1

OFFICE OF FEDERAL CONTRACT 

COMPLIANCE PROGRAMS (OFCCP)

SAMPLE CONTRACTOR AFFIRMATIVE 

ACTION PROGRAM (AAP) 

FOR SECTION 503

(FOR EDUCATIONAL AND INFORMATIONAL PURPOSES ONLY)
2 

FEDERAL CONTRACTOR, INC. (FCI)

AFFIRMATIVE ACTION PROGRAM (AAP) 

FOR INDIVIDUALS WITH DISABILITIES 

(IWD)

(January 1, 2015 to December 31, 2015) 
3 

I. Table of Contents

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

II. Policy Statement on Equal Employment Opportunity for Individuals with Disabilities [41

CFR 60-741.44(a)] ........................................................................................................................... 4

III. Review of Personnel Processes [41 CFR 60-741.44(b)]........................................................... 5

IV. Review of Physical and Mental Job Qualification Standards [41 CFR 60-741.44(c)]............... 7

V. Reasonable Accommodation [41 CFR 60-741.44(d)] .............................................................. 8

VI. Anti-Harassment Procedures [41 CFR 60-741.44(e)] .............................................................. 9

VII. External Dissemination of Policy [41 CFR 60-741.44(f)]........................................................ 10

VIII. Outreach and Positive Recruitment [41 CFR 60-741.44(f)]................................................... 11

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

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

741.44(f)(3)] .............................................................................................................................. 11

IX. Internal Dissemination of Policy [41 CFR 60-741.44(g)]........................................................ 13

X. Audit and Reporting System [41 CFR 60-741.44(h)] ............................................................ 14

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

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

b. Personnel Activity .............................................................................................................. 20

c. Applicant Flow Logs ........................................................................................................... 20

XII. Responsibility for Implementation of AAP [41 CFR 60-741.44(i)]......................................... 21

XIII. EEO and Affirmative Action Training [41 CFR 60-741.44(j)].................................................. 22

XIV. Applicant and Hiring Data [41 CFR 60-741.44(k)].................................................................. 23

XV. Utilization Analysis [41 CFR 60-741.45(d)] ............................................................................ 24

a. Job Groups [41 CFR 60-741.45(d)(2)]................................................................................. 24

b. Utilization of Individuals with Disabilities ......................................................................... 25

c. Identification of Problem Areas and Action-oriented Programs [41 CFR § 60-741.45(e)

and (f)]....................................................................................................................................... 26
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II. Policy Statement on Equal Employment Opportunity for 

Individuals with Disabilities [41 CFR 60-741.44(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 individuals with disabilities. Therefore, it is 

the policy of FCI not to discriminate on the basis of disability and to take affirmative action to employ 

and advance in employment qualified individuals with disabilities 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 disability. FCI will also provide qualified 

applicants and employees with disabilities 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 on the basis of disability and will conduct 

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

retaliation or punishment 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 regarding FCI’s employment practices, or otherwise seeking to obtain their legal rights under 

any Federal, State, or local EEO law requiring equal employment opportunity for individuals with 

disabilities. 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 individuals with disabilities 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 equal 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.
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III. Review of Personnel Processes [41 CFR 60-741.44(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 individuals with disabilities. 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.

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 individuals with disabilities 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 having a disability before an offer of 

employment is made.

On May 1, 2014, FCI began inviting all applicants to voluntarily inform FCI whether they are individuals 

with disabilities before an offer of employment is made in compliance with 41 CFR 61-741.42(a) using 

the form prescribed by OFCCP. FCI provides the self-id form prescribed by OFCCP 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 required self-id form using the parameters 

outlined by OFCCP in its FAQs. FCI also created a separate electronic file where it stores all self-id 

information separate from employment applications, personnel records, and employee medical files. 

FCI also continues to invite applicants to voluntarily self-identify as individuals with disabilities after a 

job offer has been made, but before the applicant begins work, in compliance with 41 CFR 61-

741.42(b). FCI uses the form prescribed by OFCCP to invite this post-offer self-identification, and 

stores all self-id responses in the separate electronic file created for this purpose.

 
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3. Invite self-identification of disability from all FCI employees every five years. 

In compliance with 41 CFR 60-741.42(c), FCI invited all of its current employees to voluntarily inform 

FCI whether they are individuals with disabilities via an email sent on May 1, 2014, and will do so every 

five years thereafter. The email contained a link to the electronic self-id form, and also indicated to 

employees that paper self-id forms are available in FCI’s human resources office. Employees were 

asked to reply by May 8, 2014. FCI will also remind employees via email three years after the most 

recent invitation that they can voluntarily update their disability status with FCI at any time. The next 

reminder will be sent to employees on May 1, 2017, and the next all-employee invitation to selfidentify is scheduled for May 1, 2019.

4. Modify applicant flow logs. 

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

60-741.44(k). In order to facilitate the accurate tracking of applicant and hiring data for individuals 

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

logs will be maintained confidentially.

5. Documentation and Assessment of the Effectiveness of Outreach and Recruitment Activities

FCI has always engaged in positive outreach and recruitment for individuals with disabilities, as 

required by OFCCP regulations. FCI has begun documenting each outreach and recruitment activity to 

comply with the requirements of the new Section 503 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 60-741.44(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 60-741.44(k), to see if it is producing measurable results:

1. To what extent did the activity attract qualified applicants with disabilities? 

2. To what extent did the activity result in the hiring of qualified individuals with disabilities?

3. To what extent did the activity expand FCI’s outreach to individuals with disabilities in the 

community? 

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

disabilities 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 individuals with disabilities, 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 60-741.44(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 individuals with disabilities, 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 individuals with disabilities. 

Nevertheless, to ensure our compliance, FCI strives to use only job qualification standards that are jobrelated and consistent with business necessity. The review found all job qualification requirements to 

be job-related and consistent with business necessity.

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

require the conduct of a medical examination, FCI affirms that such inquiries or exams will be 

conducted in accordance with the Section 503 regulations and that information obtained as a result of 

the inquiry or exam will be kept confidential, except as otherwise provided for in the Section 503 

regulations. The results of the examination or inquiry will only be used in accordance with the Section 

503 regulations.
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V. Reasonable Accommodation [41 CFR 60-741.44(d)]

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

physical or mental limitations of qualified individuals with disabilities 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 Section 503 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 accommodation 

procedures using the optional guidance in Appendix B of 41 CFR Part 60-741.
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VI. Anti-Harassment Procedures [41 CFR 60-741.44(e)]

Employees and applicants of FCI will not be subject to harassment because of disability. Any employee 

or applicant who believes that they have been subject to harassment because of their disability 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 individuals with disabilities is prohibited. Any 

employee or applicant who believes that he or she has 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 

disability 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 60-741.44(f)]

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

regarding the employment of qualified individuals with disabilities to all current subcontractors, 

vendors, and suppliers on June 1, 2014 and will continue to do soon 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, educational institutions 

and social service agencies, of the company’s policy concerning the employment of qualified 

individuals with disabilities 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. 

FCI will include the equal opportunity clause concerning the employment of qualified individuals with 

disabilities in all non-exempt subcontracts and purchase orders.
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VIII. Outreach and Positive Recruitment [41 CFR 60-741.44(f)]

a. FCI’s Outreach and Positive Recruitment Activities

Outreach/Recruitment 

Activity

Date of 

Activity

Description Evaluation of Each 

Activity

Annual meeting with 

State Vocational 

Rehabilitation Service 

Agency (SVRA)

November 15, 

2014

Will provide information 

regarding FCI job openings to 

SVRA starting January 1, 2015.

Listing of jobs with 

Employment One-Stop 

Center 

Recurring All jobs are posted with 

Employment One-Stop Career 

Center. 

Briefing of Local 

Disability Advocates 

(LDA) 

September 1, 

2014

Briefed representatives of LDA, 

a local disability advocacy 

group, regarding FCI’s services 

and job opportunities, and 

provided an FCI facility tour.

Assessment of Effectiveness of Totality of Outreach/Recruitment Efforts:

Criteria for Evaluation:

1. To what extent did the activity attract qualified applicants with disabilities?

2. To what extent did the activity result in the hiring of qualified individuals with disabilities?

3. To what extent did the activity expand FCI’s outreach to individuals with disabilities in the

community? 

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

disabilities in its applicant pool and workforce? 

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

741.44(f)(3)]

FCI will begin assessing its outreach and recruitment efforts annually, using the above stated 

evaluation criteria, 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 well 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 individuals with disabilities, which it began collecting 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 individuals with disabilities into its 
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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 60-741.44(f)(4). 

c. Future Outreach and Positive Recruitment Activities

FCI plans to expand its outreach and positive recruitment efforts in 2015. FCI will participate in the 

upcoming annual job fair hosted by a consortium of regional disability advocacy groups, and is 

exploring the creation of an internship program for students with disabilities with the nearby state 

university college. FCI will also begin hosting briefing sessions and facility tours for representatives of 

local disability advocacy groups that provide employment services to individuals with disabilities.
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IX. Internal Dissemination of Policy [41 CFR 60-741.44(g)]

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

efforts to employ and advance in employment qualified individuals with disabilities. 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 on 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 60-741.44(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 individuals with disabilities 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 were

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/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. Documentation of self-audit;

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 Section 503 AAP that it makes available to applicants and 

employees (including managers), as they contain information that could identify specific employees with disabilities in 

violation of Section 503’s confidentiality requirements. Such items should only be made available to OFCCP and to those 

employees responsible for the development and implementation of the AAP. 
15

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

resignations, terminations, and layoffs by job group relating to individuals with disabilities

(withheld from distribution or public inspection to protect confidentiality); and 

3. An applicant flow log showing the name, race, ethnicity, sex, disability 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 protect confidentiality).
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XI. Supporting Data

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

SECTION 503 AAP 

Component Requirements

Date last inspected 

for compliance and 

Results of Inspection 

(Compliant (C) / Not 

Compliant (NC))

Follow-on or remedial actions

Invitation to selfidentify at the pre-offer 

stage of employment 

process (41 CFR 60-

741.42(a)(1) and (2))

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

individual with a disability pre-offer using the invitation form 

provided by OFCCP. 

May 1, 2014; (C) 

Invitation to selfidentify at the postoffer stage of 

employment process 

(41 CFR 60-741.42(b)(1) 

and (2))

FCI invites applicants to self-identify as an individual with a 

disability post-offer using the invitation form provided by 

OFCCP. 

December 1, 2014; (C)

Employee invitation to 

self-identify (41 CFR 60-

741.42(c)

FCI sent an invitation to all employees to voluntarily selfidentify as an individual with a disability on June 1, 2014 by 

e-mail. The email contained a link to the electronic self-id 

form, and also indicated to employees that paper self-id 

forms are available in FCI’s human resources office. FCI will 

extend this invitation to self-identify to employees every five 

years thereafter.

December 1, 2014; (C) Remind employees on May 1, 2017 that 

they may update their status at any time. 

Issue next invitation to self-identify on 

May 1, 2019. 

Policy Statement (41 

CFR 60-741.44(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 individuals with disabilities.

December 1, 2014; (C)

Policy Statement contains required non-discrimination and 

non-retaliation statements.

December 1, 2014; (C)

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

Review of Personnel 

Processes (41 CFR 60-

741.44(b))

FCI conducts periodic review of personnel processes using 

procedures designed to facilitate this review.

December 1, 2014; (C)

FCI provides necessary reasonable accommodation to ensure 

applicants and employees with disabilities receive equal 

opportunity in the operation of personnel processes.

December 1, 2014; (C)
17

SECTION 503 AAP 

Component Requirements

Date last inspected 

for compliance and 

Results of Inspection 

(Compliant (C) / Not 

Compliant (NC))

Follow-on or remedial actions

Physical and Mental 

Qualifications (41 CFR 

60-741.44(c))

FCI provides and adheres to a schedule for reviewing all 

physical and mental qualification standards in the AAP. 

December 1, 2014; (C)

FCI demonstrates that, if a physical/mental qualification 

standard tends to screen out qualified individuals with 

disabilities, the standards are job-related and consistent with 

business necessity.

December 1, 2014; (C)

Reasonable 

Accommodation to 

Physical and Mental 

Limitations (41 CFR 

60-741.44(d))

FCI provides reasonable accommodation to the known 

physical and mental limitations of otherwise qualified 

individuals with disabilities, absent undue hardship. 

December 1, 2014; 

(NC) 

During the audit, FCI discovered several 

requests for reasonable accommodation 

submitted during the AAP year that were 

not timely processed, without a 

reasonable explanation for the delay. FCI 

will review reasonable accommodation 

procedures and provide training to all 

managers and supervisors on the proper 

processing of accommodation requests.

If employees with known disabilities 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, asks 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 

60-741.44(e))

FCI has developed and implemented procedures to ensure 

employees are not harassed on the basis of disability and 

provided those procedures in the AAP.

December 1, 2014; (C)

External dissemination 

of policy, outreach, and 

positive recruitment (41 

CFR 60-741.44(f))

FCI undertakes appropriate outreach and positive 

recruitment activities that are reasonably designed to 

effectively recruit qualified individuals with disabilities.

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.
18

SECTION 503 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 60-741.44(f))

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

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-

741.44(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 qualified individuals with 

disabilities

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 

60-741.44(g))

FCI includes its affirmative action policy in the policy manual 

or makes 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 

60-741.44(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 individuals with 

disabilities 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)
19

SECTION 503 AAP 

Component Requirements

Date last inspected 

for compliance and 

Results of Inspection 

(Compliant (C) / Not 

Compliant (NC))

Follow-on or remedial actions

Audit and Reporting 

System (41 CFR 

60-741.44(h))

(continued)

FCI documents the actions it takes to comply with audit and 

reporting system obligations and retains these documents as

employment records (see § 60-741.80).

Pending 

Implementation

FCI will begin documenting all audit and 

reporting activities starting January 1, 

2015

FCI undertakes necessary action to bring AAP into 

compliance if it finds any deficiencies.

December 1, 2014; (C)

Responsibility for 

Implementation (41 CFR 

60-741.44(i))

FCI assigns an official the responsibility for implementation 

of its AAP activities whose identity 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)

Training (41 CFR 

60-741.44(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 60-741.44(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

individuals with disabilities at the pre-offer stage of

FCI’s employment process (§ 60-741.42(a));

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 applicants with disabilities hired;

6. The total number of applicants hired.

Pending 

implementation

FCI will begin collecting required data 

starting January 1, 2015.

Utilization goals (41 CFR 

60-741.45)

FCI annually evaluates the representation of individuals with 

disabilities in each job group established for utilization 

analysis under EO 11246 with the 7% utilization goal. 

Pending 

implementation

FCI will conduct its first full annual 

utilization analysis on December 1, 2015. 

FCI takes steps to determine if there are impediments to 

equal employment opportunity when the percentage of 

individuals with disabilities in the job group is less than the 

7% utilization goal.

FCI develops & executes action-oriented programs designed 

to correct any identified impediments or problem areas.
20

b. Personnel Activity2 [Withheld from distribution or public inspection to ensure confidentiality.]

Category and Job Group Number Hires Applicants Promotions – Into Job Group Terminations Layoffs Recalls

Total IWD Total IWD Total IWD Total IWD Total IWD Total IWD

Officials and Managers

Job Group: 1

1 0 9 1 1 0 1 0 0 0 0 0

Professionals

Job Group: 2

2 0 24 3 1 0 0 0 0 0 0 0

Technicians

Job Group: 3

0 0 0 0 0 0 0 0 0 0 0 0

Sales Workers

Job Group: 4

0 0 0 0 0 0 1 0 0 0 0 0

Administrative Support Workers 

Job Group: 5

2 1 63 8 0 0 1 0 0 0 0 0

Craft Workers

Job Group: 6

9 1 92 12 2 0 1 0 0 0 0 0

Operatives

Job Group: 7

2 0 34 0 1 0 0 0 0 0 0 0

Laborers and Helpers

Job Group: 8

1 0 28 1 0 0 2 0 0 0 0 0

Service Workers

Job Group 9

0 0 0 0 0 0 0 0 0 0 0 0

Overall activity 17 2 250 25 5 0 6 0 0 0 0 0 

c. Applicant Flow Logs [Withheld from distribution or public inspection to ensure confidentiality.]

Name Referral 

Source

Race/

Ethnicity Sex Disability(Y/N)

Date of 

Application

Job 

Title

Interview

(Y/N)

Action Taken

(H/NH)3

Date Action 

Taken

2 FCI revised its audit procedures to include summary data of personnel activities involving Individuals with Disabilities, and such revisions were implemented on June 1, 

2014. Data pertaining to IWDs in this chart is incomplete, and FCI expects to have more complete data in its next AAP update.

3 H = Hired; NH = Not Hired
21

XII. Responsibility for Implementation of AAP [41 CFR 60-

741.44(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 individuals with disabilities, 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 individuals 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 AAP (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 individuals with disabilities 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 with disabilities 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 individuals with 

disabilities.
22

XIII. EEO and Affirmative Action Training [41 CFR 60-741.44(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 individuals with disabilities 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 with disabilities 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 

individuals with disabilities unless such accommodation would impose an undue hardship on 

the conduct of its business; 

• Maintain confidentiality of any disability-related information obtained regarding any applicant 

or employee; and

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

XIV. Applicant and Hiring Data [41 CFR 60-741.44(k)] 

[Withheld from distribution or public inspection to ensure 

confidentiality.]

FCI collects employee data pertaining to individuals with disabilities in order to assess the effectiveness 

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

inform the company whether they believe they are individuals with disabilities in compliance with the 

Section 503 requirements. 

2014 2015 2016

Number of applicants who selfidentify as individuals with 

disabilities before an offer of 

employment is made

254

Total number of job openings 17

Total number of jobs filled 17

Total number of applicants for all 

jobs

250

Number of applicants with 

disabilities hired

2

Total number of applicants hired 17

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

has partial-year data for this data element for 2014. 

 
24

XV. Utilization Analysis [41 CFR 60-741.45(d)]

a. Job Groups [41 C.F.R. § 60-741.45(d)(2)]5

5 For utilization analysis under 41 CFR 60-741.45, a company is required to use the same job groups established for its 

Executive Order 11246 AAP if it has more than 100 employees.

Job Titles Job Group Name EEO-1 Category

General Manager

Controller

Pricing – Billing Manager

Sales – Customer Support Manager 

Interior Design Manager

Personnel Manager

Installation Manager

Installation Supervisor

Repair Supervisor

1 Officials and Managers

Interior Designer

Office Space Planner

General Ledger Accountant 

Payroll Administrator

Purchasing Agent

Pricing Specialist

2 Professionals

No FCI employees in Job Group 3 3 Technicians

Office Equipment Sales Representative 4 Sales Workers

Executive Assistant

Administrative Assistant

File Clerk

Billing Clerk

Inventory Control Clerk

Customer Information Sales Representative

Call Center Agent

Customer Service Complaints Clerk

5 Administrative 

Support Workers 

Systems – Specialist

Installer

Furniture Repair

6 Craft Workers

Truck Driver

Forklift Operator

7 Operatives

Installer Helper

Receiving

8 Laborers and Helpers

No FCI Employees in Job Group 9 9 Service Workers

 
25

b. Utilization of Individuals with Disabilities6

6 If the number of employees in one or more of a contractor’s job groups is so small that the identity of an employee with a 

disability would be readily discernable, the data for that job group(s) should be omitted from any copies of the AAP 

disseminated or made available for public inspection, so as to ensure confidentiality.

Job Group Total Number of 

Employees per Job 

Group

# of Employees 

who are 

individuals with 

disabilities per Job 

Group

Utilization rate of 

individuals with 

disabilities per Job 

Group

Underutilized? 

(Y/N)

1 9 0 0.0% Y

2 22 2 9.1% N

4 10 1 10.0% N

5 30 3 10.0% N

6 43 3 7.0% N

7 10 0 0.0% Y

8 16 1 6.3% Y

 
26

c. Identification of Problem Areas and Action-oriented Programs7 [41 CFR 60-

741.45(e) and (f)]

Job Groups where 

Utilization Goal is Not Met

Identification of Problem Areas 

(if any) Action-oriented Programs

1 

None identified

7 None identified 

8 None identified

7 FCI’s review of its internal audit, including review of the company’s personnel processes and job qualification standards 

did not reveal any impediments to equal employment opportunity for these job groups. However, FCI recognizes that this 

review was based on incomplete data, as FCI is in the midst of its transition to compliance with the revised Section 503 AAP 

requirements. FCI’s next AAP will include a more thorough and complete assessment of problem areas for any job group 

where the 7% goal is not met.