EEO-1 Reporting and Affirmative Action Plans AND E-Verify

I have asked this question before but was never answered. My company is a construction materials supplier for general contractors and subcontractors who hold government contracts and subcontracts. Therefore, we do not hold any direct federal contracts. We are not located on the jobsites, we simply deliver our products and then leave. We are paid by the subcontractors and general contractors on these construction projects that involve federal money. We have over 50 employees, but less than 100. We are affliated through common ownership with an employer that has direct federal contracts and subcontracts. I don't know the $ amounts of these contracts but I'm sure they amount to more than $25,000. We almost never get to actually see the actual federal contract in the first place. Sometimes all we ever get is a PO from a sub.

1. Is my company considered a government contractor and required to complete EEO-1 reports and acquire and keep Affirmative Action applicant data?

2. Is my company required to use the E-Verify system (after the May 2009 effective date)?

Thank you for any help in this matter.


  • 3 Comments sorted by Votes Date Added
  • Sorry Jill but I can't answer your questions however, if you contact your local DOL, OFCCP office they may be able to give you some guidance.
  • Check [url][/url]
    Executive Order 11246

  • I strongly recommend that, before embarking on any affirmative action plan, an employer consult with a competent employment law attorney.

    Some companies that are required by law to establish written AAPs include those that fit into at least one of the following categories:

    [*]A non-construction employer with at least 50 employees and U.S. government contracts or subcontracts worth at least $50,000. If you have at least 50 employees and several small government contracts that add up to $50,000, an AAP is required. If you’re a branch office of a bigger company with the required number of employees and contracts, an AAP is required even though your office doesn’t handle the contracts or have 50 employees. (Note: construction employers have separate affirmative action obligations set by the federal government. Check with employment counsel for more information.)
    [*]A depository of any amount of government funds.
    [*]An issuing and paying agent of U.S. government bonds.
    [*]An employer required by a judge to create a written AAP as part of a court judgement against it.
    [*]An employer that has agreed, with court approval, to implement a written AAP as part of a consent decree to settle a discrimination lawsuit.
    The above is an excerpt from the topic on Affirmative Action at [url][/url]

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