Federal contractor rules for an Affirmative Action Plan
The internal audit and reporting system is the contractor’s way to assess the overall effectiveness of the Affirmative Action Program and advise senior management of the effectiveness of the Affirmative Action Plan…
If you are a non-construction contractor/subcontractor with 50 or more employees you are required to develop a written Affirmative Action Program for each of your establishments within 120 days from the start of the Federal contract, if it:
• Has a Federal contract or subcontract of $50,000 or more;
• Has government bills of lading which in any 12-month period total, or can reasonably be expected to total, $50,000 or more;
• Serves as a depository of Federal funds in any amount; or
• Is a financial institution that is an issuing and paying agent for U.S. savings bonds and savings notes in any amount?
As a Prime Contractor, are you required to make sure that the vendors and suppliers have a written Affirmative Action Plan?
You are not required to ensure that your vendors and suppliers develop and maintain written Affirmative Action Plans. The regulations require that each contractor and subcontractor include the Executive Order clause in each subcontract or purchase order. Whether a vendor or supplier is subject to the written Affirmative Action Plan requirements, would depend on whether the vendor or supplier has a subcontract that is necessary to the performance of the Government contract, the dollar value of any such subcontract, and the number of employees in the vendor’s or supplier’s workforce.
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