Defining Good Faith Efforts
What is Good Faith Effort?
FDIC defined "good faith effort" as actions by the contractor intended to identify and, if present, remove barriers to minorities and women within its workforce or expand employment opportunities for minorities and women within its workforce. Efforts to remove such barriers or expand employment opportunities may include, but are not limited to, recruiting women and minorities, providing job-related training, or other activity that could lead to those results.
How Identify and Eliminate Barriers?
Barrier identification and elimination is the process by which an employer can uncover, examine and remove barriers to equal participation at all levels of the workforce. A barrier can be a policy, principle or practice that limits or tends to limit employment opportunities for members of a particular race, national origin or gender group. Barrier removal is vital to assuring equal opportunity to employment; thus, an employer should work to create a barrier-free work environment where qualified applicants and employees have the freedom to compete and participate to the fullest extent possible, at all levels within the workforce. The use of barrier analysis will assist vendors in recruiting, hiring, developing, and retaining a high-performing workforce that draws upon the greatest talent pool.
An example of a barrier might be that a company only hires people through word of mouth. That would mean that if a highly qualified minority or woman candidate were not connected socially or professionally with current employees, they would be unlikely to have an opportunity to apply for a position. Barriers like this can be overcome through monitoring employment practices and increased outreach to expand applicant pool.
What is Evidence of a Contractor's Good Faith Effort?
The FDIC, through the Contracting Officer, may request a copy of a contractor's plan and evidence of completed actions to demonstrate good faith effort. This information may include, but is not limited to:
The total number of the contractor's employees, and the number of minority and women employees by race, ethnicity, and gender (e.g., EEO-1 report);
A list of subcontract awards under the contract that includes: dollar amount, date of award, and subcontractor's minority and/or gender ownership status;
Information similar to that required in item 1 above with respect to each subcontractor with a subcontract value that exceeds $100,000; and/or
The contractor's plan to ensure that minorities and women have appropriate opportunities to enter and advance within its workforce, including outreach efforts.