On September 30, 2020, Princeton University (Princeton) and the Department of Labor Office of Federal Contract Compliance Programs (OFCCP) entered into an early resolution conciliation agreement (Agreement) to resolve allegations that Princeton was not in compliance with Executive Order 11246, as amended and its implementing regulations. Executive Order was signed by President Lyndon B. Johnson in 1965 and prohibits federal contractors from discriminating on the basis of race, color, religion, sex, sexual orientation, gender identity, or national origin.
OFCCP alleged that Princeton discriminated against 106 female full-time professors by paying them lower salaries than those paid to similarly situated male professors from 2012-2014. OFCCP also alleged that Princeton committed several technical violations, including failure to collect and maintain certain personnel and employment records and failure to evaluate compensation to identify potential gender-based pay disparities. Princeton denied the allegations and denied that it violated any laws or regulations related to the allegations. Princeton did not admit any misconduct or unlawful activity as part of the Agreement.
The Agreement requires Princeton to dedicate almost one million dollars to compensate the 106 female full-time professors impacted by the pay inequity and to efforts to remedy gender-based pay inequity at the school. The Agreement further requires Princeton to take several steps, including, but not limited to, conducting a salary equity review of all full-time professors, making prospective salary adjustments, conducting pay equity training for its Department Chairs, submitting regular salary data reports to the OFCCP, and implementing and enforcing record retention protocols. Princeton is also generally required to continue efforts to promote diversity, pay equity, and inclusion.
Note:
The settlement agreement is an important reminder that schools should periodically conduct salary equity reviews to ensure that similarly-situated male and female employees are equally compensated.