Sponsors are required to engage in outreach and recruitment activities designed to reach all demographic groups within the relevant recruitment area and need to ensure that their programs offer equal employment opportunities to all apprentices and applicants. Further, sponsors required to maintain Affirmative Action Plans may need to set race, sex, ethnicity, or disability utilization goals – if they find that their programs underutilize any of these particular groups. However, these goals are not quotas; they do not provide a sponsor with justification to extend a preference to any individual on the basis of a protected characteristic, nor do they permit sponsors to create set-asides for specific underrepresented groups. For example, the regulations make it clear that sponsors should notestablish separate ranking lists based on protected characteristics.
May apprenticeship programs give a hiring preference to underrepresented populations (such as women or minorities) in their programs?
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As a general rule, sponsors should engage in broad-based advertising efforts to ensure that their recruitment efforts extend to all persons available for apprenticeship. Sponsors must provide recruitment sources advance notice, preferably 30 days, of apprenticeship openings and must include their equal opportunity pledge in their opportunity announcements.
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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.
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Sponsors are allowed to select apprentices through any selection method, as long as it does not discriminate on any of the protected bases and complies with the requirements for selection devices under the Uniform Guidelines on Employee Selection Procedures and the Americans with Disabilities Act. Additionally, selection methods must be uniformly and consistently applied to all applicants and apprentices and be facially neutral with respect to the protected bases. Read Selecting Apprentices for Registered Apprenticeship Programs for more details on this topic.
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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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