1 

OFFICE OF FEDERAL CONTRACT 

COMPLIANCE PROGRAMS (OFCCP)

SAMPLE CONTRACTOR AFFIRMATIVE 

ACTION PROGRAM (AAP) 

FOR VEVRAA

(FOR EDUCATIONAL AND INFORMATIONAL PURPOSES ONLY)
2

FEDERAL CONTRACTOR, INC. (FCI)

AFFIRMATIVE ACTION PROGRAM (AAP) 

FOR PROTECTED VETERANS 

(January 1, 2015 to December 31, 2015) 
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I. Table of Contents

I. Table of Contents .................................................................................................................... 3

II. Policy Statement on Equal Employment Opportunity for Protected Veterans [41 CFR 60-

300.44(a)]........................................................................................................................................ 4

III. Review of Personnel Processes [41 CFR 60-300.44(b)]........................................................... 5

IV. Review of Physical and Mental Job Qualification Standards [41 CFR 60-300.44(c)]............... 7

V. Reasonable Accommodation [41 CFR 60-300.44(d)] .............................................................. 8

VI. Anti-Harassment Procedures [41 CFR 60-300.44(e)] .............................................................. 9

VII. External Dissemination of Policy [41 CFR 60-300.44(f)]........................................................ 10

VIII. Outreach and Positive Recruitment [41 CFR 60-300.44(f)]................................................... 11

a. FCI’s Outreach and Positive Recruitment Activities .......................................................... 11

b. Future Assessment of External Outreach and Recruitment Efforts [41 CFR 60-

300.44(f)(3)] .............................................................................................................................. 11

IX. Internal Dissemination of Policy [41 CFR 60-300.44(g)]........................................................ 13

X. Audit and Reporting System [41 CFR 60-300.44(h)] ............................................................ 14

XI. Supporting Data..................................................................................................................... 16

a. FCI Self-Audit (Conducted on 12/15/2014) ....................................................................... 16

b. Personnel Activity (establishment-wide) ........................................................................... 20

c. Applicant flow log .............................................................................................................. 20

XII. Responsibility for Implementation of AAP [41 CFR 60-300.44(i)]......................................... 21

XIII. EEO and Affirmative Action Training [41 CFR 60-300.44(j)].................................................. 22

XIV. Applicant and Hiring Data [41 CFR 60-300.44(k)].................................................................. 23

XV. Hiring Benchmarks [41 CFR 60-300.45]................................................................................. 24

a. Establishment of Hiring Benchmark .................................................................................. 24
4

II. Policy Statement on Equal Employment Opportunity for 

Protected Veterans [41 C.F.R. § 60-300.44(a)]

As the Chief Executive Officer of Federal Contractor, Inc. (FCI), I am committed to the principles of 

affirmative action and equal employment opportunity for protected veterans. Therefore, it is the 

policy of FCI not to discriminate because of protected veteran status and to take affirmative action to 

employ and advance in employment qualified protected veterans at all levels within the company. FCI 

will ensure that all employment actions, including but not limited to recruitment, hiring, selection for 

training, promotion, transfer, demotion, layoff, recall, termination, rates of pay or other forms of

compensation, will be administered without regard to status as a protected veteran. FCI will also 

provide qualified applicants and employees who are disabled veterans with needed reasonable 

accommodations, as required by law, and will ensure that all employment decisions are based only on 

valid job requirements. 

FCI prohibits harassment of employees and applicants because they are protected veterans and will 

conduct training to try to prevent any harassment or discrimination before it occurs. FCI also prohibits 

retaliation against employees and applicants for filing a complaint, opposing any discriminatory act or 

practice, assisting or participating in any manner in a review, investigation, or hearing or otherwise 

seeking to obtain their legal rights under any Federal, State, or local EEO law requiring equal 

employment opportunity for protected veterans. Prohibited retaliation includes, but is not limited to, 

harassment, intimidation, threats, coercion or other adverse actions that might dissuade someone 

from asserting their rights. 

In furtherance of FCI’s policy regarding affirmative action and equal employment opportunity, FCI has 

developed a written Affirmative Action Program (AAP) that sets forth the policies, practices and 

procedures that FCI is committed to in order to ensure that its policy of nondiscrimination and 

affirmative action for qualified protected veterans is accomplished. This AAP is available for inspection 

by any employee or applicant for employment upon request, during normal business hours, in FCI’s 

Administrative Department office located at _____. Interested persons should contact the Human 

Resources Office at ______ for assistance.

In order to ensure employment opportunity and affirmative action throughout all levels of FCI, I have 

designated FCI’s Director of Human Resources as the Equal Employment Opportunity (EEO) Officer for 

FCI. The EEO Officer will establish and maintain an internal audit and reporting system that will track 

and measure the effectiveness of FCI’s AAP and show where additional action is needed to meet FCI’s 

objectives.

Roger Wilco

January 1, 2015

Federal Contractor, Inc.
5

III. Review of Personnel Processes [41 CFR 60-300.44(b)]

To comply with the requirement to “periodically review” its personnel processes, FCI reviews its 

personnel processes annually to determine whether its present procedures assure careful thorough 

and systematic consideration of the qualifications of known protected veterans. As part of this review, 

FCI also ensures that its personnel processes do not stereotype individuals with disabilities in a manner 

which limits their access to all jobs for which they are qualified. This review covers all procedures 

related to the filling of job vacancies either by hire or by promotion, as well as to all training 

opportunities offered or made available to employees. In conducting this review, FCI uses the 

procedures suggested in Appendix C to 41 C.F.R. § 60-300.

Based upon FCI’s most recent review of its personnel processes, FCI has implemented the following 

modifications to its personnel processes to come into compliance: 

1. Ensure accessibility of personnel processes.

FCI will ensure that applicants and employees who are disabled veterans have equal access to all of its 

personnel processes. Although it is not required to do so, as a best practice in furtherance of that 

commitment, FCI is in the process of making its job application, time and attendance, and employee 

benefits electronic systems conform to the Web Content Accessibility Guidelines (WCAG 2.0) 

promulgated by the World Wide Web Consortium Web Accessibility Initiative and will complete these 

upgrades by December 31, 2015. FCI believes that taking these steps now will help minimize the need 

for future reasonable accommodations and facilitate ready access to key systems for many applicants 

and employees with disabilities. Also, as part of the upgrading of our job application system, FCI will 

ensure that human resources office contact information is prominently displayed to facilitate requests

for reasonable accommodation from applicants with disabilities.

2. Invite all applicants to voluntarily self-identify as a protected veteran before an offer of 

employment is made.

On May 1, 2014, FCI began inviting all applicants to voluntarily inform FCI that they are protected 

veterans before an offer of employment is made, in compliance with 41 CFR 60-300.42(a) in the 

manner prescribed by OFCCP. FCI will also continue to invite applicants to self-identify as protected 

veterans post-offer in compliance with 41 CFR 60-300.42(b). FCI provides the self-id form it created 

using the model in Appendix B of 41 CFR 60-300 to all applicants along with FCI’s required paper 

application forms. Additionally, FCI has modified its electronic application system and created a fillable 

copy of the self-id form. FCI also created a separate electronic file where it stores all self-id 

information separate from employment applications, personnel records, and employee medical files.
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3. Modify applicant flow logs. 

FCI recognizes that it must collect applicant and hiring data to comply with the requirements of 41 CFR 

60-300.44(k). In order to facilitate the accurate tracking of applicant and hiring data for protected 

veterans, FCI has modified its applicant flow logs accordingly. (See Part XI. A.) Applicant flow logs will 

be maintained confidentially.

4. Documentation and Assessment of Outreach and Recruitment Activities

FCI has always engaged in positive outreach and recruitment for protected veterans as required by 

OFCCP regulations. FCI has begun documenting each outreach and recruitment activity to comply with 

the requirements of the new VEVRAA regulations, and will conduct an annual assessment to evaluate 

the effectiveness of the totality of our outreach and recruitment efforts, as required by 41 CFR 60-

300.44(f)(3). FCI will institute procedures to comply with the requirements of this part and will 

conduct its first annual assessment with data collected during the 2015 AAP year, starting in 2016.

FCI will evaluate the results of each outreach and recruitment activity using the following criteria, 

which includes data collected under 41 CFR 60-300.44(k), to see if it is producing measurable results:

1. To what extent did the activity attract qualified protected veterans?

2. To what extent did the activity result in the hiring of qualified protected veterans?

3. To what extent did the activity expand FCI’s outreach to protected veterans in the community?

4. To what extent did the activity increase FCI’s capacity/capability to include protected veterans 

in its workforce?

FCI will utilize the same criteria to conduct its annual assessment of the totality of its outreach and 

recruitment efforts. If FCI concludes that the totality of its efforts were not effective in identifying and 

recruiting qualified protected veterans, FCI will explore and implement alternative outreach and 

recruitment methods. FCI will document its outreach and recruitment activities and its assessments of 

these activities, and retain these documents for three years.
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IV. Review of Physical and Mental Job Qualification Standards [41 

CFR 60-300.44(c)]

To comply with the requirement to “periodically review” its physical and mental job qualification 

standards, FCI reviews the physical and mental job qualifications of each job opening before it is 

publicly posted to ensure that, to the extent that such qualification requirements tend to screen out 

qualified disabled veterans, they are related to the job(s) in question and consistent with business 

necessity and the safe performance of the job. FCI also conducts a periodic review of all job 

qualification standards every three years (except for those job qualification standards that FCI has 

reviewed within the previous twelve months) to ensure that, to the extent that such qualification 

requirements tend to screen out qualified individuals with disabilities, they are job-related and 

consistent with business necessity. The last review was completed on December 1, 2014.

Appropriately trained personnel conducted the review and identified no physical or mental job 

qualification requirements that are likely to screen out qualified disabled veterans. Nevertheless, to 

ensure our compliance, FCI strives to use only job qualification standards that are job-related and 

consistent with business necessity. The review found all job qualification requirements to be jobrelated and consistent with business necessity and safety.

FCI will continue to review physical and mental job qualification requirements whenever a job vacancy 

will be filled through either hiring or promotion and will conduct a qualifications review whenever job 

duties change.

No pre-employment physical examinations or medical questionnaires are used in FCI’s hiring process.

If at any time in the future, FCI should inquire into an applicant’s physical or mental condition or should 

conduct a medical examination, FCI affirms that such inquiries or exams will be conducted in 

accordance with the VEVRAA regulations and that information obtained as a result of the inquiry or 

exam will be kept confidential, except as otherwise provided for in the VEVRAA regulations. The 

results of the examination or inquiry will only be used in accordance with the VEVRAA regulations.
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V. Reasonable Accommodation [41 CFR 60-300.44(d)]

FCI will continue its longstanding commitment to making reasonable accommodation to the known 

physical or mental limitations of qualified disabled veterans unless such accommodation would impose 

an undue hardship on the conduct of its business. FCI also commits to engaging in an interactive 

process with the person requesting the accommodation (or their representative), as needed, to 

determine an appropriate accommodation. Undue hardship will be determined by assessing whether 

the requested accommodation, and any other potential accommodations, would cause significant 

difficulty or expense, as provided for in the VEVRAA regulations.

When an employee with a known disability has significant difficulty performing his or her job and it is 

reasonable to conclude that the performance problem may be related to the known disability, the 

employee is confidentially notified of the performance problem and asked if the problem is related to 

the disability. If the employee indicates that the performance problems are related to his or her 

disability, the employee is asked if reasonable accommodation is needed. 

FCI will also ensure that all requests for reasonable accommodation and any medical or disabilityrelated information provided to FCI will be treated as confidential medical records and maintained in a 

separate medical file.

Because FCI strives to be a model employer, it is currently drafting reasonable accommodations 

procedures using the guidance in Appendix B of the Section 503 disability regulations at 41 CFR Part 

60-741. 
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VI. Anti-Harassment Procedures [41 CFR 60-300.44(e)]

Employees and applicants of FCI will not be subject to harassment because of protected veteran status. 

Any employee or applicant who believes that they have been subject to harassment because of their 

status as a protected veteran should promptly contact a manager in their chain of command, or 

promptly contact the Director of Human Resources at 555-555-1213 for assistance. Employees or 

applicants may also file a written complaint with the office of the Director of Human Resources, [insert 

address].

Retaliation, including intimidation, threat, coercion, or discrimination, against an employee or 

applicant because they have objected to discrimination, engaged or may engage in filing a complaint, 

assisted in a review, investigation, or hearing or have otherwise sought to obtain their legal rights 

under any Federal, State, or local EEO law regarding protected veterans is prohibited. Any employee 

or applicant who believes that they have been subject to retaliation should contact the Director of 

Human Resources at 555-555-1213 for assistance.

This anti-harassment policy is communicated to all employees and managers annually via e-mail, most 

recently on December 1, 2014, and a notice is posted in the personnel office.

Additionally, training is provided annually on the identification and prevention of harassment based on 

protected veteran status to all of FCI’s employees. Furthermore, FCI monitors its environment for the 

presence of any forms of harassment, intimidation, or coercion and, where warranted, takes corrective 

action. 
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VII. External Dissemination of Policy [41 CFR 60-300.44(f)]

FCI provided written notification of FCI’s Equal Employment Opportunity and Affirmative Action policy 

regarding the employment of protected veterans to all current subcontractors, vendors, and suppliers

on June 1, 2014 and will continue to do so on an annual basis. FCI will also provide such written 

notification to new subcontractors, vendors, and suppliers upon entering into a relationship with them. 

FCI has informed its recruiting sources, including State employment agencies, local employment 

service delivery systems, educational institutions and social service agencies, of the company’s policy 

concerning the employment of qualified protected veterans and will notify them of employment 

opportunities as they become available. FCI requested all recruiting sources to actively recruit and 

refer qualified persons for job opportunities.

A copy of FCI’s Affirmative Action Policy for qualified protected veterans is provided to the State 

Employment Service annually.

FCI will include the equal opportunity clause concerning the employment of qualified protected 

veterans in all non-exempt subcontracts and purchase orders. 
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VIII. Outreach and Positive Recruitment [41 CFR 60-300.44(f)]

a. FCI’s Outreach and Positive Recruitment Activities

Outreach/Recruitment 

Activity

Date of 

Activity

Description Evaluation of Each 

Activity

Listed job openings with 

local veteran advocacy 

group

Ongoing In addition to listing openings 

with local Employment Service 

Delivery System (ESDS) as 

required by the VEVRAA 

regulations, openings are also 

listed with a local veteran 

advocacy group

Briefing of Vet-Reps at

local community college 

campus 

July 15, 2014 Briefed Vet-Reps regarding

FCI’s services and current hiring 

needs. FCI will begin sending 

job listings to Vet-Reps for 

assistance in attracting veteran 

applicants.

Participated in Veteran 

Job Fair

November 13, 

2014

Veteran Job Fair was hosted by 

local veterans’ groups, and over 

30 employers participated.

Assessment of Effectiveness of Totality of Outreach/Recruitment Efforts:

Criteria for Evaluation:

1. To what extent did the activity attract qualified applicants who are protected veterans?

2. To what extent did the activity result in the hiring of qualified protected veterans?

3. To what extent did the activity expand FCI’s outreach to protected veterans in the 

community? 

4. To what extent did the activity increase FCI’s capacity/capability to include protected veterans 

in its applicant pool and workforce?

b. Future Assessment of External Outreach and Recruitment Efforts [41 CFR 60-

300.44(f)(3)] 

FCI will begin assessing its outreach and recruitment efforts annually starting in 2015 and will 

document such assessment for inclusion in FCI’s 2016 AAP. This will include an assessment of the 

effectiveness of each individual effort, as an assessment of the effectiveness of the totality of our 

efforts for the year. Because FCI currently has limited applicant and hiring data for protected veterans, 
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which it began collecting last June 1, 2014, we can only perform a limited assessment of the 

effectiveness of our outreach and recruitment efforts at this time. Starting in 2015, FCI will have more 

complete data from which to perform a comprehensive assessment of whether our efforts are 

effective in recruiting protected veterans into our workforce. FCI documents all of its outreach and 

recruitment efforts and maintains these documents, including the written assessments of the 

effectiveness of these efforts, for three years, in accordance with 41 CFR 60-300.44(f)(4).

c. Future Outreach and Positive Recruitment Activities

FCI plans to expand its outreach and positive recruitment efforts in 2015. FCI will routinely post its job 

vacancy announcements to veteran job boards hosted by the Departments of Veterans Affairs and 

Defense (the Veterans Employment Center), the Paralyzed Veterans of America (Paving Access to 

Veterans’ Employment), and other similar public and private veteran-focused job banks. FCI will also 

reach out to the Disabled Veterans' Outreach Program Specialists (DVOPS) & Local Veterans' 

Employment Representatives (LVERs) in our area to explore the creation of an on-the-job training and 

mentorship program for protected veterans. FCI will also begin hosting briefing sessions and facility 

tours for representatives of local organizations that provide employment services to protected 

veterans. 
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IX. Internal Dissemination of Policy [41 CFR 60-300.44(g)]

FCI has developed internal procedures to communicate its obligation to engage in affirmative action 

efforts to employ and advance in employment qualified protected veterans. FCI’s procedures are 

designed to foster understanding, acceptance, and support among all employees and to encourage 

them to help FCI meet this obligation.

FCI makes copies of its AAP available for inspection to any employee or applicant upon request. FCI 

also incorporates the company’s affirmative action and equal employment opportunity policies into 

the FCI Human Resources Manual and updates this manual as needed. The policies are emailed to all 

employees annually and discussed in employee orientation programs, such as FCI’s New Employee 

Orientation seminar. Additionally, FCI’s affirmative action policy and EEO poster are placed on bulletin 

boards located throughout FCI’s facilities and office work areas, and electronic versions of these 

notices are posted and clearly labeled on FCI’s company-wide intranet. A clearly labeled link to an 

electronic version of the EEO poster is also included in FCI’s electronic job application system. 

FCI managers and supervisors are provided with affirmative action and EEO training upon taking their 

management roles and are briefed annually of these policies. The last such management briefing was 

held on June 1, 2014. FCI also notified union officials and employee representatives of these policies

on June 1, 2014 and will send them reminders on an annual basis. 
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X. Audit and Reporting System [41 CFR 60-300.44(h)] 

The FCI Director of Human Resources has the responsibility for developing and preparing the formal 

documents of the AAP. The Director of Human Resources is responsible for the effective 

implementation of the AAP; however, responsibility is likewise vested with each department manager 

and supervisor. 

FCI conducts an annual audit of personnel activities to ensure such activities are free from 

discrimination against, or stereotyping of, protected veterans in any manner. The results of FCI’s most 

recent self-audit are included in Part XI. A. During the self-audit, the following activities are reviewed:

• Recruitment, advertising, and job application procedures;

• Implementation of hiring, promotion, upgrading, award of tenure, layoff, and recall from layoff

practices;

• Rates of pay and any other forms of compensation including fringe benefits;

• Job assignments, job classifications, job descriptions, and seniority lists;

• Implementation of reasonable accommodation policies and procedures;

• Awarding of sick leave, leaves or absence, or implementation of any other leave policies;

• Participation in training, mentoring, or apprenticeship programs, and attendance at

professional meetings and conferences; and

• Application of any other term, condition, or privilege of employment, including participation in

company-sponsored educational, training, recreational, and social activities.

The CEO has also directed the Director of Human Resources to submit a quarterly report documenting 

FCI’s efforts to comply with its EEO/AAP Responsibilities, discussing any identified EEO/AAP problem 

areas along with recommended remedial actions, and providing an update regarding the status of FCI’s 

AAP objectives. Managers and supervisors are asked to report any current or foreseeable EEO problem 

areas to the Director of Human Resources and are asked to outline their suggestions or 

recommendations for solutions. 

The following documents are maintained as a component of FCI’s internal audit process:1

1 Some items in this Sample AAP are labeled “withheld from distribution or public inspection to protect confidentiality.” A 

contractor would not include these items in copies of its VEVRAA AAP that it makes available to applicants and employees 

(including managers), as they contain information that could violate the privacy and confidentiality of specific individuals. 

Such items should only be made available to OFCCP and to those employees responsible for the development and 

implementation of the AAP.

1. Documentation of self-audit;

2. Summary data of personnel activity including external job offers and hires, promotions,

resignations, terminations, and layoffs relating to protected veterans [withheld from

distribution or public inspection to ensure confidentiality]; and
15

3. An applicant flow log showing the name, race, ethnicity, sex, protected veteran status, date of

application, job title, interview status and the action taken for all individuals applying for job

opportunities [withheld from distribution or public inspection to ensure confidentiality].
16

XI. Supporting Data

a. FCI Self-Audit (Conducted on 12/15/2014)

VEVRAA AAP 

Component Requirements

Date last inspected for 

compliance and Results 

of Inspection (Compliant 

(C)/Not Compliant (NC))

Follow-on or 

remedial actions

Invitation to self-identify at 

the pre-offer stage (41 CFR 

60-300.42(a)) 

As of May 1, 2014, FCI invites applicants to self-identify as a 

protected veteran pre-offer using a form that conforms to OFCCP 

requirements at 41 CFR 60-300.42(a) and (c)). 

May 1, 2014; (C)

Invitation to self-identify at 

the post-offer stage (41 CFR 

60-300.42(b)) 

FCI invites applicants to self-identify as a protected veteran postoffer using a form that conforms to OFCCP requirements at 41 CFR 

60-300.42(b) and (c)). 

December 1, 2014; (C)

Policy Statement (41 CFR 60-

300.44(a)) 

Policy Statement posted on bulletin boards. December 1, 2014; (C)

Policy Statement made available, as needed, in a form that is 

accessible and understandable to disabled veterans. 

December 1, 2014; (C)

Policy Statement contains required non-discrimination and nonretaliation statements. December 1, 2014; (C)

Policy Statement indicates top executive support for AAP. December 1, 2014; (C)

Review of Personnel 

Processes (41 CFR 60-

300.44(b))

FCI conducts periodic review of personnel processes using 

procedures designed to facilitate this review. 

December 1, 2014; (C)

Physical and Mental 

Qualifications (41 CFR 60-

300.44(c)) 

FCI provides and adheres to a schedule for reviewing all physical 

and mental qualification standards in the AAP. 

December 1, 2014; (NC)

FCI demonstrates that, if a physical/mental qualification standard 

tends to screen out qualified disabled veterans, the standards are 

job-related and consistent with business necessity

December 1, 2014; (C)
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VEVRAA AAP 

Component Requirements

Date last inspected for 

compliance and Results 

of Inspection (Compliant 

(C)/Not Compliant (NC))

Follow-on or 

remedial actions

Reasonable Accommodation 

(41 CFR 60-300.44(d))

FCI provides reasonable accommodation to the known physical 

and mental limitations of otherwise qualified disabled veterans

absent undue hardship

December 1, 2014; (C)

Reasonable Accommodation 

(41 CFR 60-300.44(d))

If employees who are known disabled veterans experience 

performance difficulties that may be related to the disability, FCI 

confidentially informs the employee of the issue, asks if it is 

related to the disability and, if so, ask if the employee needs an 

accommodation. 

December 1, 2014; (NC) During the audit, FCI 

discovered that several 

new managers with 

supervisory 

responsibilities over 

employees with known 

disabilities were 

unaware of this 

affirmative duty. FCI will 

immediately provide 

refresher training to all 

managers and 

supervisors regarding 

this affirmative duty in 

January 2015.

Harassment (41 CFR 

60-300.44(e)) 

FCI has developed and implemented procedures to ensure 

employees are not harassed on the basis of protected veteran 

status and provided those procedures in the AAP. 

December 1, 2014; (C)

External dissemination of 

policy, outreach, and 

positive recruitment (41 CFR 

60-300.44(f))

FCI undertakes appropriate outreach and positive recruitment 

activities that are reasonably designed to effectively recruit 

qualified protected veterans. 

December 1, 2014; (C)

FCI documents all outreach and recruitment activities and retains

such documents for a period of three years. 

Pending implementation FCI will begin 

documenting all 

outreach and 

recruitment activities 

starting January 1, 2015.

FCI conducts an assessment of each outreach and recruitment 

activity, and an assessment of the effectiveness of the totality of 

these activities that meets these requirements:

Pending implementation FCI will conduct first 

annual, overall outreach 

and recruitment 

assessment on 

December 1, 2015.
18

VEVRAA AAP 

Component Requirements

Date last inspected for 

compliance and Results 

of Inspection (Compliant 

(C)/Not Compliant (NC))

Follow-on or 

remedial actions

External dissemination of 

policy, outreach, and 

positive recruitment (41 CFR 

60-300.44(f))

1. FCI conducts an overall assessment annually;

2. FCI documents criteria it uses in its assessment, which

includes data collected pursuant to 41 CFR 60-300.44(k)

for current year and the two most recent previous years;

3. FCI evaluates each outreach and recruitment activity

using the criteria set out and comes to a reasonable

conclusion as to whether each activity is effective in

identifying and recruiting protected veterans

4. FCI provides an assessment of its overall outreach and

recruitment efforts and, if it concludes that these overall

efforts are not effective, FCI identifies and implements

alternative efforts; and

5. FCI documents these assessments and retains such

documents for 3 years.

Internal Dissemination of 

Policy (41 CFR 60-300.44(g)) 

FCI includes its affirmative action policy in the policy manual or 

make it otherwise available to employees.

December 1, 2014; (C) 

FCI notifies union officials of its affirmative action policy. December 1, 2014; (C)

Audit and Reporting System 

(41 CFR 60-300.44(h)) 

FCI has designed and implemented an audit and reporting system 

that: (a) measures the effectiveness of FCI’s AAP, (b) indicates any 

need for remedial action, (c) determines whether FCI’s affirmative 

action objectives have been reached, (d) determines whether 

known protected veterans have had the opportunity to participate 

in all company sponsored educational, training, recreational and 

social activities, (e) and measures FCI’s compliance with the AAP’s 

specific objectives.

December 1, 2014; (C)

FCI documents the actions it takes to comply with audit and 

reporting system obligations and retains these documents as 

employment records.

Pending implementation FCI will begin 

documenting all audit 

and reporting activities 

starting January 1, 2015

FCI undertake necessary action to bring AAP into compliance if it 

finds any deficiencies.

December 1, 2014

Responsibility for 

Implementation (41 CFR 

60-300.44(i)) 

FCI assigns an official the responsibility for implementation of its 

AAP activities whose identify appears on all internal and external 

communications regarding the AAP and is supported by senior 

management and staff to implement the AAP.

December 1, 2014; (C)
19

VEVRAA AAP 

Component Requirements

Date last inspected for 

compliance and Results 

of Inspection (Compliant 

(C)/Not Compliant (NC))

Follow-on or 

remedial actions

Training (41 CFR 

60-300.44(j))

FCI trains all personnel involved in the recruitment, screening, 

selection, promotion, disciplinary, and related processes to ensure 

the commitments in the AAP are carried out.

December 1, 2014; (C)

Data Collection Analysis (41 

CFR 60-300.44(k))

FCI documents the following computations or comparisons 

pertaining to applicants and hires on an annual basis and 

maintains them for a period of three years:

1. The number of applicants who self-identified as protected 

veterans at the pre-offer stage of FCI’s employment 

process; 

2. The total number of job openings; 

3. Total number of jobs filled;

4. The total number of applicants for all jobs;

5. The number of protected veteran applicants hired;

6. The total number of applicants hired.

Pending implementation FCI will begin collecting 

required data starting 

January 1, 2015.

Hiring Benchmarks (41 CFR 

60-300.45)

FCI establishes a hiring benchmark annually using the national 

percentage of veterans in the civilian labor force provided by 

OFCCP and will use the percentage in its next assessment of the 

effectiveness of FCI’s outreach and recruitment efforts towards 

protected veterans.

December 1, 2014; (C)
20

b. Personnel Activity (establishment-wide)2 [Withheld from distribution or public inspection to ensure 

confidentiality]

2 FCI revised its audit procedures to include summary data of personnel activities involving protected veterans, and such revisions were implemented on June 1, 2014. Data 

pertaining to protected veterans in this chart is incomplete, and FCI expects to have more complete data in its next AAP update. 3 H = Hired; NH = Not Hired

Hires Applicants Promotions – Into 

Job Group Terminations Layoffs Recalls

Total Vet Total Vet Total Vet Total Vet Total Vet Total Vet

17 3 250 30 5 0 6 0 0 0 0 0

 

c. Applicant flow log [Withheld from distribution or public inspection to ensure confidentiality]

Name Race/ 

Ethnicity Sex

VET

(Y/N)

Date of 

Application Job Title Interview (Y/N)

Action Taken Date Action 

(H/NH) Taken 3
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XII. Responsibility for Implementation of AAP [41 CFR 60-300.44(i)]

The Director of Human Resources has been designated to direct the activities of the affirmative action 

program. The Director has the full support of the Chief Executive Officer and has the responsibility for 

designing and ensuring the effective implementation of FCI’s AAP. These responsibilities include, but are not 

limited to:

1. The development of the AAP for protected veterans, policy statements, personnel policies and 

procedures, internal and external communication of the policy, and monitoring the effectiveness of 

these actions;

2. Reviewing all personnel actions, policies, and procedures to ensure compliance with FCI’s affirmative 

action obligations;

3. Reviewing the qualifications of all applicants and employees considered/eligible for hiring promotion, 

transfer, or layoff/reduction in force to ensure qualified protected veterans are treated in a 

nondiscriminatory manner when hiring, promotion, transfer, or layoff/reduction in force occur;

4. Developing solutions for any identified problem areas; 

5. Monitoring the effectiveness of the program on a continuing basis through the development and 

implementation of an internal audit and reporting system that measures the effectiveness of the 

program;

6. Keeping the CEO informed of equal opportunity progress and problems within the company through 

quarterly reports;

7. Providing department-level managers with copies of the Affirmative Action Program (minus the items 

withheld from dissemination for confidentiality reasons) and reviewing the program with them on an 

annual basis to ensure knowledge of their responsibilities for implementation of the program;

8. Reviewing the company’s AAP for protected veterans with all managers and supervisors at all levels to 

ensure that the policy is understood and is followed in all personnel activities;

9. Assisting in ensuring that career development of employees who are protected veterans is equal to 

that of other employees;

10. Auditing the contents of company bulletin boards to ensure that required information is posted and 

up-to-date; 

11. Serving as a liaison between FCI and enforcement agencies; and

12. Serving as a liaison between FCI and outreach and recruitment sources for protected veterans. 
22

XIII. EEO and Affirmative Action Training [41 CFR 60-300.44(j)]

Managers, supervisors, and human resources staff involved in recruiting, screening, selection, promotion, 

disciplinary, and other related employment processes receive annual training regarding FCI’s AAP and their 

role in its implementation. Training sessions were most recently conducted on December 1, 2014. 

During the annual training, managers and supervisors are advised of their responsibilities under FCI’s AAP for 

protected veterans and of their obligations to:

• Assist in the identification of problem areas, formulate solutions, and establish departmental goals and 

objectives when necessary;

• Ensure qualified applicants and employees who are protected veterans are treated in a 

nondiscriminatory manner in all employment practices, including when making selection decisions, 

such as for hire, promotion, training, or to receive awards or bonuses; 

• Provide reasonable accommodation to the known physical or mental limitations of qualified disabled 

veterans unless such accommodation would impose an undue hardship on the conduct of its business; 

• Maintain confidentiality of any information regarding self-identification of protected veteran status; 

and 

• Ensure that nondiscrimination is adhered to in all personnel activities.
23

XIV. Applicant and Hiring Data [41 CFR 60-300.44(k)]

[Withheld from distribution or public inspection to ensure confidentiality]

FCI collects employee data pertaining to protected veterans in order to assess the effectiveness of the 

company’s outreach and recruitment efforts. FCI invites applicants to voluntarily inform the company 

whether they believe they are protected veterans in compliance with the VEVRAA requirements. 

2014 2015 2016

Number of applicants who selfidentify as protected veterans

before an offer of employment is 

made

304

Total number of job openings 17

Total number of jobs filled 17

Total number of applicants for all 

jobs

250

Number of protected veteran 

applicants hired

3

Total number of applicants hired 17

4 FCI began inviting applicants to self-identify as protected veterans prior to an offer of employment on June 1, 2014.

 
24

XV. Hiring Benchmarks [41 CFR 60-300.45]

a. Establishment of Hiring Benchmark

FCI has adopted the national percentage of veterans in the civilian labor force provided by OFCCP, currently 

7.2%, as its hiring benchmark for the 2015 AAP year. In its AAP update on January 1, 2016, FCI will analyze its 

success in hiring protected veterans during the course of this AAP year based on this benchmark and use that 

analysis as one of the criteria in its assessment of the effectiveness of its outreach and recruitment efforts.