Affirmative Action Policies and Regulations
As a Federal contractor, UIC is subject to regulatory requirements under the laws enforced by the Department of Labor's Office of Federal Contract Compliance Programs (OFCCP). The OFCCP enforces Executive Order 11246; Section 503 of the Rehabilitation Act of 1973; and the affirmative action provisions of Section 4212 of the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA). Collectively, these legal mandates prohibit discrimination and require Federal contractors and subcontractors to take affirmative action to ensure equal employment opportunities, without regard to race, color, religion, sex, national origin, disability, sexual orientation, gender identity, or status as a Vietnam era or special veteran.
Executive Order 11246 prohibits federal contractors, subcontractors, and federally-assisted construction contractors and subcontractors with contracts that exceed $10,000, from discriminating in employment decisions on the basis of sex, sexual orientation, gender identity, race, color, religion, or national origin. It also requires covered contractors to take affirmative action to ensure equal opportunity is provided in all aspects of their employment. Covered supply & service contractors holding a contract of $50,000 or more must prepare a written annual affirmative action plan under EO 11246.
The Rehabilitation Act of 1973, Section 503, requires employers with federal contracts or subcontracts that exceed $15,000, including construction contractors, to ensure nondiscrimination in employment on the basis of disability and take affirmative action to hire, retain, and promote Individuals with Disabilities (IWDs). Covered contractors holding a contract of $50,000 or more must prepare a written annual affirmative action plan for individuals with disabilities.
VEVRAA requires federal contractors and subcontractors with contracts or subcontracts of $150,000 or more, including construction contractors, to ensure nondiscrimination in employment on the basis of Protected Veteran (PV) status and take affirmative action to employ and advance in employment Disabled Veterans, Active Duty or Wartime Campaign Badge Veterans, Armed Forces Service Medal Veterans, and Recently Separated Veterans (those discharged from the Service in the past three years). Covered contractors holding a contract of $150,000 or more must prepare a written annual affirmative action plan for protected veterans.
OAE monitors UIC's Academic Hiring process for compliance with Equal Employment Opportunity and Affirmative Action laws and regulations related to the analysis of employment data, search review and approval, assistance with recruitment plans to attract applicants from under-represented groups, and proper record-keeping requirements.
In addition to the records an employer is required to compile and maintain to support the AAPs (41 CFR 60-1.12, 41 CFR 60-2.17(d), 41 CFR 60-300.80, and 41 CFR 60-741.80), the employer should also keep materials evidencing its affirmative action efforts. This can include items such as:
- Copies of collective bargaining agreements and other documents that indicate employment policies and practices;
- Copies of letters sent to suppliers and vendors stating the EEO/affirmative action policy;
- Copies of letters sent to recruitment sources and community organizations; and
- Copies of contract language incorporating the regulatory equal opportunity clauses (41 CFR 60-1.4, 41 CFR 60-300.5, and 41 CFR 60-741.5).