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MEMORANDUM

DATE:  July 6, 2020

TO:  All Export-Import Bank of the United States Employees

FROM:  Kimberly A. Reed, President and Chairman

SUBJECT:  Anti-Harassment Policy Statement


The Export-Import Bank of the United States (EXIM) is the official export credit agency of the United States. EXIM is an independent, self-sustaining federal agency that exists to support American jobs by facilitating the export of U.S. goods and services. For EXIM to do its job well, we must ensure a professional working environment, engage in respectful behavior, and maintain the highest standard of conduct. This includes refraining from committing as any harassing and discriminatory behavior and reporting such behavior in the event it occurs. EXIM does not permit harassing conduct by anyone in the workplace.

Harassment is unwelcome conduct that is based on race, color, religion, sex (including pregnancy, sexual orientation, or gender identity), national origin, age (40 or older), disability, genetic information, or reprisal for protected Equal Employment Opportunity (EEO) activity. Harassment becomes unlawful when it alters the conditions of employment either by 1) culminating in a tangible employment action, or 2) the harassing conduct is severe or pervasive enough to create a hostile work environment.

Petty slights, annoyances, and isolated incidents (unless extremely serious) will not rise to the level of illegality. To be unlawful, the conduct must create a work environment that would be intimidating, hostile, or offensive to reasonable people. Offensive conduct may include, but is not limited to, offensive jokes, slurs, epithets or name calling, physical assaults or threats, intimidation, ridicule or mockery, insults or put-downs, offensive objects or pictures, and interference with work performance. EXIM is committed to preventing and eliminating conduct before it rises to the level of unlawful harassment.

Any employee who experiences or witnesses harassing conduct should promptly report the matter to their supervisor, another manager or supervisor, the Chief of the Human Capital Division, or the Office of Inspector General (OIG). In addition, employees may initiate an EEO complaint based on their membership in one or more protected bases by contacting the Office of Equal Employment Opportunity Director and initiating the EEO process within 45 days of the alleged harassment.

Upon receipt of a report of harassment, the supervisor or manager will consult with the appropriate office and ensure that a prompt, thorough, impartial and appropriate inquiry is initiated within ten calendar days ; and recommend appropriate action to stop any harassing conduct and prevent further harassment. If the inquiry determines harassment occurred, EXIM will take immediate and proportionate corrective action.

The identity of the individual who submits a report, a witness who provides information regarding a report, and the target of the complaint, will be kept confidential to the extent possible consistent with a thorough and impartial inquiry. Any information gathered as part of an inquiry will be kept confidential to the extent possible consistent with a thorough and impartial inquiry.

An individual who submits a report (either of harassment experienced or observed) or a witness who provides information regarding a report will be protected from retaliation. Any employee who retaliates against any individual who submits a report or provides information regarding a report will be disciplined appropriately.

All EXIM employees are responsible for exhibiting professional conduct and behavior in the workplace and cooperating in the enforcement of this policy. Individuals engaging in conduct or behavior that violates this policy may be subject to appropriate disciplinary action up to, and including, removal from Federal service.

It is an important goal at EXIM to maintain avenues for full participation in its mission to support American jobs by facilitating U.S. exports, and to hold true to our EXIM values of: integrity, stewardship, accountability, inclusivity, and leadership.