Withholding Bonuses

Update applicable criteria and withhold bonus opportunities for failure to implement or follow the FDIC Action Plan for a Safe, Fair, and Inclusive Work Environment.

Performance Standards

Update leadership performance standards to better support accountability for sexual harassment detection and prevention.

Performance Reviews

Revise performance reviews for all executives and managers to include assessments of the individual’s compliance with the FDIC’s values and the Code of Workplace Conduct.

See Cleary Gottlieb recommendation 3.a at page 168

Action Plans

Develop action plans to address any issues raised in the longevity pulse checks and listening sessions and to ensure a positive culture in the relevant Field Office, Region, or Division/Office.

See Cleary Gottlieb recommendation 3.f at page 169

Diversity and Inclusion Executive Advisory Council (EAC)

Hold special meetings for the EEO firm that conducts the barrier analysis to present to EAC members, all Regional Directors, Chairs of Field Supervisor and Supervisory Examiner Councils, and the Executive Sponsor(s) of each Employee Resource Group.

360-Degree Reviews

Implement a 360-degree review process for the Chairperson, all individuals who directly report to the Chairperson, Executive Managers, and anyone who has responsibility for an Action Plan committee or for implementing these recommendations.

See Cleary Gottlieb recommendation 3.b at page 168

Conducting Investigations Independently

Any allegations against the Chairperson, individuals who directly report to the Chairperson, and Executive Managers should be conducted by third-party firms that have not previously completed significant work in conjunction with senior FDIC executives.

See Cleary Gottlieb recommendation 6.b at page 171

Longevity Assessment

Develop longevity-related data that tracks the years in-position for all senior executives and managers to enable the FDIC to conduct pulse checks in Field Offices, Regions, and Divisions/Offices that have had senior leaders in position for significant periods.

See Cleary Gottlieb recommendation 3.c at page 169

Improved Recordkeeping

Ensure systematic recordkeeping of all formal and informal complaints alleging conduct falling within the Anti-Harassment Policy, Equal Opportunity Policy, Anti-Fraternization Policy, and Anti-Retaliation Policy, as well as records of associated investigatory and disciplinary actions.

See Cleary Gottlieb recommendation 6.e at page 172

Tracking Systems (Completed July 2024)

Enhance the centralized tracking system for monitoring sexual harassment claims to provide the agency with better data on the scope and nature of sexual harassment claims and improve decision making around how to best prevent and address sexual harassment.

Listening Sessions

Conduct annual listening sessions in any Field Office, Region, or Division/Office whose leader has been in place for more than 5 years.

See Cleary Gottlieb recommendation 3.e at page 169

Pulse Checks

Conduct annual pulse checks in any Field Office, Region, or Division/Office whose leader has been in place for more than 5 years.

See Cleary Gottlieb recommendation 3.d at page 169

Next ➜
Policies, Procedures, and Operations Review and Enhancement