D2DInc invited Patrick Hill, Executive Vice President of Foster Thomas to be our guest blogger. D2DInc will be working with Foster Thomas to provide training classes to government contractors and to ensure our clients have the HR management support they need to ensure their company is compliant with applicable government regulations.

As an HR management consulting firm, we are often asked by business owners and executives of government contractors:  What are the major HR compliance areas that I should be concerned with?

This is obviously a loaded question as there are many areas of HR compliance that companies must focus on.  However, within a two part series of blog posts, we’ll address the TOP FOUR that I see many companies needing to place more of an emphasis on.

Each of these areas is not only important to an organization’s success, but as a government contractor, most companies will specifically certify that they will comply with these regulations on each contract or sub-contract that they engage in.  The first two areas we’ll address include:

  • Executive Order 11246 – Affirmative Action Plan
  • Business Conduct and Ethics

Executive Order 11246 applies to government contractors or subcontractors with annual federal contracts totaling $50,000 or more and at least 50 employees.

  • A written Affirmative Action Plan is required under Executive Order 11246 and this plan will identify those areas, if any, in a contractor’s workforce that reflect under-utilization of women and minorities.
  • Based on an analysis of the workforce, utilization analyses are conducted and goals     (if applicable) are established to reduce the under-utilization.
  • The Office of Federal Contract Compliance Programs (OFCCP) monitors compliance and companies will often have their plans audited.
  • Penalties for non-compliance can include monetary fines and suspension.
  • The OFCCP also has the authority to debar a contractor from receiving federal contracts.

Additional compliance information can be found at:  http://www.dol.gov/compliance/laws/comp-eeo.htm

Business Conduct and Ethics practices for government contractors are defined in the Federal Acquisition Regulations (FAR).

  • Recent FAR amendments require employers that have a federal contract of at least $5 million to adopt a code of business ethics and conduct and to educate employees on its provisions.
  • Within 30 days of entering into an affected government contract, organizations must adopt a written code of business ethics and conduct, provide a copy of the code to each employee engaged in the contract and promote compliance with the adopted code.
  • Within 90 days of entering into a government contract, organizations must establish an “ongoing business ethics and business conduct awareness program,” in short, training.
  • They must also establish an internal control program aimed at the timely discovery of improper conduct and ensuring corrective measures are taken.
  • The complete text of the new FAR requirements can be found at:




Subscribe to this Blog and be notified as soon as Part II of this HR Compliance post goes live.  The next two topic areas we’ll discuss are:

  • Harassment and Discrimination
  • Fair Labor Standards Act – Exempt and Non-Exempt Classifications


Foster Thomas is the Mid-Atlantic region’s leading HR Management Consulting organization. With over 17 years of experience providing best-in-class HR-focused professional services, Foster Thomas creates custom scalable HR solutions for emerging and mid-sized organizations, government contractors and non-profits.