Guidance relating to Workforce Profile and Employment Practices

Executive Summary

The FDIC's Financial Institution Diversity is a program for assessing the diversity policies and practices of FDIC regulated financial institutions. The FDIC, together with other federal financial regulators, developed and issued the Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies (Policy Statement).

The Standards identified in the Policy Statement offer guidance and a framework that enable a financial institution to voluntarily assess its diversity and inclusion practices in several key areas:

• Organizational Commitment to Diversity and Inclusion

• Workforce Profile and Employment Practices

• Procurement and Business Practices – Supplier Diversity

• Practices to Promote Transparency of Organizational Diversity and Inclusion

• Entities' Self-Assessment

Office of Minority and Women Inclusion (OMWI) agencies have, independently, collected the assessment data they receive to report on diversity progress and trends to raise awareness of diversity policies and practices in an effort to benefit the financial services industry as a whole. The diversity self-assessments have provided valuable insight into the financial industry's diversity and inclusion practices, and has enabled the FDIC to identify areas where financial institutions experience challenges in their implementation of diversity and inclusion practices. The financial institutions self-assessment responses using the Standards help FDIC identify "exemplary" practices. These practices are actions adopted by financial institutions that expand and improve upon their workforce diversity and inclusion.

OMWI agencies have observed that diversity policies and practices continue to develop and expand throughout the industry since the Policy Statement was developed in 2015. As a result, the FDIC has captured exemplary practices that have been shared by its regulated financial institutions in their diversity self-assessments, as well as leading practices shared by industry-related organizations (e.g., National Bankers Association). Informational guides have been developed for the financial institutions' further development or improvement of their diversity policies and practices relating to the Standards.

Guidance for developing or improving diversity policies and practices relating to Standard 2, Workforce Profile and Employment Practices of the Diversity Self-Assessment of FDIC Regulated Financial Institutions

The Importance of Diversity and Inclusion in the Workplace

Diversity and inclusion is embedded in the FDIC's core values, which are integrated throughout the organization and work environment to help the FDIC continue to effectively achieve its mission of preserving and promoting public confidence in the U.S. financial system.

As stated in the FDIC's Diversity, Equity, and Inclusion Strategic Plan:

Diversity is defined by who we are as individuals. The FDIC recognizes that its strength comes from the dedication, experience, talents, and perspectives of every employee. Diversity encompasses the range of similarities and differences each individual brings to the workplace, including but not limited to national origin, language, race, color, disability, ethnicity, gender, age, religion, sexual orientation, gender identity, socioeconomic status, veteran status, and family structures.

Inclusion is the process of creating and maintaining a work culture and environment that recognizes, appreciates, and effectively utilizes the talents, skills, and perspectives of every employee in the achievement of the agency's objectives and mission; connects each employee to the organization; and encourages collaboration, flexibility, and fairness.

Examples of Workforce Diversity Practices

The financial institutions are employing a variety of methods and approaches to identify, attract, recruit, retain and train a diverse and qualified workforce. Conducting a diversity self-assessment enables financial institutions to assess their current diversity maturity to set benchmarks so they can develop strategies that increases their workforce diversity. Additionally, we have observed that while smaller banks have noted their limited resources, methods were nonetheless improvised to implement into their workforce diversity practices.

The FDIC has identified practices that apply to Standard 2, Workforce Profile and Employment Practices, that financial institutions might consider implementing as part of their workforce diversity practices. Some examples are shared for you to consider as you develop and grow diversity practices within your institution's workplace.

Outreach and Recruitment

• Identify classifications applicable to your institution's location (county/city) based on the U.S. Census Bureau's1 (census.gov) EEO labor-force tabulation table(s);

• Participate on the boards of Colleges;

• Utilize minority and women owned recruiting firms;

• Engage low income minority-majority students located at local high schools, colleges/ universities to discuss the employment and career opportunities, and offer internships;

• Establish partnerships and collaborative relationships with professional diversity organizations, Historically Black Colleges and Universities, Hispanic Serving Institutions, local non-profits and other diversity organizations to provide internship and learning opportunities;

• Source from state job-board services that aid unemployed, disadvantaged, and veteran communities;

• Hire summer interns from diverse, low income, minority-majority high schools and pairing them with a mentor to help them build a career plan;

• Establish partnerships:

  • With representatives of minority groups and community outreach programs to help place individuals for employment and to be resources to help minority job seekers with resume writing, mock interviewing, and business etiquette;

  • With trade organizations to create a training course about careers in the financial services industry for young adults from low income and underrepresented communities.

• Inform local staffing firms (for permanent or temporary employment) to make them aware of their commitment to EEO and diversity;

• Attend job and career fairs that attract minorities and women participants;

• Participate as an exhibitor or panelist in job and career fairs to promote vacant positions to women and minorities organizations;

• Sponsor community events and promote EEO/Diversity message to participants to attract women and minorities.

Employment Postings

• Post job openings/positions on various boards to expand hiring opportunities to diverse applicants. Examples of websites that cater to a diverse population of applicants, include: * AbilityLinks.org * Recruiting.com * Veteran Advantage * Goodwill * JobCorps * US Department of Veteran Affairs * Wilson Resources * OurPeopleWork.org * Monster.com to 36 websites on the Monster Diversity Job Network * Jobs.com * HireBilingual.com

• Announce job openings internally so institution's employees can avail themselves of opportunities for growth and advancement, and/or refer qualified candidates that known to them;

• Market vacancies through U.S. Department of Labor and State Workforce Centers;

• Announce job opportunities on message boards at local colleges and universities;

• Place blind ads via Indeed and local newspapers from which resumes are received by email and initial introductory interviews are scheduled without first seeing/meeting the applicants;

• Publicize employment opportunities through external organizations that serve women and minorities.

Workforce Retention

• Demonstrate buy-in from the top. Increased diversity in the executive ranks of the banking industry requires the support of senior leadership;

• Establish internal retention/appreciation programs (new hire welcome luncheon, service milestones, promotions, employee roundtables, employee meetings, etc.);

• Create a program to identify and develop women and minorities for professional advancement;

• Develop individual career plans for women and minorities identified as potential leaders in the organization;

• Formalize and provide a mentorship program;

• Provide development and skill-based training for advancement opportunities;

• Participate in women or minority-focused organizations' surveys, or hire a third party company to conduct a survey for assessing employee engagement and satisfaction levels. The benefits of hiring a third party company to survey employees provide:

  • Neutral expertise in administration,

  • Unbiased results, and

  • Increased confidence level for the employees as they complete the survey anonymously.

Informational Resources for Workforce Diversity and Inclusion

Informational resources are provided for further research and exploration, and include:

• Information about the FDIC's Financial Institution Diversity Program

• Equal Employment Opportunity Commission (EEOC)

  • Best Practices for Employers and Human Resources/EEO Professionals, that include suggestions for recruitment, hiring and promotion.

  • Small Business Resources and tips:
    https://www.eeoc.gov/employers/smallbusiness/resources.cfm
    https://www.eeoc.gov/employers/smallbusiness/tips.cfm

• Disability Employment

  • U.S. Office of Personnel Management (U.S. OPM) Disability Employment Recruiting Tips

  • U.S. Department of Labor (DOL) Public Sources for Recruitment and Hiring of Qualified Individuals with Disabilities

• American Bankers Association (ABA)

  • Business Case for Diversity: https://www.americanbanker.com/opinion/the-business-case-for-diversity

  • Diversity-related guide to aid the financial organizations in Recruiting a Diverse Workforce, published May 27, 2020, that offers 10 tips to develop an effective diversity recruitment strategy.

• The goal of the United States House Financial Services Subcommittee on Diversity and Inclusion is "to bring diversity and inclusion to the forefront of the conversation on how to make the financial services industry and all industries work for every American. Hearings relating to workplace diversity that help to identify best practices in the financial industry can be accessed on the web site.

2. Workforce Profile and Employment Practices

Many financial institutions promote the fair inclusion of minorities and women in their workforce by publicizing employment opportunities, creating relationships with minority and women professional organizations and educational institutions, creating a culture that values the contribution of all employees, and encouraging a focus on these objectives when evaluating the performance of managers. Financial institutions with successful diversity and inclusion programs also regularly evaluate their programs and identify areas to be improved.

1. 2.1 The financial institution implements policies and practices related to workforce diversity and inclusion in a manner that complies with all applicable laws.

2. 2.2 The financial institution ensures equal employment opportunities for all employees and applicants for employment and does not engage in unlawful employment discrimination based on gender, race, or ethnicity.

3. 2.3 The financial institution has policies and practices that create diversity that may include:

   • 2.3(a) Outreach to minority and women organizations.

   • 2.3(b) Outreach to educational institutions serving significant minority and women student populations.

   • 2.3(c) Participation in conferences, workshops, and other events to attract minorities and women and to inform them of employment and promotion opportunities.

4. 2.4 The financial institution uses both quantitative and qualitative measurements to assess its workforce diversity and inclusion efforts. These efforts may be reflected, for example, in applicant tracking, hiring, promotions, separations (voluntary and involuntary), career development, and retention across all levels and occupations of the financial institution, including the executive and managerial ranks.

5. 2.5 The financial institution holds management at all levels accountable for diversity and inclusion efforts, for example, by ensuring that such efforts align with business strategies and individual performance plans.