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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The written Affirmative Action Plan must include the following components:
- Workforce analyses for race, sex, and ethnicity (comparing the workforce and availability analyses)
- Utilization goals for race, sex, and ethnicity (if necessary)
- Utilization goals for individuals with disabilities
- Targeted outreach, recruitment, and retention activities (if necessary)
- Review of personnel processes
- Invitations to self-identify as an individual with a disability
Each of these components requires a sponsor to examine different elements of its apprentice workforce, document its review, and determine whether any element of its program is adversely impacting individuals within certain groups. A guide preparing sponsors to develop their plans is available on the Create Your Plan Equal Employment Opportunity webpage.
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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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The Affirmative Action Program is the general activities that sponsors engage in to support equal opportunity in recruitment and hiring of all qualified individuals.
The Affirmative Action Plan is the written documentation of these activities. Sponsors do not need to submit the Plan to the Registration Agency but must make it available upon request, including during compliance reviews.
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