Sponsors should make good faith efforts to seek alternative or additional sources that are more effective at referring diverse qualified applicants. The Office of Apprenticeship has provided information and online resources to sponsors regarding recruitment sources. During compliance reviews, sponsors would only be expected to describe their good faith efforts to recruit diverse apprentices.
If the sources that a sponsor is using to meet its outreach and recruitment obligations are not generating referrals from the various demographic groups in the sponsor’s recruitment area, what should the sponsor do?
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Yes. Background checks are allowed, with a few caveats. First, sponsors should indicate what type of background check they mean (e.g., criminal, credit, etc.) and what they mean by “passing it.” For example, descriptions might include “no felony conviction within the last seven years,” “no drug convictions,” or “no conviction of any kind within the last five years.”
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If the requirement to have a driver’s license impacts any protected group adversely, such a requirement should be validated to ensure it is job-related and consistent with business necessity. For example, an apprenticeship program that involves traveling to different sites may require apprentices to use personal or company transportation to these sites. If driving is not an essential function of the job, the requirement to have a driver’s license may not be consistent with business necessity and may adversely affect certain individuals with disabilities or other protected groups.
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The Office of Apprenticeship has developed the Universal Outreach Tool to help all sponsors – of large and small programs – identify qualified talent from all parts of their typical recruitment area. The tool can be accessed from the Universal Outreach Tool link on the Apprenticeship Equal Employment Opportunity Recruit and Hire webpage.
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Under the Equal Employment Opportunity regulations for Registered Apprenticeship Programs, sponsors must develop and update annually a list of current recruitment sources that will generate referrals from all demographic groups within the relevant recruitment area. Examples of relevant recruitment sources include the public workforce system’s American Job Centers and local workforce development boards; community-based organizations; community colleges; vocational, career, and technical schools; pre-apprenticeship programs; and Federally-funded youth job training programs such as YouthBuild and Job Corps or their successors. The Office of Apprenticeship (OA) has developed a Universal Outreach Tool to assist sponsors in expanding their outreach and recruitment efforts. The tool can be accessed from the Universal Outreach Tool link on the Apprenticeship Equal Employment Opportunity Recruit and Hire webpage.
OA encourages program sponsors to post their apprenticeship openings with their respective state job banks and local American Job Centers. For more information about posting opportunities with state job banks, please visit the Career One Stop site.
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