A contractor must review its employment practices to determine whether individuals receive fair consideration for job opportunities without regard to religion or national origin. COs must ask the contractor whether it conducted a review of its employment practices for this purpose and, if so, when, how and whether it documented the review. If the contractor undertook a review, the CO must verify the results and the sufficiency of any corrective actions that the contractor implemented. In making this assessment, the CO will keep in mind that the scope of the contractor’s efforts depends on a review of all circumstances, including the nature and extent of any problem areas, as well as the size and resources of the contractor. COs must take into consideration that contractors are not required to collect data on applicants’ and employees’ religious affiliation or national origin. Therefore, a contractor’s self-analysis will not use employment records to identify employees’ religious affiliations or national origins. If the contractor did not conduct a review, the contractor must take corrective action.
COs must verify that the contractor communicated the nondiscrimination policy to contractor officials, human resources personnel, employees and applicants, and that procedures implementing the policy are in place. A CO will also verify that the contractor has participated in recruitment and outreach efforts. A CO will review employment policies regarding nondiscrimination based on religion and national origin, and the provision of religious accommodations. During interviews with contractor officials, employees and applicants, a CO will ask about requests for religious accommodations and how the contractor responded to these requests. COs must obtain documentation regarding recruitment and outreach, and other affirmative action efforts.