Diversity Self-Assessment Template for OCC-Regulated Ent

Diversity Self-Assessment Template for OCC-Regulated Entities

Section 342(b)(2)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act

SECTION I. BANK INFORMATION

The Office of the Comptroller of the Currency (OCC) provides this self-assessment template to national banks, federal savings associations,
and federal branches and agencies of foreign banks (together, banks) regulated by the OCC in support of the Interagency Policy Statement
Establishing Joint Standards for Assessing Diversity Policies and Practices of Regulated Entities dated June 10, 2015. Pursuant to the Policy
Statement, a self-assessment by a bank is voluntary. A bank that conducts a self-assessment of its diversity policies and practices using the
standards contained in the Policy Statement may utilize this template or its own assessment tool.
Bank Name:

Period Covered by the Assessment:
Date Submitted:

Address:

City:

State:

Zip Code:

Diversity and Inclusion Officer or Equivalent:

Supplier Diversity Officer or Equivalent (if different from D&I Officer):

Name:

Name:

Title:

Title:

Email Address:

Email Address:

Phone Number:

Phone Number:

Fax Number:

Fax Number:

Diversity and Inclusion Website:
Brief Description of Bank Covered by this Assessment (e.g., governance structure, workforce size, total assets, geographic location(s), and
community characteristics):

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Diversity Self-Assessment Template for OCC-Regulated Entities

Section 342(b)(2)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act

SECTION II. ASSESSMENT OF THE BANK’S DIVERSITY POLICIES AND PRACTICES
(1) Organizational Commitment to Diversity and Inclusion
The leadership of a bank with successful diversity policies and practices demonstrates its commitment to diversity and inclusion. Leadership comes from the
governing body, such as a board of directors, as well as senior officials and those managing the bank on a day-to-day basis. The Standards inform how a bank
promotes diversity and inclusion in both employment and contracting and how it fosters a corporate culture that embraces diversity and inclusion.

STANDARDS

YES

NO

PROGRAM SUCCESSES AND/OR
PROGRAM CHALLENGES

In a manner reflective of the individual bank’s size and other characteristics,
1.1 The bank includes diversity and inclusion considerations in both employment
and contracting as an important part of its strategic plan for recruiting, hiring,
retention, and promotion.
1.2 The bank has a diversity and inclusion policy that is approved and supported by
senior leadership, including senior management and the board of directors.
1.3 The bank provides regular progress reports to the board and senior
management.
1.4 The bank regularly conducts training and provides educational opportunities on
equal employment opportunity and on diversity and inclusion.
1.5 The bank has a senior level official, preferably with knowledge of and experience
in diversity and inclusion policies and practices, who oversees and directs the bank's
diversity and inclusion efforts.
1.6 The bank takes proactive steps to promote a diverse pool of candidates,
including women and minorities, in its hiring, recruiting, retention, and promotion,
as well as in its selection of board members, senior management, and other senior
leadership positions.
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Diversity Self-Assessment Template for OCC-Regulated Entities

Section 342(b)(2)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(2) Workforce Profile and Employment Practices
Many banks promote the fair inclusion of minorities and women in their workforce by publicizing employment opportunities, creating relationships with
minority and women professional organizations and educational institutions, creating a culture that values the contribution of all employees, and encouraging
a focus on these objectives when evaluating the performance of managers. Banks with successful diversity and inclusion programs also regularly evaluate their
programs and identify areas to be improved.

STANDARDS

YES

NO

PROGRAM SUCCESSES AND/OR
PROGRAM CHALLENGES

In a manner reflective of the individual bank’s size and other characteristics,
2.1 The bank implements policies and practices related to workforce diversity and
inclusion in a manner that complies with all applicable laws.
2.2 The bank ensures equal employment opportunities for all employees and
applicants for employment and does not engage in unlawful employment
discrimination based on gender, race, or ethnicity.
2.3 The bank has policies and practices that create diverse applicant pools for both
internal and external opportunities that may include:
2.3.a. Outreach to minority and women organizations.
2.3.b. Outreach to educational institutions serving significant minority and
women student populations.
2.3.c. Participation in conferences, workshops, and other events to attract
minorities and women and to inform them of employment and promotion
opportunities.
2.4 The bank utilizes both quantitative and qualitative measurements to assess its
workforce diversity and inclusion efforts. These efforts may be reflected, for
example, in applicant tracking, hiring, promotions, separations (voluntary and
involuntary), career development, and retention across all levels and occupations of
the bank, including the executive and managerial ranks.
2.5 The bank holds management at all levels accountable for diversity and inclusion
efforts, for example, by ensuring that such efforts align with business strategies and
individual performance plans.
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Diversity Self-Assessment Template for OCC-Regulated Entities

Section 342(b)(2)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(3) Procurement and Business Practices—Supplier Diversity
Companies increasingly understand the competitive advantage of having a broad selection of available suppliers to choose from with respect to factors such as price, quality,
attention to detail, and future relationship building. A number of banks have achieved success at expanding available business options by increasing outreach to minority-owned
and women-owned businesses. As in the employment context, banks often use metrics to identify the baseline of how much they spend procuring and contracting for goods and
services, how much they spend with minority-owned and women-owned businesses, and the availability of relevant minority-owned and women-owned businesses, as well as
changes over time. Similarly, banks may use outreach to inform minority-owned and women-owned businesses (and affinity groups representing these constituencies) of these
opportunities and of the procurement process. In addition, banks’ prime contractors often use subcontractors to fulfill the obligations of various contracts. The use of minorityowned and women-owned businesses as subcontractors provides valuable opportunities for both the minority-owned and women-owned businesses and the prime contractor.
Banks may encourage the use of minority-owned and women-owned subcontractors by incorporating this objective in their business contracts.

STANDARDS

YES

NO

PROGRAM SUCCESSES AND/OR
PROGRAM CHALLENGES

In a manner reflective of the individual bank’s size and other characteristics,
3.1 The bank has a supplier diversity policy that provides for a fair opportunity for
minority-owned and women-owned businesses to compete for procurement of
business goods and services. This includes contracts of all types, including contracts
for the issuance or guarantee of any debt, equity, or security, the sale of assets, the
management of the bank’s assets, and the development of the bank’s equity
investments.
3.2 The bank has methods to evaluate its supplier diversity, which may include
metrics and analytics related to:
3.2.a. Annual procurement spending.
3.2.b. Percentage of contract dollars awarded to minority-owned and
women-owned businesses by race, ethnicity, and gender.
3.2.c. Percentage of contracts with minority-owned and women-owned
business subcontractors.
3.3. The bank has practices to promote a diverse supplier pool, which may include:
3.3.a. Outreach to minority-owned and women-owned contractors and
representative organizations.
3.3.b. Participation in conferences, workshops, and other events to attract
minority-owned and women-owned firms and inform them of contracting
opportunities.
3.3.c. An ongoing process to publicize its procurement opportunities.
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Diversity Self-Assessment Template for OCC-Regulated Entities

Section 342(b)(2)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(4) Practices to Promote Transparency of Bank’s Diversity and Inclusion
Transparency and publicity are important aspects of assessing diversity policies and practices. Greater awareness and transparency give the public information
to assess those policies and practices. Banks publicize information about their diversity and inclusion efforts through normal business methods, which include
displaying information on their websites, in their promotional materials, and in their annual reports to shareholders, if applicable. By making public a bank's
commitment to diversity and inclusion, its plans for achieving diversity and inclusion, and the metrics it uses to measure success in both workplace and supplier
diversity, a bank informs a broad constituency of investors, employees, potential employees, suppliers, customers, and the general community about its efforts.
The publication of this information can make new markets accessible for minorities and women and illustrate the progress made toward an important business
goal.

STANDARDS

YES

NO

PROGRAM SUCCESSES AND/OR
PROGRAM CHALLENGES

In a manner reflective of the individual bank's size and other characteristics, the bank is transparent with respect to its diversity and inclusion
activities by making the following information available to the public annually through its website or other appropriate communication methods.
4.1 The bank publicizes its diversity and inclusion strategic plan.
4.2 The bank publicizes its policy on its commitment to diversity and inclusion.
4.3. The bank is transparent about its progress toward achieving diversity and
inclusion in its workforce and procurement activities, which may include the bank’s
current workforce and supplier demographic profiles.
4.4. The bank publicizes its opportunities to promote diversity, which may include:
4.4.a. Current employment and procurement opportunities.
4.4.b. Forecasts of potential employment and procurement opportunities.
4.4.c. The availability and use of mentorship and developmental programs
for employees and contractors.

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Diversity Self-Assessment Template for OCC-Regulated Entities

Section 342(b)(2)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(5) Banks’ Self-Assessment
Banks that have successful diversity policies and practices allocate time and resources to monitoring and evaluating performance under their diversity policies
and practices on an ongoing basis. Banks are encouraged to disclose their diversity policies and practices, as well as information related to their assessments,
to the OCC and the public.

STANDARDS

YES

NO

PROGRAM SUCCESSES AND/OR
PROGRAM CHALLENGES

In a manner reflective of the individual bank's size and other characteristics,
5.1 The bank conducts an assessment of its diversity policies and
practices annually.
5.2. The bank monitors and evaluates its performance under its
diversity policies and practices on an ongoing basis.
5.3. The bank publishes information pertaining to its assessment
of its diversity policies and practices.

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Diversity Self-Assessment Template for OCC-Regulated Entities

Section 342(b)(2)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act

SECTION III. DIVERSITY DATA
Workforce Profile
1.1. What are the numbers and percentages of women and minorities in the
bank’s total workforce for the period covered by this assessment?

1.2. What are the numbers and percentages of women and minorities in the
bank’s Executive/Senior Level Officials and Managers job category for the period
covered by this assessment?

1.3. What are the total numbers and percentages of women and minorities of
the bank’s Board of Directors for the period covered by this assessment?

Total
Workforce
______#

Women
______#
______%

Minorities
______#
______%

Total
Management
______#

Women
______#
______%

Minorities
______#
______%

Total Board
Members
______#

Women
______#
______%

Minorities
______#
______%

Total Spend
$______

Womenowned Spend
$______
______%

Minorityowned Spend
$______
______%

Procurement – Supplier Diversity
2.0. What is the bank’s total annual procurement spend for the period covered
by this assessment with women- and minority-owned businesses compared to
the total procurement spend with all vendors and suppliers?

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Diversity Self-Assessment Template for OCC-Regulated Entities

Section 342(b)(2)(C) of the Dodd-Frank Wall Street Reform and Consumer Protection Act

SECTION IV. ADDITIONAL INFORMATION
Other information or comments the bank deems important regarding its assessment of its diversity and inclusion policies and
practices:

Use of Information by the OCC
The OCC may use information submitted by the bank to monitor progress and trends in the financial services industry with regard to diversity and inclusion in
employment and contracting activities and to identify and highlight those policies and practices that have been successful. The OCC may also publish
information disclosed by the bank, such as leading practices, in any form that does not identify a particular institution or individual or disclose confidential
business information. Banks submitting information may designate such information as confidential commercial information as appropriate, and the OCC will
follow the Freedom of Information Act in the event of requests for particular information.

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