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PART II

ADMINISTRATION OF THE FEDERAL CONTRACT
COMPLIANCE PROGRAM IN THE FEDERAL

SYSTEM AND WITHIN THE
DEPARTMENT OF LABOR

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and women with employers over which it has jurisdiction.

First, unlike the Equal Employment Opportunity Commission (EEOC), which also has jurisdiction over

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of size, location, vacancy rate, higher paying jobs,

patterns of employment of minorities and women and

related factors--are in a position to make the greatest

impact on the employment problems of minorities and

The compliance review process has an added ad

vantage over complaint or charge oriented procedures

in that its primary focus is on systemic or class-wide

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agencies, and labor unions who have 15 or more employ

ers and are engaged in industries affecting commerce, establishes the investigation, conciliation, and prosecu

tion of charges of discrimination as EEOC's primary

function. Only 35 percent of EEOC's charges allege class or systemic discrimination. I

An even smaller

percentage is of such comprehensiveness as to cover

an employers' total employment system as opposed to

individual segments relating to hiring, assignments,

training, promotion, etc.

Section 707 of the Civil

Rights Act of 1964, as amended, authorizes the Equal

Employment Opportunity Commission to initiate pattern

1

Staff Report on Investigation of Federal Enforcement of Equal Employment Opportunity Laws (hereinafter referred to as Staff Report). Prepared for the Subcommittee on Equal Opportunities of the Committee on Education and Labor, United States House of Repre

and practice charges, investigations and suits which

potentially have the same breadth as compliance re

views, other than affirmative action program issues.

In December, 1976, the Subcommittee on Equal Opportunities

reported that since the enactment of the 1972 amendments

to Title VII which authorized this procedure, fewer than

100 pattern and practice charges have been initiated, and

2 only five suits have been filed.

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goals and timetables element of the obligation operates

independently of a finding of discrimination.

Although

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