1

Fiscal Year 2021: Annual Report to Congress on the 

Notification and Federal EmployeeAntidiscrimination 

and Retaliation Act of 2002

Office of the Chief Executive Officer, Equal Employment 

Opportunity Program

March 2022
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Table of Contents

I. Executive Summary ............................................................................................................. 3

II. Introduction ........................................................................................................................ 4

III. Background........................................................................................................................4

IV. Data ................................................................................................................................... 5

A. Civil Cases..........................................................................................................................5

B. Reimbursement to the Judgment Fund ......................................................................... 6

C. Types of Disciplinary Actions ......................................................................................... 6

D. Final Year-End Data .........................................................................................................6

E. Policy Description on Disciplinary Actions ......................................................................7

F. No FEAR Training ............................................................................................................. 7

V. Analysis of Trends, Causal Analysis, and Practical Knowledge Gained Through

Experience ......................................................................................................................... 8

VI. Adjustment to Budget......................................................................................................8

VII. Actions Planned or Taken to Improve Civil Rights Programs .......................................9

VIII. Accomplishments............................................................................................................9

APPENDIX
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I. EXECUTIVE SUMMARY

The US International Development Finance Corporation, DFC, is a federal agency who partners 

with the private sector to finance solutions to the most critical challenges facing the developing 

world today. The DFC is headquartered in Washington, DC, and has a few satellite offices located 

throughout the world.

The DFC invests across sectors including energy, healthcare, critical infrastructure, and 

technology. DFC also provides financing for small businesses and women entrepreneurs in order 

to create jobs in emerging markets. DFC investments adhere to high standards and respect the 

environment, human rights, and worker rights.

DFC makes America a stronger and more competitive leader on the global development stage 

with greater ability to partner with allies on transformative projects. Further, we provide the 

developing world with financially sound alternatives to unsustainable and irresponsible statedirected initiatives. Our priorities are empowering women through our 2X women’s initiative, 

confronting climate change, responding to Covid-19, and bolstering connectivity.

This Annual Report to Congress, which covers fiscal year (FY) 2021, is required by Title II, Section 

203 of the Notification and Federal Employee Antidiscrimination and Retaliation Act of 2002 (“No 

FEAR Act” or “Act”), Public Law 107-174. The No Fear Act aims to reduce the incidents of 

workplace discrimination within the federal government by holding agencies and departments 

accountable for violations of anti- discrimination and whistleblower protection laws and requires 

an annual report.

DFC reports on the number of cases that were filed in Federal District court which resulted in 

judgments, awards or compromise settlements; the disposition of those cases; money required 

to be reimbursed; and the number of employees disciplined for discrimination, retaliation, 

harassment, or other infractions of a proviso of law cited in Section 201 (c) of the No FEAR Act.

The Office of Equal Employment Opportunity (OEEO) provides technical and policy advice to DFC 

leadership on civil rights and civil liberties issues. The OEEO ensures our agency’s compliance with

the statutes, regulations, and executive orderswhich prohibit discrimination in the workplace. Its 

mission is to ensure an inclusive workplace free from unlawful discrimination through active 

engagement, training, and enforcement of civil rights laws, regulations and other guiding 

sources. OEEO is responsible for the day-to-day operations of EEO program for employees, 

including processing EEO complaints. OEEO is also responsible for diversity programming, special 

observances, and oversight of the employee resource groups.

DFC continues to be diligent in its efforts toward achieving a model EEO program and a robust 

program which fosters diversity, equity, and inclusion. DFC has a relatively low rate of formal 

complaints. We expectthis trend to continue due to an ongoing effort by OEEO to actively seek
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resolution during the initial intake and/or the informal counseling process.

During FY 2021, DFC was not a party to any Federal District Court case that resulted in 

judgements, awards, or compromise settlements. As a result, DFC was not required to reimburse 

the Judgement Fund during FY 2021. No DFC employees were disciplined for discrimination,

retaliation, harassment, or other infractions of a provision of law cited in the NO FEAR Act 

stemming from Federal District Court actions.

There was one formal Equal Employment Opportunity (EEO) complaint filed against DFC during 

FY 2021. The complaint was filed under Title VII of the Civil Rights Act of 1964(42 U.S.C. 2000 e et 

seq.). To date, the case filed in FY 2021 have not resulted in any findings of discrimination by 

either DFC or the Equal Employment Opportunity Commission (EEOC).

II. INTRODUCTION

The No FEAR Act requires Federal agencies to submit annual report to the Speaker of the House 

of Representatives, the President pro tempore of the Senate, the Committee on Governmental 

Affairs of the Senate, the Committee on Government Reform of the House of Representatives, 

each committee of Congress with jurisdiction relating to the agency, the Attorney General, and 

the Equal Employment Commission (EEOC). Additionally, the U.S. Office of Personnel 

Management’s final regulation on the No Fear Act issued on December 28, 2006, requires that 

the Office of Personnel Management receive a copy of the report. This report is submitted by 

DFC to satisfy these reporting requirements.

III. BACKGROUND

The No FEAR Act was signed into law by President George W. Bush on May 15, 2002 and became 

effective on October 1, 2003. The Act requires federal agencies to be accountable for violations 

of anti-discrimination and whistleblower protection laws and to post certain statistical data 

relating to Federal sector EEO complaints filed with the agency.

Section 203 of the No FEAR Act requires that each Federal agency submit an annual report to 

Congress not later than one-hundred eight (180) days after the end of each fiscal year. Agencies 

must report on the number of Federal District Court cases arising under each of the respective 

areas of law specified in the Act in which discrimination was alleged; the status or disposition of 

cases; the amount of money required to be reimbursed; the number of employees disciplined; 

any policies implemented related to appropriate disciplinary actions against the Federal 

employee who discriminated against any individual or committed a prohibited personnel 

practice; and an analysis of the data collected with respect to trends, casual analysis, etc.

The President delegated responsibility to the Office of Personnel Management (OPM) for the 

issuance of regulations governing implementation of Title II of the No FEAR Act. The OPM 

published final regulations on May 10, 2006, concerning the reimbursement provisions of the 

Act; final regulations to carry out the notification and training.
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IV. FY 2021 COMPLAINT DATA

A. Civil Cases

Section 203 (1) of the No FEAR Act requires that agencies include in their annual Report to 

Congress “the number of cases arising under each of the respective provisions of law covered by 

paragraphs (1) and (2) of section 201 (a) in which discrimination on the part of such agency was 

alleged.” Section 724.302 of OPM’s final regulations issued on December 28, 2006, clarifies 

section 203 (1) of the No FEAR Act, stating that Federal agencies report on “the number of cases 

in Federal Court pending or resolved arising under each of the respective provisions of the 

Federal Anti-discrimination laws and whistleblower Protection laws applicable to them in which 

an employee, former Federal employee, or applicant alleged a violation (s) of these laws, 

separating data by the provision(s) of law involved.”

DFC reports that during FY 2021, there were no Federal District Court discrimination 

cases resulting in payment from the Judgment Fund on behalf of the DFC.

B. Reimbursement to the Judgment Fund

OPM published final regulations in the Federal Register on January 22, 2004, and final on May 10, 

2006, to clarify the agency reimbursement provisions of Title II of the No FEAR Act. These 

regulations state, among other things, that the Financial Management Service, U.S. Department 

of the Treasury (FMS), will provide notice to an agency’s Chief Financial Officer within 15 business 

days after payment from the Judgment Fund. The agency is required to reimburse the Judgment

Fund within 45 business days after receiving notice from FMS or must contact FMS to make 

arrangements, in writing, for reimbursement.

The Treasury Judgment Fund paid no monies on behalf of DFC for discrimination 

cases filed in Federal District Court resulting in judgments, awards, or compromise 

settlements during FY 2021.

C. Types of Disciplinary Actions

Section 203 (a) (4) of the No FEAR Act requires that agencies include in the Annual Report to 

Congress “the number of employees disciplined for discrimination, retaliation, harassment, or 

any other infraction of any provision of law referred to in paragraph (1).” Section 203 (a) (1) 

requires that agencies report “the number of cases arising under each of the respective 

provisions of law covered by paragraphs (1) and (2) of section 201 (a) in which discrimination on 

the part of such agency was alleged.” OPM’s final regulation issued December 28, 2006, provides 

that these cases refer to the number of discrimination cases for which the Judgment Fund paid 

on behalf of the agency. The regulations also define disciplinary actions to include any one or a 

combination of the following actions: reprimand, suspension without pay, reduction in grade or 

pay, or removal.
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DFC reports that there were no disciplinary actions arising from any Federal District 

Court discrimination cases in FY2021.

D. Final Year-End Data

The final year-end data posted pursuant to Section 301 (c) (1) (B) ofthe No FEAR Act are include 

in Appendix A.

The final year-end data indicates that during FY 2021, there was one new 

complaint of discrimination. There have been no findings of discrimination to date, 

as the case is still in the EEO process. The case alleged the bases of sex, race, and 

reprisal. The average complaint processing time (investigation) at the end of FY 

2021 was 90 days.

E. Policy Description on Disciplinary Actions

Section 203 (a) (6) of the No FEAR Act requires that agencies include in their annual Report to 

Congress a detailed description of the policy implemented by the agency relating to disciplinary 

actions imposed against a Federal employee who discriminated against any individual in violation 

of any of the laws cited under section 201 (a) (1) or (2), or committed another prohibited 

personnel practice that was revealed in the investigation of a complaint alleging a violation of 

any of the laws cited under section 201 (a) (1) or (2). Further, the Act requires that, with respect 

to each such law, the Federal agency report on the number of employees who were disciplined

in accordance with such policy and the specific nature of the disciplinary action taken.

The CEO annually issues primary policy statements that reinforce DFC commitment 

to a workplace free from discrimination, harassment, and retaliation. DFC 

employees are accountable for their actions in accordance with these policy

statements. The policy statements are the Equal Employment Opportunity Policy 

and the Non-Harassment Policy. The first statement emphasizes DFC

determination to subject employees to appropriate disciplinary action for 

engaging in unlawful discriminatory practices or allowing discriminatory practices 

to exist. The second statement communicates DFC zero tolerance of harassment 

against employees on the bases of race, color, national origin, gender, age, 

religion, sex, disability, gender identity or expression, sexual orientation, political 

affiliation, marital or parental status, or engaging in protected activity. Both

statements warn that engaging in prohibited behavior will result in appropriate 

disciplinary action.

These annual policy statements are buttressed by the DFC anti- harassment policy 

and procedure which provides for prompt investigation of claims of harassment 

outside of the EEO complaints process.
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F. No FEAR Act Training

Section 202 (c) of the No FEAR Act requires Federal agencies to provide training to their 

employees on the rights and remedies under Federal Anti-discrimination laws and Whistleblower 

Protection laws. Under Section 724.203, Federal agencies were required to develop a written

training plan and to have trained their employees by December 17, 2006, and every two years 

thereafter. Under implementing regulations, new employees are to receive No FEAR Act training 

within 90 days of appointment, which can be met through an agency orientation or training 

program.

DFC has an established EEO training plan. New hires are given a brief introduction 

to civils rights protections and the EEO process as a part of new employee 

orientation. New staff must complete more extensive EEO training within 90 days 

of onboarding, including the No FEAR Act course. All employees must take EEO 

training courses each year.

FedTalent is our electronic learning management system, powered by Skillsoft, and 

is available to all DFC employees. Employee EEO courses are tracked through this 

system and enables DFC to ensure the completion of required courses, including No 

FEAR Act training. DFC provides an annual training day for employees to focus on 

completing mandatory courses. Supervisors and managers are discouraged from 

holding meetings or scheduling project deadlines on this day, so that employees 

can focus on completing mandatory training.

V. ANALYSIS OF TRENDS, CAUSAL ANALYSIS AND PRACTICAL KNOWLEDGE 

GAINED THROUGH EXPERIENCE

Section 203 (7) of the No FEAR Act requires that agencies undertake “an examination of trends, 

causal analysis, and practical knowledge gained through experience and any actions planned or 

taken to improve complain or civil rights programs of DFC.”

There were no Federal District Court cases resulting in judgments, awards or 

compromise settlements filed against DFC in FY 2021. This statistic illustratesDFC 

ongoing commitment to maintaining a diverse and inclusive workforce as well as 

a model EEO environment.

This is the first No FEAR Act report for the DFC, previously the Overseas Private 

Investment Corporation (OPIC), therefore there is no previous information to 

examine to identify trends. While this the first report for DFC, however, there is 

limited available data for OPIC. When comparing the DFC to other similar-sized 

federal agencies, the DFC is on par with the government-wide measure of 

complaint activity of 1.2%; 0.1% below the complaint activity reported for Small
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Level Agencies (1.3%); and 0.2% Micro Level Agencies (1.4%). (Source: FY 2019 

EEOC Federal Sector Report, Table B-1 FY 2019 Total Work Force, Counselings, and 

Complaints).

V. ADJUSTMENT TO BUDGET

Section 203 (a) (8) of the No FEAR Act requires that agencies include in their annual report to 

Congress information about “any adjustment (to the extent the adjustment can be ascertained 

in the budget of the agency) to comply with the requirements under section 201.”

DFC did not make such an adjustment in FY 2021.

VI. DFC ACTIONS PLANNED/TAKEN TO IMPROVE CIVIL RIGHTS PROGRAMS

DFC continually seeks to improve its ability to prevent and address discrimination. This includes 

offering training for staff, senior level management, and improving the agency’s EEO policies and 

procedures. Managers and supervisors are instructed to take the anti-discrimination laws 

seriously and are held accountable for their actions or inactions in accordance with established 

disciplinary policies.

DFC also includes performance measures for EEO compliance in manager evaluations. They 

include: (1) supports agency workforce diversity and equal employment policies and programs; 

fosters an inclusive workplace where diversity and individual differences are valued and 

leveraged to achieve the mission of the organization and (2) promotes respectful, cooperative, 

and productive working relationships among culturally diverse employees; establishes an 

effective work/life balance.

DFC will continue to encourage a healthy, diverse, inclusive, and equitable environment by 

focusing on employee engagement, retention, corporate culture, mentoring, and management 

skills training. Annual training for all employees includes unconscious bias and conflict resolution. 

DFC continued use of varied alternate dispute resolution methods will continue to address 

workplace conflicts in a way which results in a substantial resolution rate during the early stages 

of engagement.

DFC executive team is committed to transparent communication of impending changes to all 

employees, seeking input from those whose work will be affected. DFC leadership acknowledges 

that major changes and growth in the workplace tends to trigger more complaints. Our 

leadership anticipates such growth this fiscal year as we implement the requirements of the Build 

Back Better Plan in the coming months. Our leadership has invited all employees to share in the 

decision-making process, as appropriate, and has engaged in candid communication regarding 

potential change in workloads and responsibilities.
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VII. ACCOMPLISHMENTS.

Building a robust culture of diversity, equity, and inclusion in our workplace and in our larger 

national service enterprise is a top agency priority in FY2021, led by the Office of the Chief 

Executive Officer in partnership with the Office of Human Resource Management, and OEEO.

Prior to mid FY 2021, the EEO program was administered through a personal services contract. 

To build a model EEO program, the DFC appointed a full-time position to the position of Director, 

Office of Equal Employment Opportunity (OEEO) in May 2021. This is a first for the DFC and 

demonstrates its commitment to integrating EEO into the Strategic Mission. The Director, OEEO 

is managed by an experienced EEO official and reports directly to the CEO.

DFC will continue to work on becoming a model EEO program by correcting any deficiencies 

noted in the 2021 MD-715, Part G report. Our reasonable accommodation and personal 

assistance services policies and procedures were approved by the Equal Employment 

Opportunity Commission. We also updated our Equal Employment Opportunity and nonharassment policies and procedures to provide more clarity regarding prohibited conduct, and 

the investigation process for harassment complaints.

Respectfully submitted,

Scott Nathan

Chief Executive Officer 

March 30, 2022
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APPENDIX

APPENDIX A: No FEAR Act 2021 Fiscal Year Complaint Totals 

APPENDIX B: Equal Employment Opportunity Policy 

APPENDIX C: Non-Harassment Policy
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US International Development Finance Corporation 

Equal Employment Opportunity Data

Posted Pursuant to Title III of the Notification and Federal Employee Antidiscrimination and Retaliation Act of

2002 (No Fear Act), Pub. L. 107-174

Informal Complaint Activity

Informal Complaint Activity

Comparative Data 

Fiscal Year Data

2021

Qtr 1 

2021

Qtr 2 

2021

Qtr 3 

2021

Qtr 4 

2021

Total

Number of Complaints Filed 0 1 2 2 5

Number of Complainants 0 1 2 2 5

Repeat Filers 0 0 0 0 0

Informal Complaints by Basis

Note: Complaints can be filed alleging multiple bases. 

The sum of the bases may not equal total complaints 

filed.

Comparative Data 

Fiscal Year Data

2021

Qtr 1 

2021

Qtr 2 

2021

Qtr 3 

2021

Qtr 4 

2021

Total

Race 0 1 1 2 4

Color 0 0 0 0 0

Religion 0 0 0 0 0

Reprisal 0 1 0 0 1

Sex (Male) 0 0 1 0 1

Sex (Female) 0 1 0 2 3

National Origin 0 0 0 0 0

Equal Pay Act 0 0 0 0 0

Age 0 0 0 1 1

Disability 0 0 1 0 1

Genetic Information 0 0 0 0 0

Non-EEO basis 0 0 0 0 0

Complaints by Issue

Note: Complaints can be filed alleging multiple 

issues. The sum of the issues may not equal total

complaints filed. 

Comparative Data 

Fiscal Year Data

2021

Qtr 1 

2021

Qtr 2 

2021

Qtr 3 

2021

Qtr 4 

2021

Total

Appointment/Hire 0 0 0 1 1

Assignment of Duties 0 0 0 0 0

Awards 0 0 0 0 0

Conversion to Full-time 0 0 0 0 0

Disc ip lin ar y Action

Demotion 0 0 0 0 0
2

Reprimand 0 1 0 0 1

Removal 0 0 0 0 0

Suspension 0 0 0 0 0

Other 0 0 0 0 0

Duty Hours 0 1 0 0 1

Evaluation Appraisal 0 0 0 0 0

Examination/Test 0 0 0 0 0

Harassment

Non-Sexual 0 1 0 2 3

Sexual 0 0 0 0 0

Medical Examination 0 0 0 0 0

Pay (Including Overtime) 0 0 0 0 0

Promot io n /N on -S ele ctio n 0 0 0 0 0

Reassignment

Denied 0 0 0 0 0

Directed 0 0 1 0 1

Reasonable Accommo da tio n (Disabilit y) 0 0 0 0 0

Reinstatement 0 0 0 0

0

Retirement 0 0 0 0 0

Termination 0 0 1 0 1

Terms/Conditions of Employment 0 0 0 0 0

Time and Attendance 0 0 0 0

0

Training 0 0 0 0 0

Religious Accommodation 0 0 0 0 0

Other 0 0 0 0

0

Formal Complaint Activity

Formal Complaint Activity

Comparative Data 

Fiscal Year Data

2021

Qtr 1 

2021

Qtr 2 

2021

Qtr 3 

2021

Qtr 4 

2021

Total

Number of Complaints Filed 0 1 0 0 1

Number of Complainants 0 1 0 0 1

Repeat Filers 0 0 0 0 0

Formal Complaints by Basis

Note: Complaints can be filed alleging multiple bases. 

The sum of the bases may not equal total complaints 

filed.

Comparative Data 

Fiscal Year Data

2021

Qtr 1 

2021

Qtr 2 

2021

Qtr 3 

2021

Qtr 4 

2021

Total
3

Race 0 1 0 0 1

Color 0 0 0 0 0

Religion 0 0 0 0 0

Reprisal 0 1 0 0 1

Sex (Male) 0 0 0 0 0

Sex (Female) 0 1 0 0 1

National Origin 0 0 0 0 0

Equal Pay Act 0 0 0 0 0

Age 0 0 0 0 0

Disability 0 0 0 0 0

Genetic Information 0 0 0 0 0

Non-EEO basis 0 0 0 0 0

Formal Complaints by Issue

Note: Complaints can be filed alleging multiple 

issues. The sum of the issues may not equal total 

complaints filed.

Comparative Data 

Fiscal Year Data

2021

Qtr 1

2021

Qtr 2

2021

Qtr 3

2021

Qtr 4

2021

Total

Appointment/Hire 0 0 0 0

0

Assignment of Duties 0 0 0 0

0

Awards 0 0 0 0

0

Conversion to Full-time 0 0 0 0

0

Disc ip lin ar y Action

Demotion 0 0 0 0 0

Reprimand 0 1 0 0 1

Removal 0 0 0 0

0

Suspension 0 0 0 0 0

Other 0 0 0 0

0

Duty Hours 0 1 0 0 1

Evaluation Appraisal 0 0 0 0

0

Examination/Test 0 0 0 0 0

Harassment

Non-Sexual 0 1 0 0 1

Sexual 0 0 0 0

0

Medical Examination 0 0 0 0 0

Pay (Including Overtime) 0 0 0 0 0

Promot io n /N on -S ele ctio n 0 0 0 0 0

Reassignment

Denied 0 0 0 0 0
4

Directed 0 0 0 0 0

Reasonable Accommo da tio n (Disabilit y) 0 0 0 0 0

Reinstatement 0 0 0 0 0

Retirement 0 0 0 0 0

Termination 0 0 0 0 0

Terms/Conditions of Employment 0 0 0 0 0

Time and Attendance 0 0 0 0 0

Training 0 0 0 0 0

Religious Accommodation 0 0 0 0 0

Other 0 0 0 0 0

Processing Time

Comparative Data 

Fiscal Year Data

2021

Qtr 1 

2021

Qtr 2 

2021

Qtr 3 

2021

Qtr 4 

2021

Total

Complaints pending for any length of time during 

fiscal year

Average number of days in investigation stage 0 90 0 0 90

Average number of days in final agency action 

stage 0 0 0 0 0

Complaints pending for any length of time during 

fiscal year where hearing was requested

Average number of days in investigation stage 0 0 0 0 0

Average number of days in final agency action 0 0 0 0 0

Complaints pending for any length of time during 

fiscal year where hearing was not requested

Average number of days in investigation stage 0 0 0 0 0

Average number of days in final agency action 

stage

0 0 0 0 0

Complaints Dismissed by Agency

Comparative Data 

Fiscal Year Data

2021

Qtr 1 

2021

Qtr 2 

2021

Qtr 3 

2021

Qtr 4 

2021

Total

Total Complaints Dismissed by Agency 0 0 0 0 0

Average days pending prior to dismissal 0 0 0 0 0

Complaints Withdrawn by Complainants

Total Complaints Withdrawn by Complainants 0 1 0 0 1
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Total Final Actions Finding Discrimination

Comparative Data 

Fiscal Year Data

2021

Qtr 1

2021

Qtr 2

2021

Qtr 3

2021

Qtr 4

2021

Total

# % # % # % # % # %

Total Number of Findings 0 0 0 0 0 0 0 0 0 0

Without Hearing 0 0 0 0 0 0 0 0 0 0

With Hearing 0 0 0 0 0 0 0 0 0 0

Findings of Discrimination Rendered by Basis 

Note: Complaints can be filed alleging multiple bases. 

The sum of the bases may not equal total complaints 

and findings.

Comparative Data 

Fiscal Year Data

2021

Qtr 1

2021

Qtr 2

2021

Qtr 3

2021

Qtr 4

2021

Total

# % # % # % # % # %

Total Number of Findings 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Race 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Color 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Religion 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Reprisal 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Sex 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

National Origin 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Age 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Disability 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Genetic Information 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Non-EEO 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Findings After Hearing 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Race 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Color 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Religion 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Reprisal 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Sex 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0
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National Origin 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Equal Pay Act 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Age 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Disability 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Genetic Information 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Non-EEO 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Findings Without Hearing 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Race 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Color 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Religion 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Reprisal 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Sex 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

National Origin 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Equal Pay Act 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Age 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Disability 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Genetic Information 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Non-EEO 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Findings of Discrimination Rendered by Issue

Note: Complaints can be filed alleging multiple issues. 

The sum of the issues may not equal total complaints 

and findings.

Comparative Data 

Fiscal Year Data

2021

Qtr 1

2021

Qtr 2

2021

Qtr 3

2021

Qtr 4

2021

Total

# % # % # % # % # %

Total Number of Findings 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Appointment/Hire 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Assignment of Duties 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Awards 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Conversion to Full-time 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Disc ip lin ar y Action

Demotion 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Reprimand 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Suspension 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Removal 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Other 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Duty Hours 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Evaluation Appraisal 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Examination/Test 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0
7

Harassment

Non-Sexual 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Sexual 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Medical Examination 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Pay (Including Overtime) 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Promot io n /N on -S ele ctio n 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Reassignment

Denied 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Directed 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Reasonable Accommo da tio n (Disabilit y) 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Reinstatement 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Retirement 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Termination 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Terms/Conditions of Employment 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Time and Attendance 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Training 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Religious Accommodation 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Other 0 0.0 0 0.0 0 0.0 0 0.0 0 0.0

Pending Complaints Filed in Previous Fiscal 

Years by Status

Comparative Data 

Fiscal Year Data

2021

Qtr 1

2021

Qtr 2

2021

Qtr 3

2021

Qtr 4

2021

Total

Total Complaints from Previous Fiscal Years 0 0 0 0 0

Total Complainants 0 0 0 0 0

Number of Complaints Pending

Investigation

0 0 0 0 0

Hearing 0 0 0 0 0

Final Agency Action 0 0 0 0 0

Appeal with EEOC Office of Federal Operations 0 0 0 0 0

Complaint Investigations

Comparative Data 

Fiscal Year Data

2021

Qtr 1

2021

Qtr 2

2021

Qtr 3

2021

Qtr 4

2021

Total

Pending Completion Where Investigation Exceeds 

Required Time Frames 0 0 0 0 0
1100 New York Avenue,NW 

Washington, DC 20527

Office +1 202.336.8400

dfc.gov

MEMORANDUM

TO: DFC Staff

FROM: Dev Jagadesan, ActingChief Executive Officer 

DATE:

RE: DFC EEO Policy Statement

The U.S. InternationalDevelopment FinanceCorporation (DFC) is committed to a workplace free 

of discrimination. As the Acting Chief Executive Officer, I am proud to reaffirm DFC’s 

commitment to the principles of equal employmentopportunity (EEO)in the workplace. I ask that 

all DFC employees, including managers and staff, take responsibility forreporting and addressing 

discriminatory conduct and preventing all types of discrimination, including workplace 

harassment. DFC cannot and will not tolerate discrimination based on race; color; religion; sex, 

(including pregnancy, sex stereotyping, gender identity, gender expression or transgender status); 

national origin; sexual orientation; physical or mental disability; age (40 or older); protected 

genetic information; status as a parent; marital status; political affiliation; or retaliation based on 

previous EEO activity. In addition, DFC will not tolerate any type of harassment – either sexual 

or nonsexual – of any employee or applicant for employment. Employment decisions must be 

made in accordance with Federal civil service merit system principles.

Our DFC management team is expected to continue to providefirst-class leadership in supporting 

the Agency’sEEO program by takingstepsto promote EEOin all facets of employment, including 

recruitment, hiring, promotion, performance assessment, awards or career-development 

opportunities.

Any former/current employee or applicant for employment who believes that they have been 

subjected to discrimination and elects to seek redress for discrimination must initiate the EEO 

complaintprocesswithin 45-calendar daysof the alleged discriminatory eventorthe effective date 

of a personnel action. To file an EEO complaint, please contact DFC’s Office of Equal 

Employment Opportunity at eeo@dfc.gov or by calling (202) 977-5062.

In addition, an employee or applicant for employment who believes he or she was subjected to 

workplace harassment should also review DFC’s procedures for addressing allegations of 

workplace harassment for information on how to report allegations of workplace harassment 

outside the EEO process.

A workplace free of discrimination protects DFC employees and allows them to focus on the 

Agency’s mission. I appreciate your shared commitment to equal employment opportunity at the 

DFC, and I look forward to working with you to advance the Agency’s all-important mission.

Dev Jagadesan
1100 New York Avenue,NW 

Washington, DC 20527

Office +1 202.336.8400

dfc.gov

MEMORANDUM

TO: DFC Staff

FROM: Dev Jagadesan, ActingChief Executive Officer 

DATE:

RE: Maintaining a Non-Hostile Workplace Free of Discriminatory Harassment

This is to affirm DFC's responsibility to maintain a workplace free from harassment (including 

sexual harassment which is a form of discrimination based on sex) and retaliation, and to ensure 

that all employees are aware of my personal commitment to this goal.

The U.S. Equal Employment Opportunity Commission (EEOC) requires agencies to remove 

every form of prejudice or discrimination from personnel policies, practices, and work conditions 

(29 C.F.R. §1614.102(a)(3)). A hostile work environment is one that allows ridicule, abuse, 

insults, or derogatory comments that are directly or indirectly based on race; color; religion; sex, 

(including pregnancy,sex stereotyping, gender identity, gender expression or transgender status); 

national origin; sexual orientation; physical or mental disability; age (40 or older); protected 

genetic information; status as a parent; marital status; or political affiliation. A hostile work 

environment also can be created by reprisal or retaliation for exercising rights under these 

criteria. It is further defined as an offensive or intimidating environment that unreasonably 

interferes with work performance or that otherwise adversely affects employment opportunities. 

Personal conversations that can be overheard by other employees who consider the conversations 

offensive also can create a hostile environment.

DFC follows guidance established by EEOC and standardsset by the U.S. SupremeCourt in two 

landmark decisions: Burlington Industries, Inc. v. Ellerth, 524 U.S. 742 (1998) and Faragher v. 

City of Boca Raton, 524 U.S. 775 (1998). In these decisions, the Supreme Court made clear that 

employers are subject to vicarious liability for unlawful harassment by supervisors. Liability is 

premised on two principles:

1) an employer isresponsible for the acts of itssupervisors; and

2) employers should be encouraged to prevent harassment and employees should be 

encouraged to avoid or limit the harm from harassment.

Managers and supervisors are responsible for maintaining a non-hostile work environment, one 

that is free from discriminatory harassment (both sexual and non-sexual). They can be held 

accountable for their own behavior and that of their employees. If an employee makes abusive or 

derogatory comments to another employee and the matter comes to a manager's or supervisor's 

attention, the manager or supervisor must take prompt action. It is very important to demonstrate 

to concerned employees that their allegations are taken seriously, and that management will not
1100 New York Avenue,NW 

Washington, DC 20527

Office +1 202.336.8400

dfc.gov

condone offensive behavior. For additional guidance, managers and supervisors should contact 

the Office of Human Resources Management (HRM).

Further, when an employee complains to management about alleged harassment, management is 

obligated to investigate the allegation regardless of whether the employee's complaint conforms 

to a particular format or is not made in writing. Disciplinary or other remedial actions should 

reflect management's findings during the course of the inquiry.

Employees are responsible for reporting any behavior they view as harassment before it becomes 

severe or pervasive, by speaking to:

1) their immediate supervisor or, if the alleged harassment is at thislevel, to a second or 

third level supervisor;

2) HRM; or

3) the Director, Office ofEqualEmploymentOpportunity (EEO).

While isolated incidents of harassment generally do not violate federal law, a pattern of incidents 

may be unlawful. Employees also are responsible for taking advantage of any preventive or 

corrective opportunities provided by DFC or to otherwise avoid harm. To the extent possible, the 

confidentiality of employees bringing harassment claims will be protected.

Employees who raise claims of harassment or provide information related to such claims are 

legally entitled to be free from retaliation. Retaliation is a form of discrimination where an 

employee is subjected to an adverse employment action or harassment that creates a hostile or 

abusive work environment solely because the employee opposed an unlawful employment 

practice. "Opposing" an unlawful employment practice includes filing a charge of discrimination, 

participating in an investigation, proceeding or hearing, or taking other, similar action in 

opposition to the unlawful practice.

Unwelcome sexual advances,requests for sexual favors, and other verbal or physical conduct of 

a sexual nature constitute sexual harassment when:

1) Submission to such conduct is made either explicitly or implicitly a term or condition of 

an individual's employment;

2) Submission to or rejection of such conduct by an individual is used as the basis for 

employment decisions affecting such individual; or

3) Such conduct has the purpose or effect of unreasonably interfering with an individual's 

work performance or creating an intimidating, hostile, or offensive working environment.

Whether such conduct is intimidating, hostile, or offensive is determined by both objective and 

subjective factors, including the perception of the recipient, witnesses, or others affected by the
1100 New York Avenue,NW 

Washington, DC 20527

Office +1 202.336.8400

dfc.gov

conduct. The person who initiates the conduct, i.e., the alleged harasser, does not ultimately 

determine whether such conduct constitutes sexual harassment.

In Meritor Savings Bank v Vinson, 477 U.S. 57 (1986), the U.S. Supreme Court has ruled that 

sexual harassment is proven if the offensive conduct is based on the employee’s sex, is 

unwelcome, and is sufficiently severe or pervasive to interfere with the employee's job 

performance or to create an abusive work environment. EEOC has stated that a complaint may 

be filed by anyone offended by such conduct, even if the employee is not the person at whom it 

is directed.

Offended individuals are encouraged to initiate actions to resolve harassment issues at the 

earliest possible stage. When the situation permits, the offended individual should inform the 

offending individual that their conduct is considered intimidating, hostile, or unwelcome. The

immediate supervisor will often bethe first level of resolution for harassment issues. However, 

employees also may directly contact HRM. Supervisors shall inform HRM whenever they 

become aware of any situation that could have harassment implications.

In some situations, DFC will conduct an investigation in order to determine if an employee or 

anyone else has engaged in inappropriate conduct or illegal harassment. DFC will initiate any 

such investigation within ten (10) days of the report of inappropriate conduct or illegal activity. 

DFC is also committed to conclude any investigation as quickly as possible, taking into account 

the complexity of the facts, the number of witnesses, and the issues arising out of the 

investigation. DFC will keep complaining witnesses informed of the status of the investigation, 

recognizing that some information may not be disclosed if the disclosure would violate the 

privacy rights of someone else.

When an individual feels that it is necessary to consider filing an EEO complaint, the individual 

should contact an EEO Counselor or the EEO Director within forty-five (45) calendar days of the 

alleged inappropriate conduct or illegal harassment at eeo@dfc.gov or (202) 977-5062. The 

complaint will be processed in accordance with 29 C.F.R., Part 1614. If an EEO complaint is to 

be pursued, the individual will then work with an EEO Counselor to try to resolve the matter 

prior to filing a formal EEO complaint.

It is DFC's intention to discourage harassment (including sexual harassment) and retaliation from 

occurring and, if it does occur, to take firm and immediate action.

Dev Jagadesan