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

Yes. The exemption is based on the total number of apprentices per sponsor – not per employer.  Thus, if the number of apprentices in the sponsor’s program is five or more, the sponsor is required to maintain an Affirmative Action Program.  Regardless of the number of employers or the distribution of apprentices across them, if the total number of apprentices is five or more, the sponsor is required to have an Affirmative Action Program.

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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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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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The apprenticeship Equal Employment Opportunity regulations require certain Registered Apprenticeship Program sponsors to develop Affirmative Action Programs.  An Affirmative Action Program assists sponsors in detecting, diagnosing, and correcting any barriers to equal opportunity that may exist in its apprenticeship program.  Further, an Affirmative Action Program is designed to ensure equal opportunity and prevent discrimination in apprenticeship programs.  A sponsor’s written Affirmative Action Plan states the specific steps sponsors will take to ensure all qualified applicants and apprentices receive equal opportunity to be selected for – and succeed in – Registered Apprenticeship Programs.

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