Open Recommendations

We recommend the Chairman dedicate the necessary resources and staff time for effective implementation of the FDIC’s Anti-Harassment Program.

We recommend the Director, Division of Administration, develop and implement quality control procedures to ensure the FDIC maintains an accurate and complete population of sexual harassment misconduct allegations and related records.

We recommend the Director, Division of Administration, conduct a review of prior allegations to ensure that it has an accurate and complete population of sexual harassment allegations and that it has maintained all allegation records in accordance with the FDIC record retention schedule, which requires that all records be maintained for 7 years.

We recommend the Director, Division of Administration, implement an effective system for tracking, securing, documenting, and reporting sexual harassment misconduct allegations. Include the following: original allegation date, names of witnesses, whether allegations are substantiated or unsubstantiated, date of written notification to complainant and alleged harasser regarding completion of the investigation, written reports, misconduct type, and a unique identification code that follows the allegation through disciplinary action.

We recommend the Director, Office of Minority and Women Inclusion, develop and implement standard operating procedures to guide the efforts of the Anti-Harassment Program Coordinator.

We recommend the Directors, Office of Minority and Women Inclusion and Division of Administration, develop and implement standard operating procedures for case file records management, including where to securely maintain files, what to maintain, and how long to retain records.

We recommend the Director, Division of Administration, update and implement investigation standard operating procedures to clearly guide investigations by ensuring that investigations are: conducted appropriately and consistently; convey the outcome of the investigation, including a Report of Investigation; and are well-documented.

We recommend the Director, Division of Administration, provide regular investigation training to the LERS Specialists conducting investigations under the Anti-Harassment Program

We recommend the Director, Division of Administration, develop a centralized disciplinary action tracking system or tool and related procedures for what information should be captured in the tool and in support of the disciplinary decision.

We recommend the Chairman consider developing and implementing Agency-wide, consistent penalties or recommended penalty ranges to be used in disciplinary actions for harassing conduct, in accordance with applicable laws and regulations, and, as necessary and appropriate, incorporate the consistent penalties and recommended penalty ranges into policy and procedures.

We recommend the Chairman update the AHP Directive to include: (1) a statement that the policy applies to applicants, clients, customers, and other relevant individuals; (2) a statement that employees are encouraged to report conduct that they believe may be prohibited harassment (or that, if left unchecked, may rise to the level of prohibited harassment), even if they are not sure that the conduct violates the policy; and (3) astatement that the employer will provide a prompt, impartial, and thorough investigation.

We recommend the Chairman develop and implement a policy to ensure that parallel processing of allegations of sexual harassment occur under the EEO and the AHP as necessary and appropriate.

We recommend the Chairman develop and implement policy to ensure that staff who are responsible for promptly, thoroughly, and impartially investigating allegations of harassment and taking immediate and appropriate corrective action are neutral and free of conflicts or the appearance of a conflict.

We recommend the Chairman establish and implement a policy for handling allegations against senior-level corporate managers and executives from intake to final determination, including the use of Memorandums of Understanding, as appropriate, to engage those outside of the FDIC chains of command.

We recommend the Chairman update the AHP Directive to include: (1) a clear definition of sexual harassment misconduct and practical examples tailored to the workplace, (2) an explanation of the Agency’s duty to investigate and correct harassment even if alleged victims indicate they do not want the matter investigated or corrected, and (3) general time limits for concluding investigations.

We recommend the Chairman reassess and redesign, as needed, the roles and responsibilities within the AHP Directive to ensure all aspects of the Directive can be implemented. Further, we recommend the Chairman develop a plan for implementing all aspects of the AHP Directive

We recommend that the Chairman develop and implement regular, comprehensive, and effective required training on preventing and reporting sexual harassment for all nonsupervisory employees that incorporates elements from the EEOC 2023 Promising Practices, including a larger emphasis on the Agency’s prohibition for retaliation of any kind.

We recommend that the Chairman develop and implement regular, comprehensive, and effective required training for all supervisors and executives on preventing and reporting sexual harassment that incorporates elements from the EEOC’s 2023 Promising Practices, including a larger emphasis on the Agency’s prohibition for retaliation of any kind.

We recommend that the Chairman develop and implement a plan to routinely analyze the FDIC’s sexual harassment training, ensure that it is current, and measure the impact that training is having on reducing harassment and retaliation in the Agency.

Further evaluate space communication and navigation risks, including running and reviewingloading analysis from all four networks.

Develop a contingency plan for Roman’s space communication and navigation services,including an assessment of the DSN’s ability to support Roman.

Assess the potential impacts of the delayed upgrades to the NSN on Roman’s scheduled launchtimeline.

Work with Divisional Directors and District Managers at all the facilities to provide stand-up talks and training to all employees and maintain evidence the training was conducted as well as post the stand-up talks and relevant procedures around the workroom floor.

Develop and implement a process for delivery units to segregate Election Mail identified as Postal Automated Redirection System Mail prior to sending it back to a mail processing facility.

Evaluate the postmarking policy and adjust as necessary to ensure that all mail-in ballots receive a postmark.