EQUAL EMPLOYMENT

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OPPORTUNITY-Policy Statement

At its December 16, 1968 meeting the Conference of Presidents approved a recommended policy statement on equal employment opportunity within the System and a 10-point program of action aimed at further progress in this field. The Board concurs in the policy position adopted by the conference and strongly supports the measures proposed by the conference aimed at effectuating its policy position.

The Board understands that key emphasis in this program will be placed upon reaching hard-core unemployed. It recognizes that such efforts may entail reasonable additional costs to the Reserve Banks, and it excepts such expenditures, subject to the safeguards contained in the conference program, from the limiting provisions of preceding S letters regarding the use of Reserve Bank funds for community projects. In view of the experi

mental nature of much of these efforts, the Board would appreciate receiving periodic progress reports. The Board staff will be prepared to work with the appropriate Reserve Bank representatives in developing such reporting procedures.

Notice is taken of the tenth and final point in the proposed program of actions, calling for the designation of a senior officer of each Reserve Bank to report to the president or first vice president with respect to the equal employment opportunity program. As this officer is essentially engaged in auditing each institution's program in this field, it appears that generally this appointed officer should be outside the regular personnel function and accessible to employees outside of the usual personnel channels. The Board has followed this approach, and asks that each Reserve Bank also give consideration to the value of distinguishing the officer who is to report on the equal employment opportunity program from its regular personnel administration. S-2074;

EQUAL EMPLOYMENT OPPORTUNITY-Reaffirmation of

Policy

On August 8, 1969, President Nixon issued Executive Order No. 11478, which outlined a continuing equal employment opportunity program....

The Board has on a number of occasions taken the position that, whether or not executive orders of the President relating to equal employment opportunity are legally binding on the Reserve Banks, the Board and each Reserve Bank in its own operations would conform to the spirit of such orders. In connection with Executive Order No. 11478, the Board today reaffirmed this earlier position. You will note that the order is in line with the 10-point program of action approved by the Conference of Presidents of the Federal Reserve Banks December 16, 1968, in which the Board concurred by letter of December 24, 1968 (S-2074 at 2-020). In May 1969 the Board adopted the same 10-point program with respect to its own equal employment opportunity program.

forward with their action plans, having in All Reserve Banks are encouraged to move mind the executive order and all phases of the 10-point program. S-2109; Nov. 6, 1969; ¶ 200.71.

Personnel (Policy Statements)

progress has been made in the System as a whole during the past year, and the Board looks forward to further implementation of the program at all supervisory levels during 1970.

It is understood that some of the Reserve Banks have developed or are considering developing affirmative EEO action plans with specific target dates. Having in mind the advantages of such plans, the Board believes that it would be desirable for all the Reserve Banks to have plans similar to those prescribed by the Civil Service Commission for government agencies and by the Treasury Department for depository banks. It is recognized that the action plan of any Reserve Bank might need to have certain unique institutional or community characteristics and, accordingly, the Board is not suggesting a uniform plan for all the Reserve Banks.• • •

The Board is interested in keeping in touch with the Reserve Bank EEO programs and will appreciate receiving copies of action plans initiated by them. S-2139; June 4, 1970; ¶200.72.

2-023

EQUAL EMPLOYMENT
OPPORTUNITY-Guidelines for
Review of Affirmative Action Programs

At its January 8, 1980 meeting, the Conference of Presidents approved a restatement of the System's support of equal employment opportunity and use of affirmative action programs. The restatement set out seven principles aimed at updating and reaffirming the earlier equal employment opportunity policy statement and program of action of December 16, 1968. In its statement, the conference observed that the primary focus of the affirmative action program is to eliminate personnel management practices that might tend to have an adverse effect on, or result in disparate treatment of, protected class members.

The Board concurs in the conference's position and supports the measures adopted by the conference to implement this policy. The

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Board believes that a reexamination of the System's EEO programs within the context of the seven principles referred to above will enable us to strengthen those programs, and thereby maintain a position of leadership in our EEO efforts among employers in our respective communities. The Board further recognizes that the seven principles will involve an analysis of Reserve Bank work forces to determine appropriate program goals and timetables, and the measurable actions necessary to achieve those goals. In such a program, special recruitment, training and educstional programs are appropriate means to facilitate the placement and career development of protected class members. A senior officer reporting directly to the president or first vice president of each Reserve Bank is the preferable arrangement for leadership and direction in implementing the Bank's equal employment opportunity initiatives.

The Board's director of EEO will provide assistance to the Reserve Banks by reviewing the effectiveness of their affirmative action programs and will also, where appropriate, make recommendations for improvement. In conducting these reviews, the director of EEO will follow the guidelines approved by the Personnel Subcommittee of the Conference of Presidents on March 14, 1980 (following).

The Board recognizes that efforts to foster equal employment opportunity may not succeed without a willingness to incur added costs. In considering these efforts, expenditures should, insofar as possible, be held within each Bank's overall budgetary goal.

Thoroughness of the Reserve Bank work force analysis process.

Thoroughness of the Reserve Banks prob lem-solving process. The director will check to determine whether reasonable

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achievement were analyzed and whether the Reserve Bank selected appropriate and effective strategies.

Specificity of AAP actions. The director will review the actions identified to determine if they are specific and sufficiently detailed to enable meeting the objectives and goals.

Measurable improvement in the targeted occupational areas over the planning year. The director will evaluate the degree of representation from one year to the next. Additionally, the director will monitor the overall status of EEO within the Reserve Bank and determine if progress already achieved in all occupations is maintained. · The existence of a results-oriented recruitment program and the implementation of Reserve Bank EEO management and information system. The director will monitor and evaluate Banks on the develop ment of EEO information systems that ensure that adequate statistical data is available for confirming work force analysis and affirmative action.

Further, the Reserve Banks should implement procedures to ensure that the AAP is fully integrated into the Reserve Bank personnel management system. This requires the following four processes.

1. Affirmative action policies and procedures should become routine personnel management practices. Therefore, the Reserve Bank should revise or update existing instructions or policy guidelines as necessary to reflect initiatives taken in the AAP. The AAP itself should contain specific actions to be taken on target dates.

2. The Reserve Bank should establish monitoring procedures that ensure an adequate flow of information through the department supporting the on-going affirmative action planning process. Reserve Bank personnel information systems should be initiated or mod

Personnel (Policy Statements)

that provide feedback on the status of EEO as well as AAP goal/objective accomplishment. The AAP development process outlined in this instruction would be used as a reference in the development of on-going information systems.

3. Techniques such as work force analysis and control charting should be developed as appropriate to evaluate the effectiveness of AAP initiatives and establish sufficient historical data profiles to show changes in EEO conditions over time.

4. The Reserve Bank should establish procedures and guidelines as necessary to evaluate and monitor its affirmative action programs. These procedures at a minimum should ensure that the Reserve Bank's AAP is implemented at all levels of the Reserve Bank.

Following is a checklist of topics to be addressed in Reserve Bank rules regarding employee conduct. Each employee should receive a copy of the rules and an annual reminder containing a summary of the rules.

The Board wishes to stress that Reserve Banks should (1) make certain that their written rules on standards of employee conduct are as high and as comprehensive as those contained in the Board's regulation (part 264 of the Code of Federal Regulations)

In 1958, a copy of the Code of Ethics for Government Service, endorsed by the U.S. Congress, was also distribut ed to the Reserve Banks for information purposes.