Under Executive Order 11246, all employers with 50 or more employees and Federal Contracts over $50,000 are required to have an Affirmative Action Program for each of its locations that have over 50 employees. In addition, a separate program is required under Section 503 of the Rehabilitation Act of 1973 and a separate program is required under the Vietnam Era Veterans' Readjustment Assistance Act of 1974 (38 U.S.C. 2012).

The Affirmative Action Program is subject to a compliance review, usually conducted by the Office of Federal Contract Compliance Programs (OFCCP) which consists of a desk audit, on-site review and, where appropriate, off-site analysis.

The written program determines the availability of minorities and women for positions in the various EEO-1 categories. This availability is then measured against the Company's actual work force to determine if there is underutilization in any of the categories. If there is underutilization, Goals and Timetables must be developed to implement strategies to attract qualified candidates that will reduce and eliminate underutilization.

Action programs to obtain your Goals and Objectives must be implemented. Specific statements must be included regarding the Company's commitment to Non-Discrimination, Affirmative Action and the Dissemination of Policy. A system of internal audit and reporting systems must be established.

In addition, plans must be written for compliance with regards to the Handicapped and Vietnam Veterans. There are no statistical requirements for these two plans.

IMA will be responsible for implementing an Affirmative Action Program that will fulfill your organization's obligations under the various regulations. This includes:

1. Coordination with management in establishing the program's goals, schedule, procedures, etc.

2. Perform the factor analysis to determine the availability of employees by job group.

3. Assist in the data gathering needed of Company's employees and provide forms to ease this process.

4. Write the Affirmative Action Plan as required under Executive Order 11246, as amended.

5. Write the Affirmative Action Plan required by Section 503 of the Rehabilitation Act of 1973, as amended.

6. Write the Affirmative Action Plan required by the Vietnam Veterans' Readjustment Assistance Act of 1974 (38 U.S.C. 2012).

7. Review documents and procedures for compliance with various EEO/AAP requirements.