The Standards for Assessing the Diversity Policies 

and Practices

The FDIC, together with federal financial regulators (The Agencies) designed these Standards to 

provide a framework for an entity to create and strengthen its diversity policies and practices, 

including its organizational commitment to diversity, workforce and employment practices, 

procurement and business practices, and practices to promote transparency of organizational 

diversity and inclusion. The Agencies recognize that each entity is unique with respect to 

characteristics such as its size, location, and structure. When drafting these standards, the 

Agencies focused primarily on institutions with more than 100 employees. The Agencies know 

that institutions that are small or located in remote areas face different challenges and have 

different options available to them compared to entities that are larger or located in more urban 

areas. The Agencies encourage each entity to use these Standards in a manner appropriate to 

its unique characteristics. Finally, the Agencies intend that the Standards will address an entity’s 

U.S. operations. 

(1) Organizational Commitment to Diversity and Inclusion 

The leadership of an organization with successful diversity policies and practices demonstrates its 

commitment to diversity and inclusion. Leadership comes from the governing body, such as a board 

of directors, as well as senior officials and those managing the organization on a day-to-day basis. 

These Standards inform how an entity promotes diversity and inclusion in both employment and 

contracting and how it fosters a corporate culture that embraces diversity and inclusion. 

Standards 

In a manner reflective of the individual entity’s size and other characteristics, 

§ The entity includes diversity and inclusion 

considerations in both employment and 

contracting as an important part of its strategic 

plan for recruiting, hiring, retention, and 

promotion. 

§ The entity has a diversity and inclusion policy 

that is approved and supported by senior 

leadership, including senior management and 

the board of directors. 

§ The entity provides regular progress reports to 

the board and senior management. 

§ The entity regularly conducts training and 

provides educational opportunities on equal 

employment opportunity and on diversity and 

inclusion. 

§ The entity has a senior level official, preferably 

with knowledge of and experience in diversity 

and inclusion policies and practices, who 

oversees and directs the entity’s diversity and 

inclusion efforts. For example, this official 

may be an executive-level Diversity Officer (or 

equivalent position) with dedicated resources 

to support diversity strategies and initiatives. 

§ The entity takes proactive steps to promote 

a diverse pool of candidates, including 

women and minorities, in its hiring, 

recruiting, retention, and promotion, as well 

as in its selection of board members, senior 

management, and other senior leadership 

positions. 
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(2) Workforce Profile and Employment Practices 

Many entities promote the fair inclusion of minorities and women in their workforce by publicizing 

employment opportunities, creating relationships with minority and women professional 

organizations and educational institutions, creating a culture that values the contribution of all 

employees, and encouraging a focus on these objectives when evaluating the performance of 

managers. Entities with successful diversity and inclusion programs also regularly evaluate be 

improved. 

Entities use various analytical tools to evaluate a wide range of business objectives, including 

metrics to track and measure the inclusiveness of their workforce (e.g., race, ethnicity, and gender). 

Entities that are subject to the recordkeeping and reporting requirements of the Equal Employment 

Opportunity Commission (EEOC) and the Office of Federal Contract Compliance Programs currently 

collect and maintain data and supporting documentation that may assist in evaluating and assessing 

their policies and practices related to workforce diversity and inclusion. Specifically, entities that 

file EEO-1 Reports9 required under Title VII of the Civil Rights Act of 1964 routinely track and analyze 

employment statistics by gender, race, ethnicity, and occupational group. Entities that develop and 

implement the affirmative action programs required under the regulations implementing Executive 

Order 11246 track and analyze employer-created job groups. 

Entities also are encouraged to use other analytical tools that they may find helpful. 

Standards 

In a manner reflective of the individual entity’s size and other characteristics, 

§ The entity implements policies and practices 

related to workforce diversity and inclusion in a 

manner that complies with all applicable laws. 

§ The entity ensures equal employment 

opportunities for all employees and applicants 

for employment and does not engage in 

unlawful employment discrimination based on 

gender, race, or ethnicity. 

§ The entity has policies and practices that create 

diverse applicant pools for both internal and 

external opportunities that may include: 

• Outreach to minority and women 

organizations; 

• Outreach to educational institutions serving 

significant minority and women student 

populations; and 

• Participation in conferences, workshops, 

and other events to attract minorities and 

women and to inform them of employment 

and promotion opportunities. 

§ The entity utilizes both quantitative and 

qualitative measurements to assess its 

workforce diversity and inclusion efforts. 

These efforts may be reflected, for example, 

in applicant tracking, hiring, promotions, 

separations (voluntary and involuntary), career 

development, and retention across all levels 

and occupations of the entity, including the 

executive and managerial ranks.

§ The entity holds management at all levels 

accountable for diversity and inclusion efforts, 

for example by ensuring that such efforts 

align with business strategies and individual 

performance plans.

9

 The Employer Information ReportEE0-1 (EEO—I Report) is required to be filed annually with the EEOC by (a) private employers with 100 or more employees and (b) federal contractors and first tier subcontractors with 50 or more employees 

that have a contract or subcontract of $50,000 or more or that serve as a depository of government funds in any amount.
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(3) Procurement and Business Practices—Supplier Diversity

Companies increasingly understand the competitive advantage of having a broad selection of 

available suppliers to choose from with respect to factors such as price, quality, attention to detail, 

and future relationship building. A number of entities have achieved success at expanding available 

business options by increasing outreach to minority-owned and women-owned businesses.

As in the employment context, entities often use metrics to identify the baseline of how much they 

spend procuring and contracting for goods and services, how much they spend with minority-owned 

and women-owned businesses, and the availability of relevant minority-owned and women- owned 

businesses, as well as changes over time. Similarly, entities may use outreach to inform minorityowned and women-owned businesses (and affinity groups representing these constituencies) of 

these opportunities and of the procurement process.

In addition, entities’ prime contractors often use subcontractors to fulfill the obligations of various 

contracts. The use of minority-owned and women-owned businesses as subcontractors provides 

valuable opportunities for both the minority-owned and women-owned businesses and the prime 

contractor. Entities may encourage the use of minority-owned and women-owned subcontractors by 

incorporating this objective in their business contracts.

Standards

In a manner reflective of the individual entity’s size and other characteristics,

§ The entity has a supplier diversity policy that 

provides for a fair opportunity for minority 

-owned and women-owned businesses to 

compete for procurement of business goods 

and services. This includes contracts of all 

types, including contracts for the issuance or 

guarantee of any debt, equity, or security, the 

sale of assets, the management of the entity’s 

assets, and the development of the entity’s 

equity investments.

§ The entity has methods to evaluate its supplier 

diversity, which may include metrics and 

analytics related to:

• Annual procurement spending;

• Percentage of contract dollars awarded 

to minority-owned and women-owned 

business contractors by race, ethnicity, and 

gender; and

• Percentage of contracts with minorityowned and women-owned business subcontractors.

§ The entity has practices to promote a diverse 

supplier pool, which may include:

• Outreach to minority-owned and womenowned contractors and representative 

organizations;

• Participation in conferences, workshops, 

and other events to attract minority-owned 

and women-owned firms and inform them 

of contracting opportunities; and

• An ongoing process to publicize its 

procurement opportunities.
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(4) Practices To Promote Transparency of Organizational Diversity and Inclusion

Transparency and publicity are important aspects of assessing diversity policies and practices. 

Greater awareness and transparency give the public information to assess those policies and 

practices. Entities publicize information about their diversity and inclusion efforts through normal 

business methods, which include displaying information on their Web sites, in their promotional 

materials, and in their annual reports to shareholders, if applicable. By making public an entity’s 

commitment to diversity and inclusion, its plans for achieving diversity and inclusion, and the 

metrics it uses to measure success in both workplace and supplier diversity, an entity informs a 

broad constituency of investors, employees, potential employees, suppliers, customers, and the 

general community about its efforts. The publication of this information can make new markets 

accessible for minorities and women and illustrate the progress made toward an important 

business goal.

Standards

In a manner reflective of the individual entity’s size and other characteristics, the entity is transparent 

with respect to its diversity and inclusion activities by making the following information available to 

the public annually through its Web site or other appropriate communication methods:

§ The entity’s diversity and inclusion strategic 

plan;

§ The entity’s policy on its commitment to 

diversity and inclusion;

§ The entity’s progress toward achieving 

diversity and inclusion in its workforce and 

procurement activities (which may include 

the entity’s current workforce and supplier 

demographic profiles); and

§ Opportunities available at the entity that 

promote diversity, which may include:

• Current employment and procurement 

opportunities;

• Forecasts of potential employment and 

procurement opportunities; and

• The availability and use of mentorship and 

developmental programs for employees 

and contractors.

(5) Entities’ Self-Assessment

The Agencies interpret the term “assessment” to mean self-assessment. Entities that have 

successful diversity policies and practices allocate time and resources to monitoring and evaluating 

performance under their diversity policies and practices on an ongoing basis. Entities are 

encouraged to disclose their diversity policies and practices, as well as information related to their 

assessments, to the Agencies and the public. Entities submitting information may designate such 

information as confidential commercial information as appropriate, and the Agencies will follow the 

Freedom of Information Act in the event of requests for particular submissions.

Standards

In a manner reflective of the individual entity’s size and other characteristics,

§ The entity uses the Standards to conduct 

self-assessments of its diversity policies and 

practices annually.

§ The entity monitors and evaluates its 

performance under its diversity policies and 

practices on an ongoing basis.

§ The entity provides information pertaining to 

the self-assessments of its diversity policies 

and practices to the OMWI Director of its 

primary federal financial regulator.

§ The entity publishes information pertaining to 

its efforts with respect to the Standards.