U.S.

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Washington, D.C. 20507

September 29, 2016

Tanya Ward Jordan

President
The Coalition for Change, Inc. (C4C)
Dear President Jordan,
Thank you for the opportunity to respond to the questions posed by your organization. As
requested, the attached are provided in response.
Thank you!
Digitally signed by Carlton M. Hadden
DN: cn=Carlton M. Hadden, o=U. S. Equal Employment
Opportunity Commission, ou=Office of Federal Operations,
email=carlton.hadden@eeoc.gov, c=US
Date: 2016.09.30 16:30:48 -04'00'

Carlton M. Hadden
Director, Office of Federal Operations

How can members of the public ask questions and learn more about
the federal sector EEO complaint process? (Response to Question
V)
Telephone calls to EEOCs Intake Information Group at 1-800-669-4000
EEOC has an Intake Information Group (IIG), which receives all calls from the public made to
1-800-669-4000, 1-844-234-5122 for ASL Video Phone, and 1-800-669-6820 TTY (TTY and
ASL Video Phone are for Deaf/Hard of Hearing callers only). The IIG also receives e-mail
from the public addressed to info@eeoc.gov. The IIG is staffed by Intake Information
Representatives (IIRs) in locations across the country.
IIRs provide information about the laws enforced by EEOC and the processes including how to
file a charge or complaint of discrimination. They also refer callers to the appropriate EEOC
office for information, as appropriate. They also refer individuals to the appropriate Federal,
State, or local agency if EEOC is not the right agency to address their concerns.
In late 2015, EEOC increased staffing of the IIG so that in January 2016 IIRs could begin
receiving and responding to questions relating to the status of appeals before the EEOC Office
of Federal Operations in the federal sector EEO complaint process. Members of the public,
who have questions about the federal sector EEO complaint process, should call 1-800-6694000, 1-844-234-5122 for ASL Video Phone (for Deaf/Hard of Hearing callers only), or 1-800669-6820 (TTY for Deaf/Hard of Hearing callers only).
E-mail inquiries to the Office of Federal Operations at ofo.eeoc@eeoc.gov
EEOCs Office of Federal Operations responds to e-mail inquiries sent to ofo.eeoc@eeoc.gov.
Staff in the Office of Federal Operations monitor this e-mail account from Monday through
Friday from 9:00 a.m. to 6:00 p.m. and typically responds to e-mail inquiries within a few hours.
Resources at EEOCs website
EEOCs website has informational resources on the federal sector EEO complaint process,
including:
Equal Employment Opportunity Management Directive for 29 C.F.R. Part 1614 (EEO-MD-110)
(revised Aug. 5, 2015), https://www.eeoc.gov/federal/directives/md110.cfm. This
Directive provides federal agencies with Commission policies, procedures, and guidance
relating to the processing of employment discrimination complaints governed by the
Commission regulations in 29 C.F.R. Part 1614. Additionally, the Directives preamble
examines the history of the federal sector EEO complaint process, from the 1940s to the
2010s. The Directives appendix has certain sample forms.
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 U.S. Equal Employment Opportunity Commission Handbook for Administrative Judges (July 1,
2002), https://www.eeoc.gov/federal/ajhandbook.cfm. This Handbook provides
guidance to EEOC Administrative Judges concerning the processing of hearing requests
and the conduct of hearings on individual and class complaints of discrimination. This
Handbook supplements the Commissions regulations and the EEOC Management
Directive 110 (EEO-MD-110).
Frequently Asked Questions About the Federal Sector Hearing Process,
https://www.eeoc.gov/federal/fed_employees/faq_hearing.cfm. These frequently asked
questions are primarily intended for complainants and their representatives seeking
information about the EEOC federal sector hearing process. There is also an index of
sample forms and orders.
Database of Frequently Asked Questions, https://eeoc.custhelp.com/app/answers/list. Need
quick answers? Search EEOCs database of frequently asked questions, which includes
several questions on the federal sector EEO complaint process.
Federal Agency EEO Directors, https://www.eeoc.gov/federal/eeo_directors.cfm. This is a
listing of the EEO Directors at various federal agencies. Should you have issues with an
agencys processing of your federal sector EEO complaint or need assistance in locating
the correct agency EEO official to assist you, you may contact the appropriate EEO
Director for guidance.
Digest of Equal Employment Opportunity Law,
https://www.eeoc.gov/federal/digest/index.cfm. This publication includes feature
articles on timely issues in equal employment opportunity law, as well as summaries of
recent Commission decisions and federal court cases, as they affect federal government
employees. For example, the Winter 2008 Digest issue provided a historical look at the
federal sector EEO process. A Look at the EEOCs Office of Federal Operations Federal Sector
Programs: Past, Present, and Future, DIGEST OF EQUAL EMPLOYMENT OPPORTUNITY LAW,
Vol. XIX, No. 1 (Winter 2008), https://www.eeoc.gov/federal/digest/xix-1.cfm

Why do aggrieved individuals generally have to go through the precomplaint process and contact their agencys EEO counselor within
45 days? (Response to Questions XI & XII)
The pre-complaint process can help promote impartial, fair, and early resolution of
complaints
In 1992, EEOC revised the way that federal agencies and EEOC processed administrative
complaints and appeals of employment discrimination filed by federal employees and applicants
for federal employment. The regulation (29 C.F.R. Part 1614) was intended to enable quicker,

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more efficient processing of complaints and promote impartial, fair, and early resolution of
complaints. 57 Fed. Reg. 12,634 (Apr. 10, 1992).
The pre-complaint process under 29 C.F.R. Part 1614 provides aggrieved individuals with vital
information about the whole EEO process, as well as other processes that may be available for
resolution. During the pre-complaint process, the basic facts of concern are gathered and the
bases and issues of concern are identified. In the pre-complaint process, aggrieved individuals
are provided their rights and responsibilities for the entire EEO process. An informal type of
resolution is attempted or the aggrieved individual may choose to participate in the agencys
alternative dispute resolution process.
The pre-complaint process in the federal sector has historically resolved over half of all
aggrieved individuals concerns, resulting in fewer formal complaints filed. The ability to quickly
and efficiently resolve these concerns allows for a more productive environment, less stress in
the work environment, as well as less costs to the federal government.
When efficient resolutions are reached, it is a win-win for both aggrieved individuals and the
government. Individuals can get back to accomplishing the agencys mission. The agency saves
money, time, and maintains a work environment that is less stressful for all of its employees.
Without the pre-complaint process, it is likely that the protracted EEO complaint process will
increase costs and increase stress for the parties.
The historical origins and future of the 45-day time limit for contacting an EEO
counselor
In 1992, EEOC revised the way that federal agencies process administrative complaints; one
revision extended the time limit to contact an EEO Counselor from 30 days to 45 days. Id. at
12,635. In so doing, the Commission explained:
As under part 1613, a person who believes he or she has been retaliated against or
discriminated against on the basis of race, color religion, sex, national origin, age, or
handicap must first seek counseling under part 1614 from the alleged discriminating
agency and file a written complaint with that agency. Proposed part 1614 contained the
same 30-day time limit for contacting a counselor as the existing part 1613 but invited
comments on whether that time period should be enlarged. Many of the non-agency
commenters advocated lengthening the time period to as much as 180 days arguing that 30
days was insufficient to reflect, secure advice or realize the impact of a discriminatory
action, that the relatively short period was screening out many meritorious complaints and
that there should be a symmetry between the private sector time limit for filing a charge
and the federal sector time limit for contacting a counselor. Most, but not all, of the
agency commenters suggested retaining the 30-day limit reasoning that the existing liberal
extension provision adequately protects the rights of federal employees and applicants and
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that any lengthening of the time period would introduce further delays, undermine quick
resolution and result in faded memories, lost documents and unavailable witnesses.
We do not believe that the analogy between the private sector filing period and the federal
sector counseling time limit is apt. Private employees must actually file a complaint within
180 days, not just contact an EEOC office about doing so. Private employees may have to
travel many miles or use the mail to file a charge with EEOC while federal employees only
have to contact a counselor by telephone or often merely visit a counselor who is located
in the same work place in order to comply with the time limit. Moreover, a comparison of
private sector charge filings and federal sector complaint filings indicates that federal
employees file complaints at a rate three times greater than private sector employees file
charges. Further, the earliest possible contact with a counselor aids resolution of disputes
because positions on both sides have not yet hardened. Therefore, we believe a significant
lengthening of the pre-complaint period is not justified. Nonetheless, some potential
complainants may not be able to comply with the 30-day limit for valid reasons.
Consequently, EEOC has decided to modify the time limits for seeking counseling.
In fiscal year 2015, EEOC issued an Advance Notice of Proposed Rulemaking on improving the
federal sector complaint process. 80 Fed. Reg. 6669, https://www.gpo.gov/fdsys/pkg/FR2015-02-06/pdf/2015-02330.pdf. As part of this effort, the Commission asked the public what
time limits should be imposed at various stages of the process, and how many days should a
complainant have to contact a counselor from the date of the alleged discriminatory matter. Id.
at 6671. EEOC plans to utilize this information in preparing a rulemaking process for improving
the federal sector complaint process.

When will complainants and their representatives be able to submit

and access digital documentation related to their cases? (Response
to Question VI)
EEOC File Exchange (EFX)
In fiscal year 2012, EEOC revised its regulations to require federal agencies to submit appellaterelated documentation in digital format to the EEOC Office of Federal Operations. 77 Fed.
Reg. 43,498. EEOC decided as a first step to build a government-to-government web portal for
federal agencies to submit documents in digital form to the Commission, because of the volume
of documents submitted by federal agencies, the security concerns with firewalls, and proper
credentialing of users. This government-to-government web portal became known as the EEOC
File Exchange (EFX), and for a while, it served as the primary vehicle for federal agencies to
submit federal-sector-appellate documents to the Commission.
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Throughout the creation and implementation of EFX, EEOC was aware of the need to provide
a complementary system for complainants and their representatives to make the process more
efficient, fair, and transparent.
Federal Sector EEO Portal (FedSEP)
In fiscal year 2015, building on the foundation established by EFX, EEOC integrated the ability
for agencies to send complaint-related files electronically to EEOC for hearings and appeals into
an online data system, called the Federal Sector EEO Portal (FedSEP). FedSEP initially allowed
agencies to submit their affirmative employment plans (Management Directive 715 reports) and
complaint processing data (Form 462 reports) to EEOC. In fiscal year 2015, the Commission
added two modules to FedSEP, Hearings and Appeals, so that agencies could submit
complaint files for hearings and appellate cases.
In fiscal year 2017, EEOC plans to develop a Complainant Portal as part of FedSEP that will
enable federal sector complainants and their representatives to submit and access digital
documentation related to their cases. Future enhancements to FedSEP will allow two-way
exchanges of documents.

Why does the EEOC use Administrative Judges rather than

Administrative Law Judges? (Response to Question X)
The use of Administrative Law Judges is governed by statute and the regulations of the U.S.
Office of Personnel Management. Under the statutory provisions governing EEOC, the
Commissions present structure does not allow for Administrative Law Judges, and
Administrative Judges do not qualify presently as Administrative Law Judges.

Can EEOC publicly share the status of specific class complaints?

(Response to Question XIII)
Under 5 U.S.C. 552a(b), EEOC is prohibited from disclosing information about the status of
class action cases, except when parties in those cases have given explicit permission that the
information sought be disclosed.

How does EEOC prioritize its backlogs? (Response to Question VII)

Complaints at the hearing stage
EEOC requires the Hearings Units within the Districts to identify aged inventory each new
fiscal year and reduce that inventory as much as possible. To reduce the backlog, the Districts

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will make greater use of Administrative Judge status and settlement conferences; mediations; and
expedited discovery, motion practice, and scheduling for hearings and decisions.
As of August 2016, the oldest complaint is about 4800 days old, a class complaint. The
processing of this case has, consistent with our regulations, involved remands and appeals and is
presently pending rulings on various matters.
There is no target date for hearing a complaint. If there are material facts in dispute, and an
Administrative Judge has received the Report of Investigation, and if the parties are prepared for
a hearing, an Administrative Judge could schedule a complaint for a hearing after the initial
status conference, depending on the Judges calendar and other inventory priorities.
Complaints at the appeals stage
At the appeals level, priority goals are explained in three documents:
The Commissions Strategic Plan for Fiscal Years 2012-2016,
https://www.eeoc.gov/eeoc/plan/strategic_plan_12to16.cfm. This Plan was approved
in February 2012 and established the framework for pursuing EEOCs mission to stop
and remedy unlawful employment discrimination in order to achieve the Commissions
vision of justice and equality in the workplace.
The Commissions Strategic Enforcement Plan for Fiscal Years 2013-2016,
https://www.eeoc.gov/eeoc/plan/sep.cfm. This Plan was adopted in December 2012 to
coordinate EEOCs programs and have a sustainable impact in reducing and deterring
discriminatory practices in the workplace. This Plan identified 6 national priorities as the
focus of an EEOC-wide integrated enforcement effort: (1) eliminating barriers in
recruitment and hiring; (2) protecting immigrant, migrant, and other vulnerable workers;
(3) addressing emerging and developing issues; (4) enforcing Equal Pay laws; (5)
preserving access to the legal system; and (6) preventing harassment through systemic
enforcement and targeted outreach.
Office of Federal Operations and Office of Field Programs Federal Sector Complement Plan to the
Strategic Enforcement Plan,
https://www.eeoc.gov/eeoc/plan/federal_complement_plan.cfm. This Plan describes
how the federal sector will implement the goals of the Strategic Plan and the Strategic
Enforcement Plan in the federal workplace.
As of August 2016, the oldest pending appeal is about 3065 days old. The processing of this
appeal has, consistent with our regulations, involved the issuance of prior decisions and
supplemental investigations, and we are trying to resolve this case as quickly as possible. As of
August 2016, the average age of the pending appellate inventory is 408 days.

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While there is no specific targeted numeric goal in days for deciding appeals, EEOC is mindful
of the need to expeditiously adjudicate appeals and is committed to utilizing its resources as
efficiently and effectively as possible.

What purpose do sanctions serve and how does EEOC decide on an

appropriate sanction? (Response to Questions I & II)
EEOCs authority to issue sanctions
In appropriate circumstances, EEOC may sanction parties for their conduct in the
administrative process. EEOC can issue sanctions because it has been granted, through statute,
the power to issue such rules and regulations that it deems necessary and appropriate to enforce
the prohibition on unlawful employment discrimination. See 42 U.S.C. 2000e-16(b); 29 C.F.R.
1614.108(c)(3); 109(f)(3); 404(c).
Issuing sanctions is discretionary and situational and serves a dual purpose
Issuing sanctions, such as a default judgment in favor of a complainant, is at the discretion of
the Commission, which includes EEOCs Administrative Judges and the Appellate Attorneys in
the Office of Federal Operations. When considering whether to exercise such discretion (and to
ensure that this discretion is not abused), the Commission keeps the following tenets in mind.
Sanctions serve a dual purpose. In one sense, they aim to deter the underlying conduct of the
non-complying party and prevent similar misconduct in the future. In another sense, they
are corrective and provide equitable remedy to the opposing party.
Sanctions should be tailored. Given the dual purpose of sanctions, sanctions should be
tailored to each situation so they deter a non-complying party from similar conduct in
the future and, if warranted, equitably remedy any harm incurred by the opposing party.
Sanctions should not be so severe that they result in inequity, nor should they be so
lenient that they fail to serve as a deterrent. If a lesser sanction would suffice to deter the
conduct and to equitably remedy the opposing party, then imposing a harsher sanction
may constitute an abuse of discretion. 1
To honor these tenets, the Commission must distinguish between conduct that does not warrant
the imposition of a sanction and conduct which does. For example, a complainants failure to
submit a Designation of Representative Form or failure to respond to a notice of the
Administrative Judges intent to issue a decision without a hearing is not the type of conduct
See, e.g, U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION HANDBOOK FOR
ADMINISTRATIVE JUDGES, CHAPTER 6: SANCTIONS (July 1, 2002),
https://www.eeoc.gov/federal/ajhandbook.cfm.
1

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which an Administrative Judge should sanction. 2 But a partys failure to obey an Administrative
Judges order to produce a document during discovery or to expedite an investigation may be
cause for a sanction. 3
EEOCs framework for deciding on an appropriate sanction in a particular case
When tailoring a sanction to ensure that it is warranted for a particular case, the Commission
considers several case-specific factors:
the extent and nature of the non-compliance, and the justification presented by the noncomplying party;
the prejudicial effect of the non-compliance on the opposing party;
the consequences resulting from the delay in justice;
the effect on the integrity of the EEO process. 4
Within this framework of tailoring appropriate sanctions, the Commission has been actively
engaged in ensuring that federal agencies comply with the 29 C.F.R. Part 1614 regulations. The
EEOC Office of Federal Operations published in 2010 a case update, which discussed a
trilogy of appellate decisions that reinterpreted how to evaluate several types of non-compliance
actions when determining the appropriateness of default judgment sanctions. 5
More recently, from October 2012 to May 2016, the Office of Federal Operations (OFO) issued
31 decisions that addressed the appropriateness of sanctions, 21 of which reviewed sanctions
issued by EEOC Administrative Judges. Here are 10 decisions where OFO considered the
appropriateness of sanctions at the appellate stage for various types of agency conduct:
Tammy S. v. Dept of Defense (Defense Intelligence Agency), EEOC Appeal No. 0120084008
(June 6, 2014), https://www.eeoc.gov/decisions/0120084008.txt (sanctioning agency for
delays in processing complaint and conduct of its Office of General Counsel)

Id. (citing Hale v. Dept of Justice, EEOC Appeal No. 01A03341 (December 8, 2000),
https://www.eeoc.gov/decisions/01a03341.txt)
3 Id.
4 See, e.g., Royal v. Dep't of Veterans Affairs, EEOC Request No. 0520080052 (Sept. 25, 2009),
https://www.eeoc.gov/decisions/0520080052.txt; Gray v. Dep't of Defense, EEOC Appeal No.
07A50030 (Mar. 1, 2007), https://www.eeoc.gov/decisions/07A50030.txt.
2

The Sanctions Cases of 2009: Preserving the Integrity of the EEO Process, DIGEST OF EQUAL
EMPLOYMENT OPPORTUNITY LAW, Vol. XXI, No. 1 (Winter 2010),
https://www.eeoc.gov/federal/digest/xxi-1.cfm.
5

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 Shena S. v. Broadcasting Board of Governors, EEOC Appeal No. 0120110117 (Nov. 6, 2014),
https://www.eeoc.gov/decisions/0120110117.txt (issuing default judgment against
agency for its failure to provide OFO with complete complaint file)
Complainant v. Dept of Housing and Urban Development, EEOC Appeal Nos. 0120111827,
0120113765 (July 16, 2014) (issuing default judgment against agency for its failure to
provide OFO with complete complaint file)
Complainant v. Dept of Agriculture, EEOC Appeal No. 0120113592 (June 5, 2013),
https://www.eeoc.gov/decisions/0120113592.pdf (issuing default judgment against
agency for its failure to provide OFO with complete complaint file)
Amina W. v. Dept of Energy, EEOC Appeal No. 0120113823 (Nov. 17, 2015),
https://www.eeoc.gov/decisions/0120113823.txt (issuing default judgment against
agency for its failure to provide OFO with complete complaint file)
Arnoldo E. v. Dept of Justice (Federal Bureau of Investigation), EEOC Appeal No. 0120121034
(Oct. 15, 2015) (declining to sanction agency for 4-month delay in completing
investigation because it had promptly begun the investigation and there was no evidence
of contumacious conduct or bad faith)
Gerald L. v. Dept of Transportation (Federal Railroad Administration), EEOC Appeal No.
0120123187 (Dec. 17, 2015), https://www.eeoc.gov/decisions/0120123187.txt (issuing a
decision partially in favor of complainant with respect to retaliation claim because the
agency failed to provide OFO with a complete record)
Miriam B. v. Dept of State, EEOC Appeal No. 0120132708 (Nov. 24, 2015) (informing
agency that sanctions are possible if agencys supplemental investigation fails to provide
information requested by OFO)
Petitioner v. Dept of Navy, EEOC Petition No. 0420130025 (Feb. 26, 2014) (denying
petitioners request for sanctions against agency for delays in compliance process because
(1) the agency had stayed in contact with petitioner throughout the compliance process
and responded to his concerns in substantial ways; (2) the agency came into full
compliance a little more than four and a half months late, with some of the delay due to
the parties engaging in almost two months of settlement negotiations)
Glynda S. v. Dept of Justice (Federal Bureau of Prisons), EEOC Appeal No. 0120133361(Feb.
23, 2016), https://www.eeoc.gov/decisions/0120133361.txt (issuing default judgment
against agency for issuing a final decision 371 days late)

Why doesnt EEOC impose a minimum form of mandatory

discipline in federal sector cases when it has found a violation of the
anti-employment discrimination laws? (Response to Question IX)
The Commission maintains an interest in determining whether the relief ordered effectively
addresses the violation, including consideration of whether discipline of the people responsible
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for the violation is appropriate. In so doing, the Commission fully utilizes its authority to do so.
Existing authority and Commission precedents provide that the Commissions orders require
agencies to consider discipline against its officials after a finding of discrimination and require
agencies to submit documentation to the Commission demonstrating their reasoning why
discipline was or was not imposed.
Moreover, the Commission leverages the authority of the U.S. Office of Special Counsel (OSC)
to order discipline, as appropriate, when there is a finding of discrimination by referring some
cases for potential enforcement action by OSC. EEOC and OSC first entered into a
Memorandum of Understanding (MOU) in 1988 to enhance enforcement. However, very few
matters were referred pursuant to that MOU. As a result, EEOC and OSC focused on
improving and enhancing enforcement. In 2014, the agencies signed a new Memorandum of
Understanding. 6 Since the implementation of this MOU, EEOC has referred and continues to
refer cases to OSC.

What are compliance reviews, how does EEOC decide whether to

conduct a compliance review, and are these compliance reviews
publicly available? (Response to Questions III & IV)
EEOCs compliance reviews are designed to assess a federal agencys compliance with the
statutes, regulations, and guidance the EEOC is charged with enforcing; they are also designed
to analyze an area of concern within an agency and create an action plan to bring that agency
into compliance.
We consider several factors in determining whether to conduct a compliance review, including:
Does the area of concern affect a strategic enforcement priority?
Does the issue affect a large number of employees?
Has the agency been put on notice and still remains noncompliant?
It has not been our practice to publicize the compliance reviews, but many have become public.
EEOC is currently considering the benefits to making these efforts more public.
In addition to the compliance reviews, we publish lists of non-compliant agencies in our Annual
Report on the Federal Work Force. 7

See Memorandum of Understanding Between U.S. Office of Special Counsel and Equal
Employment Opportunity Commission, https://www.eeoc.gov/laws/mous/eeoc_osc.cfm
7
See, e.g., ANNUAL REPORT ON THE FEDERAL WORK FORCE PART I EEO COMPLAINTS
PROCESSING (FISCAL YEAR 2014), APPENDIX III: FEDERAL AGENCIES PROGRAM STATUS,
https://www1.eeoc.gov/federal/reports/fsp2014/appendix3.cfm; ANNUAL REPORT ON THE
FEDERAL WORK FORCE PART II WORK FORCE STATISTICS (FISCAL YEAR 2011), APPENDIX III:
6

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What has EEOC done when agencies have not implemented nonsexual anti-harassment policies? (Response to Question VIII)
Addressing harassment is a strategic priority issue, which the Commission addresses in the
Strategic Enforcement Plan. 8 The Commission believes that with regard to harassment claims, a
targeted approach that focuses on systemic enforcement and an outreach campaign aimed at
educating employees and employers will greatly deter future violations.
The EEOC Office of Federal Operations has reviewed the anti-harassment policies and
procedures of nearly 200 federal organizations and provided specific feedback on ways the
organizations can improve their efforts. The Office of Federal Operations is taking the
information gained from this effort to conduct a government-wide analysis of anti-harassment
programs.
In June 2016, EEOC Commissioners Chai R. Feldblum and Victoria A. Lipnic presented a
report they had developed after 14 months of studying workplace harassment. 9 The report
includes detailed recommendations and a number of helpful tools to aid in designing effective
anti-harassment policies; developing training curricula; implementing complaint, reporting, and
investigation procedures; creating an organizational culture in which harassment is not tolerated;
ensuring employees are held accountable; and assessing and responding to workplace risk
factors for harassment.

FEDERAL AGENCIES PROGRAM STATUS,

https://www1.eeoc.gov/federal/reports/fsp2011_2/appendix3.cfm.
8
The Commissions Strategic Enforcement Plan for Fiscal Years 2013-2016,
https://www.eeoc.gov/eeoc/plan/sep.cfm.
9
See REPORT OF THE CO-CHAIRS OF THE EEOC SELECT TASK FORCE ON THE STUDY OF
HARASSMENT IN THE WORKPLACE (June 2016),
https://www.eeoc.gov/eeoc/task_force/harassment/upload/report.pdf.
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