Form 3235-0740 Diversity Assessment Form

DIVERSITY ASSESSMENT REPORT FOR
ENTITIES REGULATED BY THE SEC

The U.S. Securities and Exchange Commission (SEC) provides the Diversity Assessment Report to entities
regulated by the SEC in support of the Joint Standards for Assessing the Diversity Policies and Practices
of Entities Regulated by the Agencies (Joint Standards) issued by the federal financial regulatory
agencies through an interagency policy statement dated June 10, 2015.
The Diversity Assessment Report is designed to guide and inform a regulated entity’s self-assessment
of its diversity policies and practices using the Joint Standards. It also provides the regulated entity with
a template for submitting diversity self-assessment information to the OMWI Director at the SEC, as
contemplated under the Joint Standards.
The Joint Standards address a regulated entity’s U.S. operations. Use of the Joint Standards by a
regulated entity is voluntary, as are conducting a self-assessment, and submitting diversity selfassessment information to the SEC.
The Joint Standards reflect leading policies and practices for advancing workforce and supplier diversity.
They are intended to be applied in a manner appropriate to the regulated entity’s unique characteristics,
such as workforce size, governance structure, total assets, and geographic location. Some standards may
not be applicable to every regulated entity. Accordingly, the SEC recognizes that the responses provided
in the Diversity Assessment Report reflect the regulated entity’s unique characteristics.
Use of Information by the SEC
The information collected from Diversity Assessment Reports will be aggregated and used in reports
such as the OMWI Annual Report to Congress.
The information may also be used to identify and highlight successful policies and practices. The SEC
may publish leading diversity practices in a form that does not identify a particular entity or disclose
confidential business information.
Confidential Treatment Request
Entities submitting information considered sensitive and confidential business information may request
confidential treatment of the information in accordance with the SEC procedures under the Freedom of
Information Act (17 CFR 200.83), and the SEC will keep the information confidential to the extent allowed
by law.

Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average ten (10)
hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the
data needed and completing and reviewing the collection of information. Send comments regarding this burden estimate or any
other aspect of this collection of information, including suggestions for reducing this burden to: David Bottom, Director/Chief
Information Officer, Securities and Exchange Commission, c/o Cynthia Roscoe, 100 F Street NE., Washington, DC 20549, or send an
email to [email protected], and include “SEC File No. 270-664—OMWI Diversity Assessment Report” in the subject line of the
message.

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SECTION I: FIRM INFORMATION
Firm Name

Total Number of Employees

Address
City

State

Zip

Website
Type of Registration (Check All That Apply)
Broker-Dealer
Investment Adviser
Investment Company (Mutual Fund)
Transfer Agent
Municipal Advisor
Private Fund Adviser
Clearing Agency
Nationally Recognized Statistical Rating Organization
National Securities Exchange
O
 ther Self-Regulatory Organization (such as, the Financial Industry Regulatory Authority
and Securities Rulemaking Board)

Point of Contact for this Report (POC)
Title

Email

Phone
Diversity and Inclusion Officer or Equivalent
Same as POC
Title

Email

Phone
Business Diversity Officer or Equivalent
Same as POC
Title

Email

Phone
Diversity and Inclusion Webpage

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SECTION II: ASSESSMENT OF DIVERSITY POLICIES AND PRACTICES
1. Organizational Commitment to Diversity and Inclusion
The leadership of a firm 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 regulated entity on a day-to-day basis.
In a manner reflective of its size and
other characteristics,

Yes

Comments

1.1 The firm has a written diversity
and inclusion policy that is
approved and supported by the
chief executive officer or other
senior level official.

1.2 A senior level official with
experience in diversity and
inclusion policies and practices
oversees and directs the firm’s
diversity and inclusion efforts.

1.3 The firm includes diversity and
inclusion considerations as part
of its strategic plan for recruiting,
hiring, retaining, and promoting
employees.

1.4 The firm includes diversity
and inclusion considerations
as part of its strategic plan for
recruiting, hiring, retaining, and
promoting executive and senior
level officials and managers.

1.5 The firm includes diversity and
inclusion considerations as part
of its strategic plan for recruiting
and selecting members of the
board of directors or other
governing body.

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In a manner reflective of its size and
other characteristics,

Yes

Comments

1.6 The firm includes diversity
and inclusion considerations
as part of its strategic plan for
contracting with vendors and
suppliers.

1.7 The firm takes proactive steps
to promote a diverse pool of
candidates when:

1.7(a) Selecting executive and
senior level officials and
managers.

1.7(b) Selecting members of
the board of directors or
other governing body.

1.8 The firm regularly offers training
and educational opportunities
on equal employment opportunity and diversity and inclusion.

1.9 The firm provides regular
progress reports on diversity
and inclusion efforts to the
board of directors or other
governing body.

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In a manner reflective of its size and
other characteristics,

Yes

Comments

1.10 The firm takes diversity and
inclusion into consideration
when making strategic planning
and governance decisions.

The Joint Standards reference minorities and women, but do not preclude a firm from using a broader
definition of diversity. If your firm uses a broader definition, such as including individuals with disabilities,
veterans, or lesbian/gay/bisexual/transgender individuals, please describe.

Please describe any other ways in which your firm demonstrates its organizational commitment to
diversity and inclusion.

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2. Implementation of Employment Practices to Promote Workforce Diversity and Inclusion
Many firms proactively promote diversity and the fair inclusion of minorities and women in their
workforces. Firms with successful diversity and inclusion programs also regularly evaluate their programs
and identify areas to be improved.
In a manner reflective of its size and
other characteristics,

Yes

Comments

2.1. The firm implements policies
and practices that create or
foster diverse applicant pools
for employment opportunities.
These practices may include:

2.1(a) Outreach to minority and
women organizations.

2.1(b) Outreach to educational
institutions serving significant or predominantly
minority and women
student populations.

2.1(c) Participation in conferences, workshops, and
other events to attract
minorities and women
and to inform them of
employment and promotion opportunities.

2.1(d) Communication of employment opportunities
through media predominately serving minorities
and women.

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In a manner reflective of its size and
other characteristics,

Yes

Comments

2.2 The firm regularly evaluates
performance under its workforce
diversity and inclusion programs.

2.3 The firm uses quantitative
measures to assess the
effectiveness of its diversity
and inclusion efforts in its
employment activities (e.g.,
hires, promotions, separations,
career development, and
retention).
2.4 The firm uses qualitative
measures (e.g., surveys) to
assess the effectiveness of its
diversity and inclusion efforts in
its employment activities.

2.5 The firm holds management at
all levels accountable for diversity and inclusion efforts, for example by assuring these efforts
align with business strategies or
individual performance plans.

Please describe any other actions the firm takes to promote workforce diversity and inclusion.

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Please describe practices that have been most successful in advancing workforce diversity and inclusion.

3. Procurement and Business Practices—Business Diversity 1
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. Many firms have successfully expanded available business options by increasing
outreach to minority-owned and women-owned businesses. The use of minority-owned and womenowned businesses as subcontractors also provides valuable opportunities for both the minority-owned
and women-owned businesses and the prime contractors.
In a manner reflective of its size and
other characteristics,

Yes

Comments

3.1 The firm has a business diversity
policy that is aimed at providing
business opportunities to diverse
suppliers, including minorityowned and women-owned
businesses.

3.2 The firm has policies and
practices that provide minorityowned and women-owned
businesses an opportunity to
enter into agreements for:

3.2(a) The issuance of or
guarantee of any debt,
equity, or security.

1

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The term “business diversity” has been substituted for “supplier diversity” to reflect that programs also cover businesses
providing professional services.

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In a manner reflective of its size and
other characteristics,

Yes

Comments

3.2(b) The sale of assets.

3.2(c) The management of the
entity’s assets.

3.2(d) The development of
the entity’s equity
investments.

3.3 The firm takes steps to promote
a pool of diverse businesses.
These steps may include:

3.3(a) Conducting outreach
to minority-owned and
women-owned businesses
and representative
organizations.

3.3(b) Participating in
conferences, workshops,
and other events to
attract minority-owned
and women-owned
businesses and inform
them of contracting
opportunities.

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In a manner reflective of its size and
other characteristics,

Yes

Comments

3.3(c) Maintaining a list of
qualified minority-owned
and women-owned
businesses that may
compete for upcoming
contracting opportunities.

3.3(d) Having an ongoing
process to publicize
its procurement
opportunities.

3.4 The firm has established
methods to evaluate its business
diversity efforts. These methods
may include metrics and
analytics related to:

3.4(a) The annual amount spent
purchasing goods and
services.

3.4(b) The annual amount spent
with minority-owned and
women-owned businesses
by gender, race, and
ethnicity.

3.4(c) The percentage of the
annual amount spent
with minority-owned and
women-owned businesses
by gender, race, and
ethnicity, as compared to
the total annual amount
spent purchasing goods
and services.

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Please describe practices that have been most successful in advancing supplier diversity objectives.

4. Practices to Promote Transparency of Organizational Diversity and Inclusion
Transparency and publicity are important aspects of assessing diversity policies and practices. By
making public a regulated entity'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 business diversity, a
regulated entity informs a broad constituency of investors, employees, potential employees, business,
customers, and the general community about its efforts.
In a manner reflective of its size and
other characteristics,

Yes

Comments

4.1 The firm publishes information
about its diversity and inclusion
efforts. This includes publications on:

4.1(a) Internal platforms.

4.1(b) Website.

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In a manner reflective of its size and
other characteristics,

Yes

Comments

4.2 The firm publishes on its
website or otherwise makes
public information regarding its
diversity and inclusion efforts.
The published information may
include:

4.2(a) The firm’s diversity and
inclusion strategic plan.

4.2(b) The firm’s policy on its
commitment to diversity
and inclusion.

4.2(c) Information about the
firm’s progress toward
achieving diversity
and inclusion in its
workforce, including the
demographic profile of
the firm’s workforce.

4.2(d) Information about the
firm’s progress toward
achieving its business
goals.

4.2(e) Information about the
demographic composition
of the firm’s board
of directors or other
governing body.

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In a manner reflective of its size and
other characteristics,

Yes

Comments

4.2(f) Information on
partnerships and
sponsorships with diverse
organizations.

4.3 The firm publicizes opportunities
that promote diversity and
inclusion on its website. The
opportunities may include:

4.3(a) Employment and
internship opportunities.

4.3(b) Contracting opportunities.

4.3 (c) Developmental programs
for potential vendors and
suppliers.

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Please describe any other tools your firm has found useful in promoting transparency of organizational
diversity and inclusion.

5. Self-Assessment of Diversity Policies and Practices
Firms that have successful diversity policies and practices devote time and resources to monitoring and
evaluating performance under their diversity policies and practices on an ongoing basis. Firms regulated
by the SEC are encouraged to disclose their diversity policies and practices, as well as information related
to their assessments, to the SEC and the public.
In a manner reflective of its size and
other characteristics,

Yes

Comments

5.1 The firm monitors and evaluates
performance under its diversity
policies and practices on an
ongoing basis.

5.2 The firm uses the Joint
Standards to conduct an
assessment of the firm’s
diversity policies and
practices annually.

5.3 The firm publishes information
pertaining to its assessment
of its diversity policies and
practices.

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SECTION III: DIVERSITY DATA
1. What is the demographic composition of the firm’s workforce and management, as reported on the most recent EEO-1 Report?2
RACE AND ETHNICITY
GENDER

TOTAL

Men

Women

Not Hispanic or Latino

Hispanic or
Latino

White

Black or
African
American

Native
Hawaiian
or Other
Pacific
Islander

Asian

American
Indian or
Alaska
Native

Two or
More
Races

All Employees

Executive/Senior
Level Officials
and Managers
First/Mid-Level
Officials and
Managers

2

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Section III of the Diversity Assessment Report requests workforce demographic data using the same categories for race and ethnicity that the EEOC adopted for the EEO–1
Report, and are consistent with the minimum standards for maintaining, collecting and presenting data on race and ethnicity prescribed by the Office of Management and
Budget. See Revised Standards for the Classification of Federal Data on Race and Ethnicity, 62 FR 5872 (October 30, 1997).

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2. W
 hat is the demographic composition of the firm’s board of directors or other governing body for the period covered by this
assessment?
RACE AND ETHNICITY
GENDER

TOTAL

Men

Women

Not Hispanic or Latino

Hispanic
or Latino

White

Black or
African
American

Native
Hawaiian
or Other
Pacific
Islander

Asian

American
Indian or
Alaska
Native

Two or
More
Races

Board of Directors
or Other Governing
Body
3. Procurement—Business Diversity
What was the total procurement spend with minority-owned and women-owned businesses for the period covered by this assessment
compared to the total procurement spend with all vendors and suppliers?
Dollar Amount

Percent of Total

Total Spend
Minority-Owned Businesses
Women-Owned Businesses

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