Contract Compliance Checklist

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CONTRACT COMPLIANCE REVIEW CHECKLIST

Georgia Department of Transportation, Contract Compliance Division


PRIME CONTRACTOR & ACTIVE SUBCONTRACTORS: Complete this checklist. Attach all required documentation and send to the
GDOT Contract Compliance District EEO Review Officer: _______________________________________________________,
on or before (date in letter) as stated in the notification letter for the Contract Compliance Review. All records concerning Equal
Employment Opportunity and Disadvantaged Business Enterprise utilization must be available at the time of the review. ALL
DOCUMENTATION MUST BE CLEAR, LEGIBLE, ORGANIZED, AND LABELED ACCORDING TO SECTION AND QUESTION NUMBER.

SUBCONTRACTORS: IF ALL OF THE REQUIRED INFORMATION IS RECEIVED TIMELY, AND AFTER REVIEW, THERE ARE ONLY A FEW BASIC
QUESTIONS, A CONFERENCE CALL MAY BE HELD AT THE SCHEDULED DATE AND TIME INSTEAD OF AN ON-SITE VISIT. A DECISION WILL
BE MADE AND CONVEYED APPROXIMATELY FORTY-EIGHT HOURS PRIOR TO THE SCHEDULED REVIEW.

1. Contract or Project Number 2. Contract Value 3. Date of Review

4. Contractor Identification (Specify if a Disadvantaged Business Enterprise.)

Prime Sub Vendor Supplier Other (specify)

5. Name And Address of Contractor

6. Project Address, if Different (List county and nearest city or town.)

7. Name And Title of Policy Making Officer (List titles of other positions currently being held in the company.)

8. Name And Title of Project Officer (List titles of other positions currently being held in the company.)

9. Name And Title of Equal Employment Opportunity Officer (List titles of other positions currently being held in the company.)

10. Contract or Project Production Beginning date: Est. completion Anticipated peak employment date:
Schedule date:

11. Type of Work 12. % COMPLETE

13. Is a written EEO Affirmative Action Plan available?

(Provide a copy of the plan)

NOTE: The following questions relate to requirements found in FHWA 1273 - Required Contract Provisions, Federal-Aid Construction
Contracts; Contract Special Provision - On-the-Job Training Program; Contract Special Provision - EEO Affirmative Action
Requirements; and Contract Special Provision - Utilization of Disadvantaged Business Enterprise, which are located in the bidder's
proposal.
GDOT
Effective 02/2010
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A. Subcontractors, Regular Dealers, Vendors, Suppliers, Etc.
1. What is the DBE requirement for this project? %

2. List intended DBE participation (provided at time of bid submittal) and actual DBE participation (amount paid to date) below.

FIRM NAME TYPE OF WORK INTENDED AMOUNT ACTUAL AMOUNT

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

3. Have copies of all executed subcontract agreements with DBE firms and copies of supporting document (i.e. canceled checks -
front and back) issued to only the DBE subcontractors been submitted to the project engineer?

☐ Yes ☐ No If No, please explain:

4. Provide a list of all subcontractors, with contracts of $10,000 or more, on this project to include name and address; dollar
amount; type of work or service provided; and whether or not subcontract work has started, is in progress, or has been
completed. For those subcontractors that have performed any work on the project, include what their peak employment
week has been to date for this project only (to include total number of employees, total number of minority and female
employees, and the percent of each).

Subcontractor Name Address Dollar Type of Work or Work in


Amount Service Provided Process or
Complete?

1.

2.

3.

4.

5.

2
6.

7.

8.

9.

10.

5. Are there established procedures to ensure subcontractors' compliance with the EEO obligations of this contract?

Yes No (Provide documentation of this procedure)

B. Union Affiliations

1. Is this firm signatory to a collective bargaining agreement(s)? Yes No (If no, continue to Section C.)

2. Provide a copy of all current collective bargaining agreements.

3. Does the agreement(s) provide for exclusive hiring hall referrals? Yes No

4. Is there an Equal Employment Opportunity clause incorporated in the agreement(s)? Yes No

5. If so, on what page does the clause appear?

6. Have required written notices been sent to unions? Yes No (Provide documentation)

7. If the union(s) has been unable to refer qualified minorities and females for employment, have recruitment procedures been
established and used to fill job vacancies consistent with EEO obligations of this contract?

Yes No (Provide a copy of the procedures and documentation of these efforts)

C. Other Recruitment Sources


1. Provide a list of recruitment sources (other than unions) actually used on the project this year or review period to include name
and addresses.

D. Project Personnel
1. Submit employment data record which reflects the review period for this project. Categorize employees by job classification and
include the employee’s name, date hired, job classification, race, sex, wage rate and date fired, if applicable.

2. Submit a list of all employees hired and promoted during the review period, annotated to include race, sex, job classification, date
of hire and wage rate. Please indicate if company hires project specific or company-wide. (Provide documentation)

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3. Provide a list of all minority and female employees who have worked on the project during this review period (as of the same
week ending date as your last available payroll), to include name and address, race, sex, job classification, beginning work date,
ending work date (if applicable), and status of employment (still working on project, transferred to another project, laid off,
discharged and for what reason, etc). (Provide information)

4. Submit a copy of the initial payroll as well as a copy of the most current payroll for the review period. The payroll should be
annotated to indicate race, sex, wage rate and job classification of each employee. (Provide Copies)

5. Are nondiscriminatory wage practices utilized on t his project (no wage difference between minority, female, and nonminority

personnel within a given classification? ☐ Yes ☐ No


6. Please complete and submit a Cumulative Utilization Report and FHWA 1391 for the entire review period. (Provide information)

E. Training
1. Under the Contract Special Provision On-the-Job Training Program, how many trainees have been assigned to your company?
(If none, continue to Section F.)

2. Are there approved training programs? Yes No (Provide copies)

3. How many trainees are actually employed on this project?

4. If there are none on the project at the time of review, are they anticipated to be on the project?

Yes No

5. In what classifications are they being trained?

6. On what equipment (if applicable) are they being trained?

7. How many hours of training have the trainees received in their classification to date?

8. Have the trainees received the proper number of training hours as stated in their training programs? ☐ Yes ☐ No
9. Will the trainees complete their training this review period? Yes No
What are their anticipated completion dates?

10. What plans have been made for those trainees who do not complete their programs?

11. Are trainees receiving the proper pay scale for the classifications in which they are being trained?

Yes No

12. Have the trainees received rate increases as provided for in their training programs? Yes No

(Provide salary history for trainees including dates and amounts of salary increases)

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13. Are trainees being retained by the contractor after completion of their programs? Yes No

(Provide employment records on all trainees who have completed programs within the past three years)

F. Project Personnel Actions


1. Are records kept on personnel actions that are necessary to determine compliance with FHWA 1273 regulations?

Yes No
(Personnel actions include termination, layoff, upgrading, demotion, transfer, training, etc.)

G. Recruitment
1. When advertising for employees by any of the above means, has the advertisement been placed in publications that have a
large circulation among minorities in the area from which the project workforce would normally be derived?

Yes No
(Provide documentation and a list of the newspapers, trade magazines, or other publications used)

2. When advertising for employees in newspapers, trade magazines, or other publications, has the notation “An Equal Opportunity
Employer” been included in those advertisements?

Yes No
(Provide documentation for this project only including name of publication and date(s) advertisement ran)

3. Have present employees been encouraged to refer minority and female applicants for employment?

Yes No (Provide documentation supporting this claim)

4. Who on this project has the responsibility for hiring employees?

5. Have they been instructed in the methods to be followed when locating and hiring minority and female employees?

Yes No (Provide documentation)

6. Has systematic and direct recruitment been conducted with referral sources likely to yield minority and female applicants?

Yes No (Provide details of the results of these contracts)

7. Have procedures been established with these referral sources whereby minority and female applicants may be referred for
employment consideration?

Yes No (Provide documentation of this contact to include name and address)

8. What other innovative and proactive recruiting techniques have been used to locate and hire minority and female employees
(placing notices or fliers in grocery stores, Laundromats, gas stations, community halls, etc.)?

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H. EEO Policy

1. Is the following statement included in the EEO Policy? Yes No


“It is the policy of this company to assure that applicants are employed, and that employees are treated during employment,
without regard to their race, color, religion, sex, age, national origin, or disability. Such action shall include, but not be
limited to the following: employment, upgrading, demotion, or transfer; recruitment advertising; layoff or termination; rates of
pay or other forms of compensation; and selection for training, including apprenticeship pre-apprenticeship, and/or on-the-
job training.” (See Exhibit A of the form “Required Posters on Federal-Aid Projects.”)

2. Submit a copy of your company’s EEO Policy signed by the President or a principal policy official. This policy
must be currently dated and must indicate the name and telephone number of your company’s EEO Officer.

I. Dissemination of EEO Policy


1. Has the EEO policy and other required notices and posters been placed in an area readily accessible to employees, applicants
for employment, and potential employees? Is the information current and signed by the company official?

Yes No Where? _______________________________________

Are all “Required Posters on Federal-Aid Projects” provided during Pre-construction Conference posted on bulletin board?

Yes No Where? ______________________________________

2. Check by which of the following means the EEO policy and the procedures to implements such policy have been brought to the
attention of all employees on this project at least once annually:

Meetings Employee Handbooks Other Appropriate Means: _______________________________

(Provide minutes of meeting with roster of attendees, handbook, or documentation of other means utilized)

3. Check which of the following prospective employee providers have been made fully aware of the EEO policy and provide
documentation:

Schools Employment Agencies Labor Unions College Placement Offices Other

4. Do supervisory personnel fully understand the company EEO policy? Yes No

5. Have all new supervisory personnel and office personnel hired this review period been given a thorough indoctrination in the EEO
policy within 30 days of their employment starting date?

Yes No (Provide documentation)

6. Have EEO meeting with supervisory personnel and office personnel been conducted prior to the start of work on this project and
at least every six months during the progress of this project?

Yes No (Provide minutes of the meetings including rosters of attendees)

J. EEO and DBE Officers


1. Has an EEO officer been designated for the company (May be combined with designation of DBE officer.)

Yes No (Provide a copy)

2. Has adequate written authority delegating the duties and responsibilities of that position been provided to the EEO officer?

Yes No (Provide documentation)

3. What EEO training has the officer received within the past two years?

(Provide dates and details of training)

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4. When was the EEO responsibility assigned to the officer?

5. Annually, approximately what percentage of time does the officer spend on EEO concerns?

K. General
1. Is a written discrimination complaint process available?

(Provide a copy of the plan)

Yes No (Provide a copy of the procedure)

2. Have any complaints of discrimination been received within the past three years? Yes No

3. If yes, give specific date(s) of complaint(s), nature of complaint(s), who was involved, what action was taken, and the outcome.

(Provide documentation)

4. Check which of the following required contract special provisions have been incorporated in all subcontract agreements of
$10,000 or more used on the project.

FHWA-1273 - Required Contract Provisions, Federal-Aid Construction Contracts.

☐ EEO Affirmative Action Requirements. (Provide one sample subcontract agreement with a DBE and subcontractor)

5. In the past three years, have reviews made by the Equal Employment Opportunity Commission (EEOC), the Office of Federal
Contract Compliance Programs (OFCCP), or any other federal, state, or local agency regarding your company or any of your
subcontractors resulted in a determination of compliance or noncompliance?

Yes No (Provide name of agency, date of review, and results)

This is to certify that all information submitted is accurate and correct.

Submitted (Print Name) by: __________________________________________


(Name & Title)

Signature: ______________________________________________ Date:_____________

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TO BE COMPLETED BY THE
GEORGIA DEPARTMENT OF TRANSPORTATION

GDOT District EEO Review Officer sign and date below:

Contract Compliance Officer sign and date below:

L. Inspection
1. Review of the project was made to ensure that working conditions and employee facilities do not indicate Discriminatory
treatment of project site personnel.

Yes No Date:

2. Notices and posters have been placed in an area readily accessible to employees, applicants for employment, and potential
employees.

Yes No Where:

3. Check which of the following are posted at the job site.

Posted Bulletin Board – Accessible & Readable (A)

Federal Wage Rates (B)

Discrimination Complaint Procedure (C)

4. Are letters and notices dated and signed (where applicable – EEO policy statement/Bulletin Board)? Yes No

M. Project Manager Review

1. Does the contractor submit timely FHWA 1391 reports? Yes No

2. Does the contractor submit Certified Payrolls accurately and timely? Yes No

4. Have Labor Compliance and EEO Contract Compliance Job-Site Interviews been completed?

Yes No (Attach)

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