Where do these Employees belong in an AAP?
The OFCCP requires a facility/location with fifty or more employees to prepare and implement an affirmative action plan annually. If a company has multiple facilities/locations and one or more of these employ less than fifty individuals, while these employees are required to be accounted for in an affirmative action plan, there are a few options for including them.
- Although not required, the contractor has the option of preparing a separate affirmative action plan for any facility/location with less than fifty employees. This option could be helpful in terms of disseminating goals and responsibilities and would make sense if there is a possibility that a facility/location would reach the fifty employee threshold soon.
- These employees can be included in the AAP of the facility where they report into.
- These employees can be included in the AAP of the facility where the human resources function occurs.
- These employees can be included in the AAP of the facility that would make the most sense geographically.
The AAP you decide to capture these employees will be based on what makes the most sense for a contractor in terms of their company structure, taking into account what would result in the most meaningful analyses.