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Internal grievance procedure

An important element of the Affirmative Action Program is the investigation and resolution of any employee grievance relating to discrimination because of race, color, religion, national origin, sex, age, or handicap. Any employee who believes that he or she has been discriminated against should discuss the grievance with his or her supervisor, assistant chief, chief, or manager; or with a counselor in the

Personnel Department.

An employee who believes that the grievance cannot be resolved may bring the grievance to the Equal Employment Opportunity Officer. A finding by the Equal Employment Opportunity Officer may be appealed to either the First Vice President or the President.

Bank profile

The Bank's minority and female profile, in the aggregates, favorably corresponds with that of the Bank's local labor market.'

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'Data as of December 31, 1988. The Bank's relevant labor market includes the following counties in New York: Bronx, Kings, Manhattan, Queens, Staten Island, Nassau, Putnam, Rockland, Suffolk, and Westchester, in New Jersey: Bergen, Essex, Hudson, Passaic, Union; and in Connecticut: Fairfield.

*1980 Census occupations comparable to Federal Reserve Bank of New York jubs at Salary Grades X-XVII.

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Detailed Response to Question 2a

COMPLAINT RESOLUTION PROCESS

In order to ensure sufficient and varied outlets for the airing of employee concerns, the Bank has established four means for resolving grievances or complaints. An employee may discuss her/his grievance with any or all of the following:

EEO Office

⚫ the employee's area or local management (supervisor, assistant chief, chief or officer),

⚫ the Equal Employment Opportunity officer at the Head
office or at the Buffalo Branch, or Equal Employment
Opportunity specialist,

⚫ the ombudsman at the Head Office or the Buffalo
Branch, or one of four deputy ombudspersons, and

⚫ officers and counselors in the personnel department.

The Bank's Equal Employment Opportunity (EEO) officer and the EEO specialist are responsible for investigating and resolving any employee grievance or complaint brought to their attention alleging discrimination based on race, color, religion, national origin, sex, sexual orientation, age or disability. Such grievances are expected to receive prompt and careful attention, to be investigated fully and impartially, and to be resolved as quickly as possible.

The EEO officer and the EEO specialist may inspect and examine all activities and documents they consider pertinent, hold meetings with whomever they believe can be of assistance,

and take whatever steps are required to obtain pertinent facts.

The EEO officer and the EEO specialist are responsible for

keeping the employee informed of the progress of the

investigation.

Upon concluding the investigation and review of a grievance, the EEO officer may: (a) resolve the matter informally; (b) instruct area management to take appropriate action, including disciplinary action if necessary, to effect a remedy for the complainant; or (c) dismiss the grievance, explaining the reason to the employee. A record of the EEO officer's investigation is prepared and filed in the EEO office. Any decision of the EEO officer may be appealed directly to either the first vice president or the president. A brief description of the EEO officer's responsibilities and resolution process are outlined in a bulletin issued on May 18, 1992 (copy attached).

The EEO officer and the EEO specialist periodically visit the regional check processing offices in the Second District in order to make themselves available to employees outside the head office who may wish to discuss a grievance with them. In addition, the EEO officer at the Buffalo Branch is available to address any issues at that office. The EEO office also has a voice mail system which enables evening and night force employees and others who cannot, or prefer not to, contact the office during regular hours, to call at their convenience and leave a message. The EEO officer is responsible for returning such calls promptly.

The Ombudsman Office

The complaint resolution process used by the ombudsman office is described on the reverse side of the Bank's News Bulletin, which was sent to Bank employees from James H. Oltman, first vice president, on March 30, 1992 (copy attached). This or similar reminders about the office of the ombudsman are sent to all employees twice a year.

The Bank's EEO officer and ombudsman prepare written reports to the president and the first vice president regarding the activities of their respective offices, including information on the various complaints handled during the year. Such reports are submitted directly to the president and first vice president by these officers, without any review by the Personnel Department officers or any other parties at the Bank. The President and First Vice President follow-up directly with the EEO office or ombudsman on particular issues or concerns. In addition, the employees of the Buffalo Branch have access to the Branch ombudsman and a deputy ombudsman at that office.

The Personnel Department

A personnel officer or personnel counselor will meet with an employee to determine the nature of his/her grievance. If the grievance pertains to equal employment opportunity, the personnel representative notifies a personnel officer and the Bank's EEO officer. A member of personnel management will speak with the parties involved in the grievance, including the employee's department management, in order to gain a clear understanding of the circumstances. The EEO officer is kept informed of

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