The deadline for sponsors registered with the national Office of Apprenticeship to put an initial Affirmative Action Program in place is two years after a program’s registration date, or two years from the date the program registers its fifth apprentice – whichever is later. The Affirmative Action Program deadline for sponsors registered with State Apprenticeship Agencies depends on their state Equal Employment Opportunity plan.
When do Affirmative Action Programs need to be in place?
Equal Employment Opportunity
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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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All sponsors who are not otherwise exempted are required to develop and maintain an Affirmative Action Program. Each sponsor must develop its own Affirmative Action Program, even if employers participating in the sponsor’s program maintain Affirmative Action Programs.
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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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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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