Field, Regional, and Headquarter Reviews
Conduct regular reviews of Field, Region, and Headquarters offices to ensure compliance and consistency with FDIC directives related to sexual harassment, antiharassment, and equal employment opportunity.
Access to the Chairperson
The Chairperson and all individuals who directly report to the Chairperson should meet with at least each ERG, Chairman’s Diversity Advisory Council, and each Region to solicit input for the implementation process for all Cleary Gottlieb report recommendations.
See Cleary Gottlieb recommendation 1.c at page 167
Culture and Structure Transformation Monitor
Appoint a single individual, who is not currently employed by the FDIC, to monitor and audit any and all recommendations the FDIC adopts to remediate its culture, policies, procedures, and structures that impact sexual harassment, discrimination, and other interpersonal misconduct.
See Cleary Gottlieb recommendation 2.a at page 167
Annual Survey
Develop and implement an annual survey that solicits feedback on the effectiveness of the Anti-Harassment Policy, Equal Opportunity Policy, Anti-Fraternization Policy, and Anti-Retaliation Policy, as well as the procedures for taking complaints and conducting investigations.
See Cleary Gottlieb recommendation 7.c at page 172
Independent Third-Party Expertise
Retain an independent third party with substantial and credible experience in the topics covered by the Cleary Gottlieb report to advise and assist with implementation of all recommendations made in the report.
See Cleary Gottlieb recommendation 2.b at page 168
Disciplinary Follow-Up
Develop a process for assessing whether disciplinary action taken against an individual for violations of the Anti-Harassment Policy, the Equal Opportunity Policy, Anti-Fraternization Policy, and Anti-Retaliation Policy has been effective.
See Cleary Gottlieb recommendation 6.d at page 172
Routine Reporting
Develop a process for routine reporting on the implementation of all recommendations in the Cleary Gottlieb report to the FDIC Board as well as to all FDIC employees.
See Cleary Gottlieb report at page 173