Grant Administration: Section 4.3 Equal Employment Opportunity (EEO) Compliance

Municipalities also are required by Title VI of the Civil Rights Act of 1964 to prohibit discrimination on the basis of race, color, or national origin in all federal assisted programs. This law and Executive Order 11246, as amended, specifically prohibits discrimination in employment practices. This Executive Order, applicable to any business or organization that has a federal contract/ subcontract or multiple contracts totaling greater than $10,000, also imposes requirements for affirmative action. When procuring goods, construction contractors, or professional services, grantees should incorporate equal opportunity in employment clauses in solicitation (bidding) and contract documents.

Executive Order 11246 and other statutes require grantees, sub-recipients, contractors, and subcontractors to prohibit discrimination based on the following:

  • Race
  • Sex
  • Creed
  • Religion
  • Color
  • National Origin
  • Age
  • Disability
  • Genetic Information
  • Military History

Further, grantees are required to take “affirmative action” to overcome the effects of past discrimination in the administration of federally-funded programs. Affirmative action means promoting equal employment and income development opportunities by gaining support from all administrative levels in establishing practical action plans, maintaining continual evaluation, and retaining focus and progress toward stated goals.

EEO Posters must be displayed at the grantee and all job sites supported with CDBG funds. It is the responsibility of the grant administrator to provide the posters to the grantee, as well as any sub-recipient of CDBG funds, and to verify that the posters are displayed at the job site. See Attachment 4-9: Equal Employment Opportunity Posters.

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