Time & Attendance
By Jon Hyman
Dec. 18, 2014
If you are a federal contractor of subcontractor, in four months you will have new affirmative action obligations relating to sexual orientation and gender identity.
According to a Final Rule issued last week by the Office of Federal Contract Compliance Programs, beginning April 5, 2015, federal contractors and subcontractors must include sexual orientation and gender identity in their affirmative action plans.
According to the Rule, which implements Executive Order 13762, federal contractors and subcontractors must:
Notably, and different than affirmative action for other protected traits, the Rule does not require contractors to set placement goals on the bases of sexual orientation or gender identity, nor does it require contractors to collect and analyze any data on these bases (although the OFCCP will consider statistical and non-statistical data in determining whether contractors have met their nondiscrimination obligations).
While Congress continues to drag it feet on Employment Non-Discrimination Act, the Obama Administration continues to do what it can to extend equal employment opportunity for all.
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