Equal Opportunity in Contracting Policy



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Federal Home Loan Bank of San Francisco 600 California Street, Suite 300 San Francisco, California 94108

Table of Contents Statement... 3 Responsibilities of the Office of Minority and Women Inclusion (OMWI)... 3 Definitions... 4 Policy Dissemination... 4 Outreach... 4 Reporting Complaints and Concerns... 5 December 2011 Page 2 of 5

Statement The Federal Home Loan Bank of San Francisco ( the Bank ) is committed to fostering a diverse and tolerant environment that is free of discrimination and harassment. The Bank is committed to providing equal opportunity and nondiscrimination in contracting without regard to race, color, religion, national origin, citizenship, ancestry, sex, gender identity, sexual orientation, physical or mental disability (including pregnancy childbirth, or related medical conditions), military service or veteran status, caregiver status, age, family care or medical leave status, marital status, domestic partner status, genetic information or any other basis prohibited by applicable law. The Bank continually strives to ensure fair and inclusive business practices and will not tolerate discrimination in contracting based on any protected class. To the maximum extent possible, in balance with financially safe and sound business practices, the Bank is committed to the inclusion and utilization of minority-, women-, and disabled-owned businesses. The Bank actively seeks out diverse potential vendors for contracting opportunities and encourages diverse vendors to submit offers or bids for the award of contracts for goods and services. The Bank will seek the most qualified vendor and will take diversity into account by reviewing the diversity status of the vendor as we evaluate the contracting opportunity. Responsibilities of the Office of Minority and Women Inclusion (OMWI) The Bank s Office of Minority and Women Inclusion ( OMWI ) is responsible for ensuring the Bank s compliance with the related requirements of the Housing and Economic Recovery Act of 2008. The Senior Vice President and Director of Human Resources is the Bank s EEO and OMWI Officer and is responsible for the overall implementation of the Bank s programs for equal opportunity in contracting and employment. The EEO and OMWI Officer reports to the Chief Executive Officer, has the complete and unqualified support of senior management, and is assured of the resources necessary to execute his or her responsibilities successfully. Specifically, the EEO and OMWI Officer is responsible for the following: 1. Implementing the OMWI program, including policy development and review; procedure development and maintenance; and dissemination and publication of policies and procedures. The program will be reviewed at least annually to assess its effectiveness and to make appropriate changes, if needed. 2. Keeping management informed of all important changes in the law and in equal opportunity policies regarding employment and contracting and preparing reports, as needed, to the Bank s Chief Executive Officer and the Board of Directors concerning the status of the Bank s program for promoting equal opportunity in contracting. 3. Investigating and resolving, in a timely fashion, all formal discrimination in contracting complaints. 4. Overseeing the training of Bank management and staff on the importance of equal opportunity and nondiscrimination in contracting. 5. Establishing a program that is designed to ensure, to the maximum extent possible, the inclusion of minority-, women-, and disabled-owned businesses in contracting opportunities at the Bank. December 2011 Page 3 of 5

Definitions Definitions of minority-, women-, and disabled-owned businesses (12 C.F.R. Section 1207.1): A minority-owned business is a business in which (1) more than 50 percent of the ownership or control is held by one or more minority individuals; and (2) more than 50 percent of the net profit or loss accrues to one or more minority individuals. A women-owned business is a business in which (1) more than 50 percent of the ownership or control is held by one or more women; (2) more than 50 percent of the net profit or loss accrues to one or more women; and (3) a significant percentage of senior management positions are held by women. A disabled-owned business is a business in which (1) the business is qualified as a Service-Disabled Veteran-Owned Small Business Concern as defined in 13 C.F.R. Section 125.8-125.13; or (2) more than 50 percent of the ownership or control is held by one or more persons with a disability; and (3) more than 50 percent of the net profit or loss accrues to one or more persons with a disability. For more information regarding the definitions provided above, see 12 C.F.R. Section 1207.1. Policy Dissemination The Bank s efforts to publicize its commitment to equal opportunity and nondiscrimination in contracting, include, but are not necessarily limited to, the following: 1. Publishing and posting of the Bank's and Procedures at the Bank s offices; 2. Providing training to procurement decision-makers concerning the Bank's and Procedures; and, 3. Notifying existing and potential vendors of the Bank s commitment to equal opportunity in contracting. Outreach Publication of Contracting Opportunities The Bank will publish contracting opportunities, as appropriate, to encourage diverse vendors to submit offers or bids. Publication of contracting opportunities may include: 1. Publication of a list of the goods and services that the Bank utilizes on the Bank s Supplier Diversity portal, and with organizations such as the National Minority Supplier Development Council (NMSDC) or Women s Business Enterprise National Council (WBENC), either locally, nationally, or both. Outreach to Diverse Vendors The Bank works with supplier diversity sources and organizations to ensure that members of diverse groups are aware of contracting opportunities. Outreach may include: 1. Bank membership in organizations and associations that promote supplier diversity. 2. Maintaining a database of diverse vendors that can be accessed externally, by existing and potential vendors, and internally, by the Bank s procurement decisions makers. 3. Participating in business expositions that include diverse vendors. 4. Educating and encouraging existing or potential vendors about the process of becoming certified or self-classified as a diverse business. December 2011 Page 4 of 5

Reporting Complaints and Concerns Individuals with complaints or concerns regarding perceived discrimination in contracting opportunities may bring these issues to the attention of the EEO and OMWI Officer. Any request for formal review of a complaint must be in writing and describe, in reasonable detail, the reason for the complaint, including, but not limited to, the individual(s) involved; the action or treatment believed to be discriminatory; and the approximate applicable time period. The EEO and OMWI Officer, or his representative, will thoroughly investigate every reported complaint of discrimination and will provide the results of the investigation to the person lodging the complaint. Complaints of discrimination should be directed to: Senior Vice President and Director of Human Resources FHLBank San Francisco P.O Box 7948 San Francisco, CA 94120 The Federal Home Loan Bank of San Francisco prohibits retaliation against any individual who files a complaint or other concern pursuant to this policy. December 2011 Page 5 of 5