AA plan?

LAB

OK as part of my due diligence in taking new position I have discovered that we make parts for company that makes products for company that holds federal government contract. President does not feel we need AA Plan as we are not primary or 1st tier contractor (EEO 1 report asks this question). This is what my predecessor told him (I remind him that this person's lack of HR knowledge is why they are former employee). However everything I know and read says if you are a federal contractor or subcontractor, have 50 or more employees (we do) and provide products or services valued at $50,000 or more (we do) you must have a written plan. Primary or 1st tier does not matter. Short of contacting OFCCP directly and opening that can of worms does anyone know for sure if there is a limit along the food chain where you are not required to have a plan?

Thanks

LAB