DFC-OHRM-001-007

Anti-Harassment Policy

Version: 1.0.0

Type of Document: Policy

Corresponding 

Documents:

See references / attachments within this document

Date of Approval: August 2, 2022

Effective Date: August 2, 2022

Date Last Updated: TBD

Point of Contact: U.S. International Development Finance Corporation (DFC)

Office of Human Resources Management (OHRM),

Workforce Relations & Benefits (WRB)
Anti-Harassment Policy Page 2 of 17 v.1.0.0, 08/02/2022

TABLE OF CONTENTS

1. PURPOSE AND COVERAGE .................................................................................. 3

2. DEFINITIONS........................................................................................................... 3

3. ROLES AND RESPONSIBILITIES ........................................................................... 5

4. POLICY .................................................................................................................... 7

4.1 PROHIBITED HARASSING CONDUCT........................................................... 8

4.2 REPORTING PROCEDURES AND REQUIREMENTS ..................................... 8

4.3 CONSEQUENCES OF HARASSING CONDUCT.............................................. 9

4.4 RETALIATION.................................................................................................... 9

4.5 INITIAL RESPONSE TO REPORTS OF HARASSMENT ................................ 10

4.6 INVESTIGATION AND FINDINGS................................................................... 12

4.7 CORRECTIVE ACTION ................................................................................... 13

5. RECORDS MANAGEMENT AND CONFIDENTIALITY.......................................... 14

5.1 MAINTAINING CONFIDENTIALITY................................................................. 14

5.2 TRACKING ALLEGATIONS OF HARASSING CONDUCT.............................. 14

6. MISCELLANEOUS ................................................................................................. 15

6.1 DISTINCTION FROM GRIEVANCES AND STATUTORY CLAIMS................. 15

6.2 ADDITIONAL RESOURCES............................................................................ 16

6.3 INQUIRIES....................................................................................................... 16

7. REFERENCES ....................................................................................................... 16

APPENDIX A: VERSION CONTROL AND APPROVAL .............................................. 17
Anti-Harassment Policy Page 3 of 17 v.1.0.0, 08/02/2022

1. PURPOSE AND COVERAGE

This policy creates the DFC’s program on providing a work environment free from

harassment by (1) defining unacceptable conduct that violates this policy; (2)

outlining the rights and responsibilities of employees, supervisors, and managers;

(3) establishing reporting procedures and accountability measures; and (4)

establishing the Anti-Harassment Program Team (AHPT). These procedures ensure

that appropriate officials are notified of, and have the opportunity to promptly correct,

harassing conduct.

This policy applies to all employees within all offices of the DFC and supersedes any 

other DFC policy or procedures that conflict with this policy. DFC is committed to 

taking all necessary actions, within its authority, to provide a work environment free 

of harassment. 

This policy is not intended to, and does not create any right or benefit, substantive or 

procedural, enforceable by law or equity by a party against the United States, 

agencies, instrumentalities or entities, its officers or employees, or any other person.

2. DEFINITIONS

• Anti-Harassment Program Team. The Vice President, Office of Human

Resources Management (VP OHRM) and Chief Human Capital Officer (CHCO)

determines the members of the AHPT. The Team is normally comprised of officials

from the Workforce Relations and Benefits, and the Office of General Counsel.

The AHPT provides advice to managers and supervisors on matters relating to

harassment allegations.

• Hostile Work Environment. A pattern of continuing unwelcome behavior that

unreasonably interferes with an employee’s work performance or that creates an

intimidating, hostile, or offensive work environment.

• Prohibited Harassing Conduct. The conduct prohibited by this policy includes

conduct that meets the legal definitions of harassment or sexual harassment, as

well as harassing conduct that violates the dignity and respect of others.

Illegal harassing conduct prohibited by this policy is defined as any unwelcome or

unwanted conduct, verbal or physical, based on an individual’s protected status or

protected activities, that is sufficiently severe or pervasive so as to create a work

environment that a reasonable person would consider intimidating, hostile or

abusive, to include, but not limited to, when:

1. the behavior can reasonably be considered to adversely affect the work

environment; or

2. an employment decision affecting the employee is based upon the

employee’s acceptance or rejection of such conduct.
Anti-Harassment Policy Page 4 of 17 v.1.0.0, 08/02/2022

Other harassing behavior that does not meet the legal definition of illegal 

harassment is also prohibited under this policy. Examples of this include, but are 

not limited to, unwelcome conduct (including of a sexual nature), intimidation, 

ridicule, insult, offensive comments or jokes, bullying, stalking, slurs, epithets, 

negative stereotyping, offensive objects or pictures, threats, unwelcome sexual 

advances, and requests for sexual favors. 

Harassing conduct can occur in person, in writing, or through phone calls or other 

forms of technology or social media.

• Protected Status. Protected Status is based on race, religion, color, sex (with or

without sexual conduct and including pregnancy, sexual orientation, transgender

status/gender identity, and sex-stereotyping), national origin, retaliation, age (40

years or older), disability (mental and/or physical) and/or genetic information. In

addition, all employees and applicants are to be free from harassment without

regard to parental status, marital status and/or political affiliation.

• Responsible Management Official. The Responsible Management Official is the

DFC management official, appointed by the VP OHRM & CHCO in consultation

with the AHPT. The Responsible Management Official, in consultation with the

AHPT, is responsible for overseeing investigations into allegations of harassment,

reviewing reports of investigation, and ensuring immediate and appropriate

discipline or adverse action is taken against individuals who are in violation of this

policy.

• Retaliation/Reprisal. Retaliation/ Reprisal occurs when an employer takes an

adverse action because an applicant or employee asserts rights protected by the

EEO laws, including but limited to: filing or being a witness in an EEO charge,

complaint, investigation, or lawsuit; communicating with a supervisor or manager

about employment discrimination; answering questions during an employer

investigation of alleged harassment; refusing to follow orders that would result in

discrimination; resisting sexual advances, or intervening to protect others

requesting accommodation of a disability or for a religious practice asking

managers or co-workers about salary information to uncover potentially

discriminatory wages.

• Sexual Harassment. A form of harassment that can include unwelcome sexual

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

sexual nature when (a) submission to such conduct is made either explicitly or

implicitly a term or condition of an individual’s employment; (b) submission to or

rejection of such conduct by an individual is used as the basis for employment

decisions affecting such individual; or (c) such conduct has the purpose or effect of

unreasonably interfering with an individual’s work performance or creating an

intimidating, hostile, or offensive work environment.
Anti-Harassment Policy Page 5 of 17 v.1.0.0, 08/02/2022

3. ROLES AND RESPONSIBILITIES

3.1 VICE PRESIDENT, OHRM AND CHIEF HUMAN CAPITAL OFFICER (CHCO)

• Disseminating this policy to all employees on an annual basis and

periodically reminding employees of their responsibilities under this policy.

• Ensuring that performance plans of all supervisors and managers include a

critical element that would rate their performance on taking appropriate

action against employees for misconduct.

• Providing information to the Office of the Chief Executive Officer (CEO) on

allegations of misconduct under this policy and the necessary corrective

action taken, if any.

• Resolving any disagreements involving investigations between

management officials and consulting staff from the Office of Human

Resources Management Offices or the Anti-Harassment Program Team

regarding whether and what type of investigation is necessary.

• Determining the composition of the Anti-Harassment Program Team and

assigning the role of Responsible Management Official in consultation with

the AHPT.

3.2 OFFICE VICE PRESIDENTS 

• Ensuring that supervisors/managers are appropriately rated on the critical

element regarding anti-harassment procedures.

• Ensuring that their subordinate employees are in full compliance with

requirements of this policy.

• Monitoring the work environment following a report alleging a violation of

this policy to ensure that there are no further violations or incidents of

retaliation against any individual who has reported harassment or

participated in the investigation.

3.3 DIRECTOR, OFFICE OF EQUAL EMPLOYMENT OPPORTUNITY

• Reporting allegations of harassing conduct received by the EEO Director to

the AHPT as soon as possible, but no later than one business day after

receipt of the allegations; and

• Advising alleged complainants of their rights under the EEO process.

3.4 SUPERVISORY HR SPECIALIST (DIRECTOR, WORKFORCE RELATIONS 

AND BENEFITS (WRB)) – DIRECTOR WRB

• Developing and providing periodic communications to all DFC employees

on this policy and any DFC-specific requirements and incorporating this

policy into the DFC’s supervisory training curriculum.

• Providing oversight, technical assistance, and support to DFC staff to

ensure compliance with this policy.
Anti-Harassment Policy Page 6 of 17 v.1.0.0, 08/02/2022

• Ensuring that the procedures in this policy are properly executed by

monitoring inquiries and investigations of reported or otherwise discovered

harassing conduct; providing guidance concerning the information to be

gathered and methods to be used during inquiries and investigations; and

otherwise ensuring that the investigations are swift, thorough, impartial, and

appropriate to the allegation.

• Reviewing information on the harassing conduct allegations, and providing

information to the CEO, EEO, and the CHCO as requested.

• Providing the record of actions taken under this policy to any office handling

a parallel statutory or grievance claim.

3.5 HR SPECIALIST (EMPLOYEE AND LABOR RELATIONS (ER/LR)) 

• Receiving reports alleging violations of this policy and notifying and

assisting the relevant management officials in handling allegations of

harassing conduct and taking corrective action, as appropriate and

necessary.

• Documenting reports made and actions taken pursuant to this policy and

reporting on them to the applicable parties.

3.6 ANTI-HARASSMENT PROGRAM TEAM (AHPT)

Provides advice to managers and supervisors on matters relating to 

harassment allegations. The composition of the AHPT is determined by the VP 

OHRM & CHCO and will normally include representatives from the Office of 

Human Resources Management, Workforce Relations and Benefits and the 

Office of General Counsel. The AHPT is responsible for: 

• Ensuring uniform and effective handling of all allegations submitted for

review.

• Informing the appropriate supervisor or manager of allegations reported to

the AHPT.

• Assisting supervisors and managers in determining the veracity of a

complaint.

• Consulting with the Responsible Management Official to assist him or her in

determining investigatory measures and, if needed, appointing a team to

conduct inquiries into allegations of harassment on behalf of the agency;

conducting further informal inquiries itself; and recommending or taking

other appropriate inquiry action. The AHPT does not initiate disciplinary

action(s).

• Advising management regarding unsubstantiated accusations of misconduct

within the scope of this policy.

• Providing data to the Director, Workforce Relations & Benefits for tracking

purposes.

• Reports allegations of harassment by a contract employee to the

appropriate Contracting Official.
Anti-Harassment Policy Page 7 of 17 v.1.0.0, 08/02/2022

3.7 SUPERVISORS AND MANAGERS

• Providing a work environment free of harassment.

• Ensuring that subordinates are aware of this policy and its requirements and

that all training requirements are completed.

• Acting immediately and appropriately to stop known harassing conduct and

hold employees who have engaged in harassing conduct accountable.

• Receiving reports alleging violations of this policy.

• Notifying the AHPT of reported or observed violations of this policy.

• Evaluating and holding accountable subordinate supervisors and managers

of their actions under this policy.

• Protecting employees who report misconduct from retaliation.

• Taking appropriate action regarding fabricated or false allegations.

• Maintaining confidentiality where required.

3.8 EMPLOYEES

• Refrain from engaging in harassing conduct.

• Participate in training required under this policy.

• Cooperate fully in any inquiry or investigation.

• Review their rights and responsibilities under this policy.

4. POLICY

The DFC is committed to providing a work environment free of discrimination and

harassment based on race, color, religion, sex (including pregnancy, sexual

orientation, and gender identity), national origin, age, disability, genetic information

(including family medical history), status as a parent, marital status, or political

affiliation, and reprisal and retaliation. The DFC will not tolerate offensive sexual or

non-sexual harassing behavior against any person, including but not limited to, any

DFC employee, intern, volunteer, contractor or other non-Federal employee, visitor,

or other member of the public. The DFC will take action, within its authority, to

ensure an environment free from harassing conduct regardless of whether the

parties responsible for, or affected by, the conduct are DFC employees.

The DFC also will not tolerate adverse treatment of or reprisal against employees

because they report harassing conduct or provide information related to such

complaints.

This policy provides guidance to ensure that the DFC supervisors/managers take

immediate and appropriate corrective action, including appropriate disciplinary

action, to eliminate harassing conduct regardless of whether the conduct rises to the

level of a violation of law. Therefore, the goal of this policy is to address harassing

conduct at the earliest possible stage, before it becomes “severe or pervasive,” i.e.,

harassment within the meaning of anti-discrimination law.
Anti-Harassment Policy Page 8 of 17 v.1.0.0, 08/02/2022

4.1 PROHIBITED HARASSING CONDUCT 

Although not every instance of inappropriate behavior may meet the legal 

definition of harassment, any such behavior that undermines morale, work 

environment, and/or the DFC’s mission is prohibited under this policy. 

Harassing conduct, as defined herein will not be tolerated and must be 

promptly reported and investigated in accordance with this policy.

4.2 REPORTING PROCEDURES AND REQUIREMENTS

DFC cannot correct harassing conduct if a supervisor, manager, or other DFC 

official is not aware of the behavior.

4.2.1. ALL EMPLOYEES

Any employee who has been subjected to harassing conduct is 

encouraged to inform the person(s) responsible for the conduct that it is 

unwelcome and offensive, and request that it cease. If the conduct 

continues, is severe, or if the employee is uncomfortable addressing the 

responsible person(s) about the conduct, the employee is encouraged to 

report the matter to:

1. the supervisor of the employee engaging in the misconduct;

2. any supervisor or manager;

3. the Office of Human Resources Management OHRM);

4. the Office of the Inspector General (OIG);

5. the Office of Equal Employment Opportunity (EEO); or

6. the Anti-Harassment Program Team (AHPT) at harassment@dfc.gov

Employees should report harassing conduct, including sexual misconduct,

as soon as practicable after it occurs, but may report at any time, 

regardless of when the incident occurred. Reports made pursuant to this 

policy do not replace, substitute, or otherwise satisfy the separate 

obligations of an EEO complaint, negotiated grievance, or other complaint 

process. Unlike this policy, other complaint procedures typically have a 

required timeframe in which to file and provide for remedial relief to the 

complainants. See Distinction from Statutory and Grievance Claims

for more information about how an employee may pursue rights under one 

of these separate processes, in addition to reporting the misconduct under 

this policy.

Consulting with a union representative to obtain advice or contacting the 

Employee Assistance Program, do not constitute a report under this 

policy, and do not trigger a responsibility to report under this policy. See 

Additional Resources for more information.
Anti-Harassment Policy Page 9 of 17 v.1.0.0, 08/02/2022

4.2.2. SUPERVISORY EMPLOYEES

Supervisors or managers who observe or are informed of allegations of 

harassing conduct must comply with the following reporting requirements:

1. report the conduct/allegations to the AHPT, even if the employee 

raising the allegation requests confidentiality, and

2. take steps to ensure that the harassing conduct is appropriately 

addressed to deter further misconduct, including taking disciplinary 

action, if appropriate. 

4.3 CONSEQUENCES OF HARASSING CONDUCT

4.3.1. ALL EMPLOYEES

Employees are subject to disciplinary action, up to and including removal, 

for engaging in harassing conduct while in the workplace or in any workrelated situation, including while on official travel. Off-duty misconduct may 

subject the employee to potential discipline if the misconduct is likely to 

have an adverse effect on the DFC (e.g., harassing a co-worker, visitor, 

contractor, or volunteer during off-duty hours). Harassing conduct can 

occur in person, through phone calls or in writing, or through the use of 

social media, or other forms of technology.

4.3.2. SUPERVISORY EMPLOYEES

Supervisors and management officials are held to the highest standards of 

conduct, are responsible for the environment they create and the example 

they set for all DFC employees. Appropriate corrective action, disciplinary 

or otherwise, up to and including removal, will be taken against any 

supervisor or other management official who fails to perform their

obligations as set forth in this policy, including any failure to report known 

violations of this policy.

4.4 RETALIATION

It is a violation of this policy to retaliate against employees who engage in 

protected activity under this policy. Protected activity includes, but is not limited

to, reporting harassing conduct, discrimination, or retaliation; filing a claim of 

harassment; providing evidence in any investigation; or intervening to protect 

others who may have suffered harassing conduct, discrimination or retaliation. 

A manager may not fire, demote, harass, transfer an employee impacted by the 

conduct or witness against his or her will, ignore or fail to communicate with an 

employee impacted by the conduct or witness, engage in verbal or physical 

abuse, or non-selection for an employment opportunity, or otherwise take any 
Anti-Harassment Policy Page 10 of 17 v.1.0.0, 08/02/2022

personnel action against an individual for reporting an allegation of misconduct 

under this policy.

It is important that supervisors and managers protect employees who report 

alleged misconduct, and do not take any retaliatory personnel action against 

these individuals in order to deter reporting harassing conduct or filing a 

complaint. A supervisor or manager found to have engaged in retaliation is 

subject to disciplinary action.

The existence of an EEO complaint, grievance, or other procedure alleging 

harassment does not relieve a supervisor or manager of the duty to act under 

to this policy. 

If an employee raises a claim of harassment through the EEO process, a Merit 

Systems Protection Board (MSPB) action, or a negotiated grievance, the DFC 

official who receives the claim will promptly, i.e., within one business day, notify 

the AHPT. The official who receives the claim must treat the notice as a report 

under this policy, and must follow the steps outlined above, unless inconsistent 

with applicable regulatory or statutory requirements. Multiple inquiries into a 

given complaint may proceed in parallel. As noted above, consulting with a 

union representative to obtain advice or contacting the Employee Assistance 

Program do not constitute a report under this policy, and do not trigger a 

responsibility to report under this policy. See Additional Resources for more 

information.

Engaging in protected activity under this policy does not preclude otherwise 

appropriate personnel actions. Supervisors and managers can take personnel 

actions, including discipline and removal, if they are motivated by nonretaliatory and non-discriminatory reasons that would otherwise result in such 

consequences (e.g., transferring an employee for legitimate business reasons 

or closely monitoring the performance of an employee on a Performance 

Improvement Plan).

4.5 INITIAL RESPONSE TO REPORTS OF HARASSMENT

4.5.1. INDIVIDUAL RECEIVING REPORT

When an individual listed in this policy receives a report of, or becomes 

aware of, harassing conduct, they must within one business day:

1. Document the allegation in writing capturing as many specifics as 

possible. At a minimum, the supervisor must provide the name of the 

individual making the report, the employee alleged to have violated 

the policy, and the specific policy violation(s) alleged.

2. Acknowledge receipt of the report to the individual making the report.
Anti-Harassment Policy Page 11 of 17 v.1.0.0, 08/02/2022

3. Contact the AHPT at harassment@dfc.gov or any member of the 

AHPT. 

4. If the report is made outside of the regular business hours, act based 

on their best judgment to minimize any perceived risk of immediate 

harm and contact the AHPT as soon as normal business hours 

resume.

4.5.2. RESPONSE BY AHPT TO REPORT OF HARASSING CONDUCT

When the AHPT receives a report of harassing conduct, they must 

determine:

1. Whether the reported activity is potentially criminal in nature, and if 

so, report it to the Office of Inspector General or law enforcement;

2. Whether the reported activity poses a security risk, and if so, report it 

to the Insider Threat Security Hub;

3. Whether the conduct could be considered harassing conduct, and if 

so, follow the steps outlined in Investigation and Findings, consult 

with the CHCO to designate a responsible management official to be 

responsible for making the preliminary determinations and directing 

any further investigation as warranted.

4.5.3. INTERIM MEASURES

Before directing a thorough investigation into the allegations of 

misconduct, the Responsible Management Official must first consult with 

the AHPT and then take any necessary interim steps to ensure that the 

reported conduct does not continue. The interim measures taken will 

depend on the severity of the conduct alleged, but may include actions 

such as, but not limited to, the following:

1. Instructing the employee alleged to have violated the policy, in 

writing, that an allegation of misconduct has been made, that all 

misconduct must cease and desist immediately and to have no 

further contact or communications with the employee impacted by the 

conduct.

2. Preventing further contact between the employee alleged to have 

violated the policy and the employee impacted by the conduct, by

taking the following actions as appropriate to the situation:

a. assigning the employee alleged to have violated the policy to a 

temporary detail;

b. moving the employee alleged to have violated the policy to 

another office space, desk or floor;
Anti-Harassment Policy Page 12 of 17 v.1.0.0, 08/02/2022

c. requesting approval to place the employee alleged to have 

violated the policy on administrative or investigative leave.

d. Issuing No Contact Instructions to the employee alleged to have 

violated the policy; or

e. A reassignment, detail, etc., of the employee impacted by the 

reported conduct should only be taken if requested by that 

employee. To the extent possible, the Responsible 

Management Official should honor the employee’s request.

4.6 INVESTIGATION AND FINDINGS

4.6.1. CONDUCTING THE INVESTIGATION

Investigation into reports of harassment will proceed as follows:

1. Within three business days of the receipt of the allegation, the 

Responsible Management Official will consult with the AHPT, which 

will determine whether and what type of investigation is required. 

These decisions are fact-specific and made on a case-by-case basis.

2. All information will be maintained on a confidential basis to the 

greatest extent possible, appropriately limited to officials and 

employees within the DFC with a need to know to carry out the 

purpose and intent of this policy. The maintenance of records and 

any disclosures of information from these records shall be in 

compliance with the Privacy Act of 1974, 5 U.S.C. § 552a.

3. If it is determined that an investigation is necessary, the AHPT will 

ensure that the investigative process is initiated within two business 

days, of the decision to begin an investigation.

4. The Responsible Management Official, in consultation with the 

AHPT, will determine the appropriate investigating office. A member 

of the AHPT will serve as the primary point of contact for logistics 

related to the investigation. Investigators can include, for example:

a. The Office of Inspector General, for allegations of criminal 

activity, allegations implicating a DFC executive, or other senior 

or prominent management official, or any OIG employee, and 

allegations tied to waste, fraud, or abuse of DFC funds and 

programs or violations of Federal ethics regulations.

b. An independent or third-party investigator, for allegations of 

harassing conduct of a sexual nature.

c. The Office of Human Resources Management, or the Office of 

General Counsel depending on the complexity and scope of the 

allegations and the availability of qualified investigators.

5. All investigations will be conducted promptly, impartially, and 

thoroughly, in a manner appropriate to the allegation and recommend 
Anti-Harassment Policy Page 13 of 17 v.1.0.0, 08/02/2022

appropriate action to stop any alleged harassing conduct and prevent 

further incidents, including granting appropriate interim relief to the

alleged victim while the allegations are being investigated.

6. All investigations will normally be complete within 30 calendar days.

4.6.2. FINDINGS OF FACT AND REPORT OF INVESTIGATION

1. A written summary of the inquiry shall be prepared by the assigned 

investigator. The summary shall be prepared promptly after completion 

of the inquiry and shall be submitted to the AHPT and the Responsible 

Management Official.

2. The summary of the inquiry or other documentation prepared under 

this procedure shall be kept confidential, to the extent possible. The 

maintenance of records and any disclosures of information from these 

records shall be in compliance with the Privacy Act of 1974, 5 U.S.C. 

§ 552a. Information may be disclosed to defend the DFC in litigation to 

which the information may be relevant and necessary. Further, 

information may need to be disclosed to those officials and employees 

within the DFC with a need to know in order to carry out the purpose 

and intent of this issuance.

3. The AHPT in consultation with the Responsible Management Official, 

will promptly evaluate the evidence and advise on the appropriate 

actions to be implemented by the Responsible Management Official.

Where the inquiry establishes that a supervisor or manager did not 

properly carry out the responsibilities provided for under this guidance, the 

supervisor or manager will be subject to appropriate corrective action, in 

accordance with Disciplinary and Adverse Action Policy, up to and 

including removal.

4.7 CORRECTIVE ACTION

After review of the findings of the investigation, the Responsible Management 

Official must consult with the AHPT to determine whether any disciplinary or 

other corrective action would be appropriate or if the allegation should be 

closed with no finding of misconduct. Where the inquiry substantiates that an 

employee engaged in harassing conduct under this policy, the employee will be 

subject to immediate and appropriate corrective action, in accordance with 

Discipline and Adverse Action Policy. Corrective action may include discipline 

or adverse action up to and including removal from the Federal Service.

Decisions and, if necessary, corrective action will be made within 60 days of 

receiving notice of the harassment complaint.
Anti-Harassment Policy Page 14 of 17 v.1.0.0, 08/02/2022

4.7.1. FINDINGS OF NO MISCONDUCT

If the decision is made that the allegation should be closed with no finding 

of misconduct, the Responsible Management Official should document 

why no corrective action was warranted.

4.7.2. FINDINGS OF MISCONDUCT

If facts uncovered during the investigation or inquiry substantiate 

misconduct, the Responsible Management Official must propose 

disciplinary or corrective action. The proposed corrective action will be 

initiated immediately and appropriately, in accordance with DFC Policy. 

Corrective action may include counseling or any disciplinary action 

applicable to instances of misconduct, such as reprimand, suspension, 

demotion, or termination.

5. RECORDS MANAGEMENT AND CONFIDENTIALITY

5.1 MAINTAINING CONFIDENTIALITY

Supervisors and managers must take action to investigate all allegations of 

harassing conduct, even if the employee raising the allegation requests 

confidentiality. All reports of harassing conduct and related information will be 

maintained on a confidential basis to the greatest extent possible. The identity 

of the employee alleging violations of this policy will be kept confidential, except 

as necessary to conduct an appropriate investigation into the alleged violations, 

to take appropriate disciplinary or corrective action, to comply with the reporting 

requirements of this policy, or when otherwise required by law.

The Responsible Management Official or investigating entity must notify the 

employee impacted by the conduct, in writing, about the completion of the 

process to the extent permitted under the Privacy Act. The reporting employee 

or the employee who was subject to the reported conduct may not be provided 

the outcome of any disciplinary action against the employee alleged to have 

violated the policy and may not be provided a copy of the fact-finding report. 

If the investigation reveals no findings, the employee alleged to have violated 

the policy will be advised of the outcome, in writing. Appropriate disciplinary 

action will occur if the allegation is fully or partially substantiated.

5.2 TRACKING ALLEGATIONS OF HARASSING CONDUCT

The Director, Workforce Relations and Benefits is responsible for tracking the 

information related to the allegations of harassing conduct in separate case 

files, in accordance with established records management policies. The 
Anti-Harassment Policy Page 15 of 17 v.1.0.0, 08/02/2022

Director, Workforce Relations and Benefits must monitor and record the status 

of allegations, including final resolution.

6. MISCELLANEOUS

6.1 DISTINCTION FROM GRIEVANCES AND STATUTORY CLAIMS

This policy and its reporting procedures are separate and distinct from the EEO 

process, which focuses on making employees whole after they have 

experienced discrimination (including harassment) by issuing remedial relief, 

such as compensatory damages. This policy does not change an employee’s 

right to pursue redress through EEO or other available procedures. Corrective 

action taken under this policy does not provide the remedies available in the 

EEO process, negotiated grievance procedures, or any other processes. 

Reporting allegations of misconduct under this policy does not satisfy the 

requirements for filing an EEO complaint, negotiated grievance, or other 

procedure, nor does it modify the time limits for initiating those procedures. 

An employee who chooses to pursue statutory or collective bargaining 

remedies for unlawful harassment must select one of the available forums as 

follows:

1. For an EEO complaint pursuant to 29 C.F.R. §1614 (available for all 

claims of illegal harassment other than those based on status as a 

parent, marital status and political affiliation), contact an EEO counselor 

in the Office of Equal Employment Opportunity within 45 calendar days 

from the most recent incident of alleged harassment (or personnel 

action, if one is involved), as required in 29 C.F.R. §1614.105(a)(1); or

2. For an appeal to the MSPB pursuant to 5 C.F.R. § 1201.22, file a written 

appeal with the Board within 30 days of the effective date of an 

appealable adverse action as defined in 5 C.F.R. §1201.3, or within 30 

days of the date of receipt of the agency’s decision, whichever is later.

3. Employees covered by the Collective Bargaining Agreement may file a 

grievance in accordance with the provisions of the Collective Bargaining 

Agreement.

4. For an appeal to the Office of Special Counsel (OSC) regarding claims 

of harassment related to marital status and political affiliation, pursuant 

to 5 U.S.C. §2302(b)(1) and (b)(10), file a written appeal with the OSC 

as described in 5 C.F.R. §1800.1 and on www.osc.gov; or
Anti-Harassment Policy Page 16 of 17 v.1.0.0, 08/02/2022

6.2 ADDITIONAL RESOURCES

Employees who have experienced harassing conduct have multiple resources 

available that can provide assistance and advice. Engaging with the following 

resources does not constitute a report under this policy, as these entities do not 

have an obligation to inform management of allegations of harassing conduct:

1. Employee Assistance Program (EAP). The DFC EAP is an employee 

benefit program that helps employees with personal and/or work-related 

problems that may impact their job performance, health, and mental and 

emotional well-being. Information about EAP services is available on the

DFC EAP website; or by phone at 1-800-222-0364 (or 888-262-7848 if 

you are hearing-impaired).

2. Union Representative. Employees who are covered by the bargaining 

unit can consult with a union representative.

6.3 INQUIRIES

Any DFC employee or employee representative seeking further information 

concerning this policy may contact the Office of Human Resource Management 

or the Office of Equal Employment Opportunity.

7. REFERENCES

• Title VII of the Civil Rights Act of 1964 (Pub. L. 88-352) (Title VII), as amended

• The Age Discrimination in Employment Act of 1967

• The Rehabilitation Act of 1973, as amended under the Americans with

Disabilities Act Amendments Act of 2008

• Genetic information under the Genetic Information Nondiscrimination Act of 2008

• Parental status under Executive Order 13152 (signed May 2, 2000)

• Marital status and political affiliation under the Civil Service Reform Act of 1978.

• Title 42 of the United States Code, Section 2000e through 16

• Title 29 of the United States Code, Section 633a and 791(f)

• Title 29 of the Code of Federal Regulations, Section 1604.11 and 1614

• Title 5 of the United States Code, Section 2302(b)(l) and (10)

• Title 5 of the United States Code, Chapter 75 and substantially similar authorities 

covering employees in alternate personnel systems

• Executive Order 11478, as amended

• US International Development Finance Corporation’s Harassment Policy 

Statement, issued July 2021. 
Anti-Harassment Policy Page 17 of 17 v.1.0.0, 08/02/2022

APPENDIX A: VERSION CONTROL AND APPROVAL 

Version 

Number 

Effective 

Date 

Summary of Changes Section 

1.0.0 08/02/2022 Initial Release N/A 

Approved by: 

___________________________________________________ August 2, 2022 

Paula Molloy, Vice President, HR & Chief Human Capital Officer Date Approved

PAULA

MOLLOY

Digitally signed by PAULA 

MOLLOY

Date: 2022.08.02 14:37:20 

-04'00'