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Implicit bias occurs when individuals make judgments about people based on gender, race or other prohibited factors without even realizing they’re doing it.
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Covered employers must file their EEO-1 and VETS-4212 affirmative action reports with the federal government by Sept. 30.
The Equal Employment Opportunity Commission (EEOC) and the Department of Labor (DOL) require that certain employers disclose the demographics of their workforce in two different annual reports.
The EEO-1 report applies to employers subject to Title VII of the Civil Rights Act of 1964 and who have 100 or more employees and to federal contractors with 50 or more employees and a contract or subcontract amounting to $50,000, or more.
The VETS-4212 report only applies to federal contractors and subcontractors. For the 2016 filing year, the filing threshold for contracts entered into prior to Oct. 1, 2015, is still $100,000; for contracts entered into on or after Oct. 1, 2015, the filing threshold is $150,000.
Employers must file the EEO-1 report with information about the race, ethnicity and gender of their workforces in each EEO-1 category from any pay period in July, August or September of this year.
Be aware that your password to file this report online has changed.
"Your company's password from 2015 for filing the report electronically will not work this year," said Louise Davies, an affirmative action paralegal in Constangy's Winston-Salem, N.C., office. "If your company has previously filed an EEO-1 report electronically, you should have received a notification letter by Aug. 15 with your new company password."
Davies said that if the proposed rule recently issued by the EEOC goes into effect, employers will be off the hook from filing EEO-1 reports during calendar year 2017. The survey period will change from the current July-September window to October-December, and employers will have until March 31, 2018, to file their reports.
"That's the good news," she said. "The bad news is that the EEOC's proposed rule would require employers to annually report compensation in 12 pay bands and hours worked, for each EEO-1 category, broken down by race, ethnicity and gender."
The VETS-4212 report requests the number of protected veterans currently employed, classified by EEO-1 category. It also collects data on the total number of new hires and the number of new hires who are protected veterans.
Note that the previously used VETS-100 and VETS-100A forms have been discontinued and are no longer being accepted by the DOL.
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