FARM CREDIT SYSTEM INSURANCE CORPORATION POLICY STATEMENT CONCERNING 

EQUAL EMPLOYMENT OPPORTUNITY AND DIVERSITY

NV #23-03

Effective Date: August 15, 2023

Effect on Previous Action: Replaces NV #22-03 (September 16, 2022).

Source of Authority: Farm Credit Act of 1971, as amended (Act), sections 5.53 and 5.58 (12 U.S.C. §§ 2277a-2 and 12 U.S.C. § 

2277-a-7); Bylaws of Farm Credit System Insurance Corporation (as revised), BM-12-SEP-06-05; Title VII 

of the Civil Rights Act of 1964 (Pub. L. 88-352), as amended (42 U.S.C. § 2000e et seq.) (which includes the 

Pregnancy Discrimination Act); section 501 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 791); 

Civil Service Reform Act of 1978 (Pub. L. 96-54), (5 U.S.C. § 3112); Equal Pay Act of 1974 (29 U.S.C. § 

206 (d)); Age Discrimination in Employment Act (29 U.S.C. § 621 et seq.); Genetic Information 

Nondiscrimination Act of 2008 (42 U.S.C. § 2000ff); Pregnant Workers Fairness Act (Pub. L. 117-328, 

Div. II); Executive Order 11478, as amended by Executive Orders 13087 and 13152; Notification and Federal 

Employee Antidiscrimination and Retaliation Act of 2002 (No FEAR Act) (5 U.S.C. § 2301); EEOC 

Regulation 29 C.F.R Part 1614; EEOC Management Directives including MD-110 and MD-715; EEOC 

Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors, No. 915.002 

(6/18/99); EEOC, “Model EEO Programs Must Have an Effective Anti-Harassment Program” (10/18/05).

WHEREAS, the Farm Credit System Insurance Corporation Board (Board) finds:

• Title VII of the Civil Rights Act of 1964, as amended, protects individuals against employment discrimination on the basis of race, 
color, religion, national origin, and sex (including, but not limited to, discrimination based on gender, gender identity, sexual 

harassment, sexual orientation, pregnancy, childbirth, or related medical conditions); 

• The Age Discrimination in Employment Act of 1967, as amended, protects individuals who are 40 years of age or older from 

employment discrimination based on age; 

• Section 501 of the Rehabilitation Act of 1973, as amended, prohibits employment discrimination against qualified individuals with 

disabilities who work in the Federal Government and requires Federal agencies to provide reasonable accommodation to employees 

or job applicants with disabilities, unless doing so would cause undue hardship;

• The Genetic Information Nondiscrimination Act of 2008 prohibits employment discrimination based on an individual’s genetic 

information; 

• The above laws also make it illegal to retaliate against a person because he or she filed a complaint, participated in discrimination or 

harassment complaint proceedings, or opposed discrimination;

• Executive Order 11478 (Equal Employment Opportunity in the Federal Government), as amended by Executive Orders 13087 and 

13152, includes prohibitions on Federal employment discrimination based on sexual orientation and status as a parent;

• The No FEAR Act requires Federal agencies to be accountable for violations of antidiscrimination and whistleblower protection 

laws; and,

• Equal Employment Opportunity Commission (EEOC) regulations at 29 CFR § 1614.102, as well as various EEOC guidance 

documents, provide standards and guidelines for Federal agencies to establish and maintain continuing affirmative programs to 

promote equal opportunity and to identify and eliminate discriminatory practices and policies.

THEREFORE, the Board adopts the following policy statement and attachment:

The Farm Credit System Insurance Corporation (Corporation) affirms its commitment to the principles embodied in the Federal laws,

regulations, and executive orders that establish equal employment opportunity and prohibit employment discrimination. It is the policy 

of the Corporation to provide equal opportunity for all employees and applicants for employment and to prohibit discrimination in 

Corporation policies, program practices, and operations. All Corporation employment decisions will be made without regard to race, 

color, religion, sex (including, but not limited to, discrimination based on gender, gender identity, sexual harassment, sexual orientation, 

pregnancy, childbirth, or related medical conditions), national origin, age, disability, genetic information, status as a parent, or reprisal 

for raising or participating in a discrimination or harassment complaint or opposing discriminatory or harassing employment practices. 

The Corporation will make reasonable accommodations for qualified applicants for employment and employees with physical or mental 
disabilities under the law. Additionally, the Corporation will provide reasonable accommodations based on applicants’ and employees’ 

religious beliefs or practices, consistent with Title VII. 

It is the Corporation’s policy to provide a work environment free from unlawful discrimination and to protect all employees from 

harassment of any kind. The Corporation begins prompt, thorough, and impartial investigations within 10 days of receiving notice of 

harassment allegations. The Corporation also will not tolerate retaliation against any employee for reporting harassment or for aiding in 

any inquiry about harassment. An employee or applicant who believes they have been discriminated against must initiate contact with 

an EEO Counselor within 45 days of the date of the matter alleged to be discriminatory or, in the case of personnel action, within 45 

days of the effective date of the action. Although the EEO complaint process is managed by the Director of the Office of EEO and 

Inclusion, FCSIC uses experienced outside vendors to perform EEO services. An employee or applicant wishing to enter the EEO

process may contact an EEO Counselor at the following numbers: toll free phone 1-844-322-3233, TTY 703-883-4352.

Furthermore, the Corporation will seek to build and maintain a workforce that reflects the rich diversity of individual differences evident 

throughout this nation. The Corporation values individual differences as enriching and complementary to our organization. When 

individual differences are respected, recognized, and valued, diversity becomes a powerful force that can contribute to achieving superior 

results. Therefore, we will endeavor to create, maintain, and continuously improve on an organizational culture that fully recognizes, 

values, and supports employee diversity. The Corporation is committed to promoting and supporting an inclusive environment that 

strives to provide to all employees, individually and collectively, the chance to work to their full potential in the pursuit of its mission. 

When a barrier to someone achieving this goal exists, we will strive to remove this barrier.

Moreover, the Corporation is committed to increasing the representation of disabled veterans (defined as someone who is entitled to 

compensation under the laws administered by the Department of Veterans Affairs or someone who was discharged or released from active 

duty because of a service-connected disability) within its organization. Our nation owes a debt to veterans who are disabled as a result of 

their service. To honor these disabled veterans, the Corporation will place emphasis on making vacancies known to disabled veterans 

and providing opportunities for employing disabled veterans.

The Corporation expects full cooperation and assistance from everyone associated with recruitment, hiring and firing, development, transfer, 

promotion, layoff or recall, training, compensation, assignment or classification of employees, provision of benefits, or other terms and 

conditions of employment to assure that such actions are free of unlawful discrimination and support the Corporation’s equal employment 

opportunity and diversity policies.
In addition, the Corporation will implement procedures for employees and applicants for employment to seek resolution of discrimination 

and harassment complaints in accordance with Federal law and regulations.

OVERALL OBJECTIVES:

• The Corporation is committed to ensuring that all employees and applicants for employment enjoy equality of opportunity from 

the Corporation regardless of their race, color, religion, sex (including, but not limited to, discrimination based on gender, 

gender identity, sexual harassment, sexual orientation, pregnancy, childbirth, or related medical conditions), national origin, 

age, disability, genetic information, status as a parent, or reprisal for raising or participating in a discrimination or harassment 

complaint or opposing discriminatory or harassing employment practices. 

• The Corporation will comply with all applicable EEOC regulations and guidelines for a Federal organization of its size and 

configuration. This includes maintaining a continuing affirmative program to promote equal opportunity and to identify and to 

eliminate discriminatory practices and policies; implementing procedures for employees and applicants for employment to seek 

resolution of discrimination and harassment complaints; and implementing procedures for qualified employees and applicants 

with disabilities to seek reasonable accommodation.

DATED THIS 15th DAY OF AUGUST 2023 

BY ORDER OF THE BOARD

_________________________

Ashley Waldron

Secretary to the Board

Attachment: Farm Credit System Insurance Corporation Policy Statement Regarding Harassment
Attachment

FARM CREDIT SYSTEM INSURANCE CORPORATION

POLICY STATEMENT REGARDING HARASSMENT

DEFINITION:

Harassment is unwelcome verbal or physical conduct based on race, color, religion, sex (including, but not limited to, discrimination 

based on gender, gender identity, sexual harassment, sexual orientation, pregnancy, childbirth, or related medical conditions), national 

origin, age, disability, genetic information, status as a parent, or reprisal for raising or participating in a discrimination or harassment 

complaint or opposing discriminatory or harassing employment practices when the conduct results in a tangible employment action or 

creates a hostile work environment.

1. Tangible Employment Actions include: 

- Hiring. 

- Firing. 

- Promoting. 

- Denial of promotions. 

- Demoting. 

- Suspending.

- Removing. 

- Reassigning. 

- Negative performance evaluations. 

- Withholding training or denying opportunities to compete for awards and recognition. 

- Job assignments designed to limit career progression. 

- Any other action that significantly affects one’s employment status.

2. Hostile Work Environment occurs when anyone in the workplace engages in conduct so severe and pervasive that it

creates a work environment that a reasonable person would consider intimidating, hostile, or offensive.

Harassment includes, but is not limited to:
- Threats or reprimands.

- Intimidating acts, words, or gestures.

- Coercing acts.

- Emotional abuse, bullying, or stalking.

- Display of derogatory graphic or written material.

- Derogatory, offensive, or suggestive comments, slurs or jokes.

- Vulgar gestures or language.

- Unwelcome flirtations, advances, or touching.

POLICY STATEMENT:

The Farm Credit System Insurance Corporation (Corporation) will not tolerate harassment in the workplace or reprisal for raising or 

participating in an Equal Employment Opportunity (EEO) or harassment inquiry or proceeding or for opposing discrimination or harassment. 

All managers, supervisors, employees, and agents of the Corporation must comply with the requirements of this policy. Any employee 

or agent of the Corporation found to have engaged in harassing behavior will be subject to discipline or adverse action, with penalties 

ranging up to and including removal. 

This policy applies to all Corporation employees (whether supervisory or not); to all applicants for employment; and to third parties, such 

as contractors or any other nonemployees (consistent with the Corporation’s control over third parties), in any Corporation-related setting, 

on or off Corporation premises. To the extent possible, consistent with its duty to prevent, investigate, and correct any violation of this 

policy, the Corporation will protect against unnecessary disclosure of the confidentiality of all parties to a harassment complaint. The 

Corporation begins prompt, thorough, and impartial investigations within 10 days of receiving notice of harassment allegations. Employees 

who make claims of harassment or provide information related to such claims will be protected against retaliation.

The Corporation’s Chief Operating Officer (COO) is responsible for ensuring the Corporation complies with this policy.

The Corporation managers and supervisors will take responsibility for creating and upholding a workforce free of harassment; will 

commit to bringing harassment to a halt before it becomes so severe or pervasive that it rises to a violation of Federal law; on seeing or 

becoming aware of harassment, will immediately intervene to stop the objectionable behavior and report it to the COO, even in cases where 

an employee or applicant fails to report it; and will prevent retaliation against any employee or applicant who reports harassment or aids in 

any harassment inquiry.

The Corporation employees are urged to protect their rights and those of others by reporting possible incidents of harassment through the 

procedures outlined in this policy.
COMPLAINT PROCESS:

Employees may choose to resolve a harassment complaint through the internal harassment complaint process or through other complaint 

processes. Both methods will result in a prompt, thorough, and impartial investigation. Job applicants may resolve a harassment 

complaint only by pursuing either an EEO claim or an Office of Special Counsel (OSC) complaint, or both, as appropriate, as discussed 

below. Employees planning to use both methods should be aware that there are strict time limits for filing a grievance or EEO complaint

that will run simultaneously with the time that the employee may attempt to reach an informal resolution. 

A. Internal Harassment Complaint Process 

If an employee believes someone in the workplace is harassing him or her in violation of this policy, the employee may choose 

to discuss the matter with any of the following individuals who may be able to assist him or her in resolving the matter or refer 

him or her to the appropriate person to resolve the harassment complaint:

(a) The employee’s supervisor;

(b) The accused harasser’s supervisor; or,

(c) The Chief Human Capital Officer of the Farm Credit Administration (FCA), who is hereby designated as, and delegated 

the authority to act as, the Chief Human Capital Officer of the Corporation for this purpose.

The employee that is seeking a resolution and any individual named in (a) through (c) above may take any of the following steps 

to resolve the matter:

• Contact the accused harasser in person or in writing.

• Ask a resolving official to speak to the accused harasser about the employee’s concern.

• Use mediation to address the concern.

• Explore other ways to resolve the concern.

Any individual listed in (a) through (c) above that is contacted by an employee regarding an act of harassment will inform the 

employee in the initial contact about the provisions in this policy relevant to the 15-day and 45-day time periods for filing a 

grievance or an EEO claim, respectively. (See discussion below.) Any individual listed in (a) through (c) above that helps the 

employee resolve the matter will record how the matter was resolved and provide a report to the COO.
B. Other Complaint Processes

Complaining employees may choose to pursue other complaint processes to resolve the complaint, depending on the nature of 

the harassment:

Corporation Grievance System: An employee may seek redress through the Corporation grievance system for claims of 

harassment based on race, color, religion, sex (including, but not limited to, discrimination based on gender, gender identity, 

sexual harassment, sexual orientation, pregnancy, childbirth, or related medical conditions), national origin, age, disability, 

genetic information, status as a parent, or reprisal for raising or participating in a discrimination or harassment complaint or 

opposing discriminatory or harassing employment practices. 

An employee must submit a grievance within 15 calendar days from the date on which he or she knew or had reason to know 

about the issue, condition, or occurrence that is the subject of the grievance. A grievance presented beyond this time limit may 

be rejected as untimely, but an exception may be granted if the complaining employee can demonstrate that extenuating 

circumstances precluded the submission of the complaint within the 15-calendar-day time limit. See FCA PPM 827 for more 

information.

Harassment is a form of unlawful discrimination under Title VII of the Civil Rights Act of 1964, the Age Discrimination in 

Employment Act, the Rehabilitation Act of 1973, or the Genetic Information Nondiscrimination Act of 2008 when it is based on 

race, color, religion, sex (including, but not limited to, discrimination based on gender, gender identity, sexual harassment, sexual 

orientation, pregnancy, childbirth, or related medical conditions), national origin, age, disability, genetic information, or reprisal 

for raising or participating in a discrimination or harassment complaint or opposing discriminatory or harassing employment 

practices. Federal government policy, as set forth in Executive Order 11478, as amended, forbids discrimination in Federal 

employment based on sexual orientation or status as a parent. The Corporation will address claims of harassment on any of these 

bases through the grievance system.

A grievance is a request by an employee for “personal relief” in a matter of concern or dissatisfaction relating to the employment 

of the employee that is subject to the control of Corporation management. "Personal relief" means a specific remedy directly 

benefiting the grievant. Although the personal relief available through the grievance system does not include a disciplinary or 

other action affecting another employee, the Corporation may implement such corrective action as a result of a grievance system 

claim.

Claims: An employee or job applicant may bring claims based on race, color, religion, sex (including, but not limited to, 

discrimination based on gender, gender identity, sexual harassment, sexual orientation, pregnancy, childbirth, or related medical 
conditions), national origin, age, disability, genetic information, or reprisal for raising or participating in a discrimination or 

harassment complaint or opposing discriminatory or harassing employment practices. In the Corporation Board Action on 

Delegations of Certain Functions to Officials at the FCA, BM-21-JUN-01-03, effective June 21, 2001, the Corporation authorized 

FCA’s EEO Director, or alternates as chosen by FCA, to serve as the Corporation’s EEO Director. (As noted above, these claims 

can also be brought under the Corporation’s grievance system.)

If an employee or a job applicant chooses to bring an EEO harassment claim, the EEO administrative process for filing 

discrimination claims (see 29 C.F.R. Part 1614) applies. These regulations require him or her to seek the advice of an EEO 

Counselor or the EEO Director within 45 days of the date of the alleged discrimination or, for a discriminatory personnel action, 

within 45 days of the effective date of the action. This means that to meet the 45-day timeframe and preserve the employee’s 

rights under the EEO administrative process, the employee may need to contact an EEO Counselor or the EEO Director even if 

he or she is continuing to attempt to resolve the concern informally or through the grievance system.

The EEO process is designed to make individuals whole for discrimination that has occurred through damage awards and 

equitable relief paid by the agency and to prevent the recurrence of the unlawful discriminatory conduct. Additionally, the 

Corporation may implement corrective action it deems appropriate.

Office of Special Counsel (OSC) Complaints: The OSC is an independent Federal investigative and prosecutorial agency 

whose basic authorities include protecting Federal employees and applicants from prohibited personnel practices. In some 

circumstances, employees may raise concerns to the OSC. See the OSC's website www.osc.gov or call (800) 872-9855 for 

more information.

Merit Systems Protection Board (MSPB) Complaints: In some circumstances, employees may be able to bring certain types 

of harassment claims or appeals to the MSPB. See the MSPB's web site www.mspb.gov or call (800) 209-8960 for more 

information. 

CORRECTIVE ACTION

Whether the complaint was made through the EEO process or the Corporation grievance process, if the Corporation finds that 

harassment took place, the COO will consult with the parties who need to know to decide what corrective action to take. Parties 

who need to know may include the:

- Supervisors of the complaining party or harasser.

- Supervisors affected by a proposed corrective action (such as a proposed transfer of the harasser).
- General Counsel.

- EEO Director.

Corrective action includes disciplinary action, which may include any Corporation administrative action from reprimand to 

removal, as well as training and monitoring. Corrective action may also include anything to make the complainant whole again, 

such as:

- Restoring leave taken because of harassment.

- Deleting a negative performance evaluation given because of harassment.

- Requiring the harasser to apologize to the complaining party.

If harassment is found to have occurred, the Corporation will take immediate and appropriate corrective action within sixty (60) 

calendar days of receiving the complaint. The Corporation will initiate follow-up procedures to ensure that: (a) the problem has 

been resolved, and (b) no retaliation occurs.