form 100), as well as a Vets-4212 Report.  Depending on the structure of your company, this may entail filing numerous reports, typically, separate EEO-1 and Vets-4212 reports for each location.  Dyas HRD files these reports electronically and provides you the necessary documentation to demonstrate compliance.  

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Compensation 

Compensation discrimination is a key enforcement initiative of OFCCP.  It is critical that you take the steps to ensure that your compensation practices are nondiscriminatory and you are in compliance with regulatory requirements.  All federal contractors should periodically review their compensation procedures and practices.

Dyas HRD conducts compensation analyses of employee pay data that comply with OFCCP's current compensation guidelines. We interpret the results and provide guidance to help maintain compliance.  We also prepare compensation data to submit for agency compliance reviews.

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Affirmative Action and EEO

We provide EEO and Affirmative Action training for managers and supervisors so that AAP requirements are understood and implemented. In this training, we review what managers and supervisors must know in all phases of the employment process, including the hire, promotion, termination, and transfer practices.  It defines discrimination and provides case studies for reference. 

Anti-Harassment

Contractors must maintain a work environment free from harassment, intimidation, and coercion. Dyas HRD conducts training to inform managers, supervisors, and employees on what constitutes harassment and trains each group on their responsibilities and duties.  We can work with you to develop a customized training program to meet your organization's objectives.

We also provide training on the Internet Applicant Guidelines and proper record keeping practices. See more details on our Products and Services page.

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It is often beneficial to retain an outside firm to investigate internal employee complaints or to investigate complaints filed directly with the OFCCP, EEOC, or a State Human Rights Agency.  Dyas Human Resource Development (Dyas HRD) provides complaint investigation services and provides input on resolutions, based on current OFCCP policies and guidance. Our goal is to provide your company with a plan of early internal intervention by implementing strategic planning, formal complaint procedures, and a straightforward investigative process that will save your company time and money.  This straightforward approach provides employees the reassurance that the company takes their complaint seriously and that their complaint will be handled professionally and promptly, which can reduce the number of complaints that involve outside agency involvement.

We are highly trained and experienced in conducting non-biased complaint investigations that include a written onsite plan and follow-up investigative report with recommendations for corrective action. Sound investigative procedures and an experienced investigator allow for any issues to be revealed and corrected, which in turn allows your company to retain valued employees and helps foster a well-motivated and productive workforce. 

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The Office of Federal Contract Compliance Programs (OFCCP) evaluates federal contractors' compliance with specific federal regulations.  With a combined 80+ years of direct OFCCP experience between our consultants and staff, Dyas HRD knows the range of information to be evaluated, as well as the proper procedures involved in the evaluation process.  

With this knowledge and experience, Dyas HRD has the ability to perform mock audits/evaluations in the same manner that OFCCP would.  The typical course of action for this service begins with a desk audit of your Affirmative Action Programs, personnel activity, and compensation information to identify problem areas and help determine if an onsite visit by the OFCCP could be required.  We can also conduct a facility inspection and conduct interviews with employees to parallel a full OFCCP compliance review.  We provide a written report of our findings, identifying any areas of concern or possible violations and make recommendations for corrective action.

Mock audits help the company focus attention on the areas of non-compliance and take the necessary corrective action without the consequences of being cited by government agency.   The mock audit also helps demonstrate good-faith efforts at self-monitoring.

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Government contractors and subcontractors are obligated to list all job openings with the local state employment service.  Additionally, contractors and subcontractors must establish a network of recruiting sources likely to refer qualified minorities, females, veterans, and individuals with disabilities for open positions within their companies.  Each time there is an open position, the company should actively list the position and make good-faith effort to recruit with the established network so to pursue referrals of qualified covered class candidates for the positions.  

Over the last decade, Dyas HRD has established a network of thousands of good-faith referral sources, and now has the means to conduct all good-faith job postings, recruiting and networking correspondence, and associated documentation maintenance.  This support service is designed to be supplemental to normal recruiting and is specifically designed to be integrated into the standard recruiting protocol.   This program is a robust, efficient, and a very cost effective method of good-faith recruiting and associate compliance efforts.  Please see our product and service details for more information about these obligations and associated services.

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