Wednesday, April 25, 2012

We're a Federal Contractor, Can We Take Our Employee Rights Poster Down?

No - Federal contractors are still obligated to post the Department of Labor's (DOL) "Notification of Employee Rights Under Federal Labor Laws" poster.

For the time being, employer are relieved of the obligation to post the National Labor Relation Board poster; however, the display the DOL's, "Notification of Employee Rights Under Federal Labor Laws" (which would also satisfy the NLRB requirement) has been required since June 21, 2010. 
Executive Order 13496, requires that Federal contractors provide notice to their employees of their rights under Federal labor laws. Specifically, the Order requires that covered contractors provide notice of employee rights under the National Labor Relations Act (NLRA), the law that governs relations between unions and employers in the private sector. The NLRA guarantees the right of employees to organize and to bargain collectively with their employers, to engage in other protected concerted activity with or without a union, or to refrain from all such activity.

EO 13496 applies to prime and subcontracts that result from Federal agency solicitations issued on or after the effective date of the regulations, June 21, 2010. If the amount of such a prime contract meets or exceeds the simplified acquisition threshold (currently $100,000), the prime contractor must comply with the Order. A contractor with a subcontract associated with a prime contract subject to the Order is also subject to the Order, provided the subcontract is valued at $10,000 or more.

Example: If a $100,000 prime contract, effective on June 22, 2010, is the result of a solicitation issued on June 6, 2010, the contract is not covered by EO 13496. If, however, the solicitation is issued on or after June 21, 2010, the resulting $100,000 contract is a covered contract, and the prime contractor and its subcontractors (with associated subcontracts of $10,000 or more) are subject to the Order.

Read more about Executive Order 13496

Download the EO 13496 Poster

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