In its June 21, 2016, Compliance Tips, the City of Minneapolis Department of Civil Rights Contract Compliance Division offered some tips for how a contractor can demonstrate good faith efforts at meeting the City’s workforce goals. Given the recent notice of on-site “reviews” that I blogged about earlier, this is no surprise. Contractors should expect the City will also be auditing compliance with the workforce goals, and should be prepared to make this showing. Here’s what advice the City has to offer:
“The City’s workforce goals are 6% female and 32% minority workers on all city construction projects. A contractor must demonstrate a good faith effort to meet these goals. A good faith effort means that a contractor took reasonable steps to employ female and minority workers and cure existing underutilizations in its workforce through Affirmative Action and Equal Employment Opportunity.
A contractor can demonstrate its workforce good faith efforts in the following ways:
- Provide documentation that it has alerted its subcontractors, unions, and trade organizations of the City’s workforce goals.
- Use its current Affirmative Action Plan, or create a new one, to develop a female and minority worker recruitment plan
- Advertise opportunities for employment in minority and women trade publications and at job and recruitment fairs
- Be diligent in documenting and communicating any and all efforts to CCD so that we are aware of its efforts and can help it meet its goals and are aware of its efforts.
Contractors must be truthful when submitting utilization percentages to CCD.”