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Response to Questions, p.5

Our Organization is very committed to the Boston Public Schools. At present we have two partnership programs with Boston secondary schools. We are planning to inaugurate a third partnership program with a Boston elementary school in September 1992.

The Bank has in place a highly celebrated Skills Development Center. This program, which is approximately twenty years old, hires unskilled, disadvantaged, inner city residents and provides them with a paid on the job training program. The curriculum centers on clerical skills but trainees also receive computer skills as well as personal development skills. After a trainee has finished the program, he/she is either placed in a regular position in the Bank or is placed in a position in another company in the greater Boston area.

We also strive to be a visible member of the community by active participation in community groups and organizations. We are an active member of the Private Industry Council which sponsors a myriad of educational and job training programs and projects. The President serves as a member of both the Board of Directors and the Executive Committee of the Private Industry Council. In addition, we work with neighborhood groups which promote housing opportunities and access to credit for low-income people. One of these programs is the Boston Neighborhood Housing Services Program.

The Bank will continue to seek additional ways to be of service to the community, including the conduct of research and community partnership projects. 2. with respect to complaints based on any equal amployment opportunity or pertinent civil rights lavs, and your complaint resolution process:

a. Describe your complaint resolution process. The Bank is committed to assisting employees who may have a grievance. (See As Plan 1991 p. 25 and AA Plan 1992, p. 31)

We are currently enhancing our Grievance Policy by designating several employee representatives to serve as "ombudspeople" to assist employees who may have a complaint or issue. Our list of protections afforded to employees is extensive and includes equal opportunity regardless of race, color, gender, age, national origin, religion, disability,

Response to Questions, p.6

b. How many complaints, claims, notices allegations or charges, informal or formal, vere filed for each calendar year, 1990 and 1991?

In 1990 and 1991, the Bank had only three formal complaints. The Bank averages less than ten informal complaints per year. It is important to note that informal complaints rarely involve a discrimination charge; rather, they usually involve issues such as performance, advancement and personality conflicts.

c. For each category listed in b. above, please give a breakdown of the grounds alleged for discrimination by category, whether race, religion, sex national origin, disability or age, and the status of the resolution of the complaint.

Two of the above-mentioned formal complaints are now closed and one remains open. The first of the two closed complaints involved a 57 year-old Russian-born applicant for employment who claimed discrimination on the basis of age and national origin. This claim was dismissed by the Massachusetts Commission Against Discrimination on the basis that the allegations were unsubstantiated. The second closed complaint involved a black female employee who charged race discrimination. This claim was dismissed by the Equal Employment Opportunity Commission.

The one remaining open complaint involves a former employee who alleges that he was discriminated against on the basis of his sexual orientation. 3a. Does the bank have a specific minority and women contracting outreach program? If so, attach all relevant documents, including policy statements and program guidelines. Include any information pertaining to the executive level positions which administer or oversee such programs. What is the current reporting structure to the President's office?

The Federal Reserve Bank of Boston has actively fostered a minority business procurement program since 1975. An annual goal for minority business purchases is established and approved every year by this Bank's Board of Directors. A goal of $1,303,000 was established and approved by the Board of Directors as the 1991 target for minority business purchases. Actual minority business purchases for 1991 were $1,435,520 and represented 10.5% of total Federal Reserve Bank of Boston contract awards. Positive steady growth in minority business purchases by the Response to Questions, p.7

During 1986, the Bank additionally instituted a formal set-aside program encompassing both small and small disadvantaged (minority) vendors in accordance with its newly implemented Acquisition Guidelines. Further information regarding this Bank's program is included in this Bank's Acquisition Guidelines. (Attachment 7.)

Reporting information on businesses owned and controlled by women is not required under Federal Reserve Bank guidelines which are consistent with the policies of the Small Business Act and regulations thereunder. Specifically, the Bank's definition of socially and economically disadvantaged individuals is that definition cited in the regulations of the Small Business Act and includes groups set forth by the Small Business Administration. For purposes of the Small Business Act, women are not included as one of the identified groups, therefore, the Bank does not isolate purchases from women owned businesses for statistical reporting.

This Bank's results in minority business purchases are reported annually to the Board of Directors of the Federal Reserve Bank of Boston and published annually in the Federal Reserve Bank of Boston's Affirmative Action Plan document (See AA Plan 1991. pp. 22 - 23 for 1991 results) and to the Board of Governors of the Federal Reserve System (See Attachment 8).

Assistant Vice Presidents Marilyn E. Weekes and David K. Park are designated as the Federal Reserve Bank of Boston's Small Company Specialists and are responsible for coordinating the purchase of goods and services from small and small disadvantaged (minority) businesses. Ms. Weekes is also responsible for directing the operations of the General Services Department which includes the Purchasing Unit. Mr. Park serves as Assistant General Counsel. Both Ms. Weekes and Mr. Park report to a Vice President. Each Vice President reports to a Senior Vice President who in turn reports to either the first Vice President and Chief Operating officer or to the President.

The methodology for deriving a proposed annual goal for minority business purchases involves the following process undertaken by the Purchasing Unit of the General Services Department:

Discussion with applicable departments regarding future demand requirements and budgeted dollars for the purchase of potential goods or services available from

a.

Response to Questions, p.8
b. Assessment of timing of competitive bids and contracts

and bid and set-aside opportunities for minority
businesses;

C.

Assessment of the number of existing minority
businesses with whom we do business by category and the
potential for expansion of the minority supplier base
in specified account categories where necessary.

d.

Assessment of likelihood as to whether or not the competitive bid process for a specified category will include small or large non-minority vendors in addition to minority vendors.

e.

Comparison by category with prior year results and
assessment of reasons for increases or decreases in
dollar levels in the upcoming year.
Identification of new business opportunities for
General Services to pursue during the upcoming year.

f.

3b. Describe specifically for 1991 the number and monetary value of contracts with lil minorities, or minority-owned entities, and (ii) women, or wonen-owned entities, which provide (a) financial services, (b) investment banking, (c) undervriting, (a) accounting, (e) legal services, (f) asset management (g) asset disposition or (b) other (please describe). Indicate the date the contract began and its torn.

The number of contracts made to minority businesses in 1991 was 543 and represented a 15% increase over 1990. Our 1991 minority business purchases goal of $1,303,000 was surpassed by $132,520 or 10% (See AA Plan 1991. p. 22). As previously mentioned above, our records do not separately capture reporting information on awards to women or womenowned entities. Goods or services provided by our minority businesses would be included in category (h) above. Key product categories in 1991 included computer supplies and equipment, plastic bags, plumbing and electrical supplies, office supplies, and printing and business forms. The top two categories for minority vendor purchases in 1991 were in computer supplies and equipment at $545,064 and office supplies at $458,243.

Attached is a listing of all awards made to minority businesses, the product category, the dollar amount of the issued contract and the month in which the contract was

Response to Questions, p.9 30.

Does the bank have a minority and vonon certification process? Does the bank accept certifications made by other Poderal Reserve Banks or government, State or Federal agencies?

The Federal Reserve Bank of Boston does have a certification process wherein small or small disadvantaged (minority) businesses are required to denote on our designated supplier form (See Attachment 11), the ownership/control status of the company and its size category in accordance with the Small Business Act. All current and prospective vendors doing business with the Federal Reserve Bank of Boston are informed of this Bank's policy regarding participation by small and small disadvantaged businesses in Reserve Bank procurement contracts through a letter issued to them from Ms. Weekes, Assistant Vice President and Small Company Specialist. (See Attachment 10). Vendors are asked to complete our designated supplier form (Attachment 11) and include a copy of any certification or determination of their status under the Small Business Act. Return of the designated form completed and signed by an officer of the company is accepted by us as sufficient certification by the vendor as to their status. No further investigation or documentation is required if on our form the vendor denotes that it is a small or small disadvantaged (minority) business. Certifications can be withdrawn when successfully challenged, such as might be done by a competing vendor.

Certification certificates or letters from other certifying organizations received from vendors are considered supplementary vendor information but may be useful in cases where challenges occurred from competing vendors.

The Federal Reserve Bank of Boston is also a member of The New England Minority Purchasing Council, Inc. Assistant Vice President Ms. Weekes serves as a member of the Board of Directors and is the Treasurer for this organization. Ms. Weekes also chairs the Certification Committee of its Board. The New England Minority Purchasing Council, Inc. (NEMPC) is a non-profit corporation established in 1974 to encourage and facilitate the growth and expansion of minority-owned businesses. The NEMPC is one of forty seven purchasing councils around the country affiliated with the National Minority Supplier Development Council, Inc. The Certification Committee of the NEMPC ensures that companies applying for certification are in compliance with the definitions for minority business enterprises in accordance with the Small Business Act of the Small Business

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