An Office of Federal Compliance Contract Programs (“OFCCP”) opinion letter issued on January 8, 2021, walks through six potential religious discrimination scenarios as they pertain to federal contractors and subcontractors.  Scenarios addressed adverse employment actions taken based on:

1. an employee’s presumed religious values;
2. an employee’s religion has taken public policy positions that others may find offensive;
3. an employee’s attendance during non-work hours at a religious event that others may find offensive;
4. an employee, during a company rest break, expresses religious views others may find offensive;
5. an applicant or employee informing the employer about a religious requirement that necessitates an accommodation; and
6. an applicant or employee requesting an accommodation for religious observance.

Read the opinion letter here and Wolters Kluwer’s full article here.