Anti-Harassment Directive
Issue revised draft directive on anti-harassment to include a more detailed definition of sexual harassment and provide a plain language explanation of existing anti-retaliation protections for individuals who report cases of sexual harassment or otherwise expose discriminatory practices.
Revised Mandatory Reporting Obligations
Revise the Anti-Harassment Policy to require that any manager that learns of or observes conduct that may fall within the scope of the policy report it formally and promptly, and no later than within 3 days.
See Cleary Gottlieb recommendation 4.b at page 169
Harassment Complaints
Develop procedures and guidelines to prepare close-out letters to be issued to filers of harassment complaints.
Exit Surveys
Seek opportunities to enhance all exit surveys conducted at the agency to better identify harassment as a factor in an employee leaving agency.
Anti-Fraternization Policy
Develop and implement an Anti-Fraternization Policy that requires supervisors who engage in intimate personal relationships with supervisees to report that relationship to their supervisor.
See Cleary Gottlieb recommendation 4.c at page 169
Anti-Retaliation Policy
Develop and implement a stand-alone Anti-Retaliation Policy to protect complainants from retaliation and to take action against those that are found to have engaged in retaliation.
See Cleary Gottlieb recommendation 4.d at page 170
Standard Operating Procedures
Develop more robust Standard Operating Procedures reflecting best practices for handling of complaints and investigations of the Anti-Harassment Policy, Anti-Fraternization Policy, and Anti-Retaliation Policy.
See Cleary Gottlieb recommendation 6.c at page 171
Student Resident Center (SRC) (Completed June 2024)
Update policies related to SRC to establish a residence-specific code of conduct and increase monitoring by security guards in common areas. Consider implementing a Resident Assistant Program to serve as a single point of contact for any issues that arise amongst employees residing at the SRC.
Travel Policies
Review travel policies to determine if any of these policies are negatively impacting the FDIC’s culture and environment. Develop needed modifications based on this assessment to improve employee’s safety and well-being, and retention.
Grievance Policies
Review grievance policies and examine options for extending timelines for processing harassment claims to increase time for victims to file a grievance for matters associated with sexual trauma.
Code of Conduct
Review and update code of conduct to better reflect FDIC core values and expectations for diversity, equity, inclusion, accessibility, and belonging.
Code of Workplace Conduct
Develop and implement a new Code of Workplace Conduct that defines behavioral expectations for all FDIC employees, is focused on the behavior the FDIC expects to see from its employees, and aligns with a culture in which all members can thrive and reach their full potential.
See Cleary Gottlieb recommendation 4.a at page 169