1. Affirmative ActionPlan Education forManagersGabriela RosasHuman Resource Vice President

2. Overview Who is Covered Requirements Monitoring Overriding Self Identification Compliance Assistance 3. Who is Covered All contractors and subcontractor who hold a Federal orfederally-assisted construction contract in excess of $10,000 Any organization that is subject to civil rights requirementsenforced by OFCCP Businesses or organizations that do not hold governmentcontracts/subcontracts that may still be covered under lawsenforced by OFCCP if they are considered a single entity 4. Requirements Under EO 11246 if we have more than 50 employees we arerequired to develop a written Affirmative Action Program foreach it the establishments within 120 days from the start ofthe contract It is suggested that employers create and follow an internalaudit and reporting system to make necessary changes,improvements and maintain compliance Posting of EEO posters, this is in accordance with the lawsadministered by OFCCP Posted prominently where it can be readily seen by employeesand applicants EX. Breakroom, officers, bulleting boards 5. Monitoring Compliance Evaluation is a combination of four investigativeprocedures: Compliance Review Comprehensive analysis of practices Begins with desk audit (review of AAP) Off-Site Review Review of records that could consist of a full desk audit Focused Review On site review restricted to one or more components ororganizations practices Compliance Check Determining if contractor has maintained consistent records 6. Overriding Self Identification Q: May an employer override an individuals self-identificationof race, gender or ethnicity based on the employers visualobservation? A: NO! OFCCPs policy is that deference should be give to anindividuals self-identification and it SHOULD NOT bequestioned or overridden by an employer 7. Compliance Assistance Additional OFCCP requirement education can be obtained byvisiting local OFCCP and register for seminars or visit: http://www.dol.gov/ofccp/regs/compliance/faqs/emprfaqs.htm#Q26 8. Conclusion Who is Covered Requirements Monitoring Overriding Self Identification Compliance Assistance