Equal Employment Opportunity Policy Statement

PIM 2021-008
Permanent Instruction Memorandum

http://web.blm.gov/internal/wo-600/610/design_standards/images/blm_09tri_bw.jpgUnited States Department of the Interior


Grand Junction, Colorado 81506


July 29, 2021


In Reply Refer To:

1400-735 (130) P



Permanent Instruction Memorandum No. 2021-008


To:                  All BLM Employees

From:              Deputy Director, Operations

Subject:           Equal Employment Opportunity Policy Statement

Program Area: Civil Rights and Equal Employment Opportunity.

Purpose: This Permanent Instruction Memorandum reissues the Bureau of Land Management’s (BLM) Equal Employment Opportunity (EEO) policy.

Policy/Action: The U.S. Department of the Interior (DOI), BLM, is committed to ensuring a work environment free of and from discrimination (including harassment) in all its activities, programs, and operations. Our goal is to foster a workplace that is equitable, provides equal opportunities for all, embraces diversity, and ensures all employees feel valued and included.

BLM employees and applicants for employment are covered by Federal laws designed to safeguard Federal employees and job applicants from discrimination on the basis of race, color, religion, sex (including pregnancy, gender identity, and sexual orientation), national origin, age (40 or older), disability, genetic information (including family medical history), and reprisal for protected EEO activity.  These protections extend to all management practices and decisions, including recruitment and hiring, appraisal systems, promotions, training, and career development programs. Consistent with these obligations, the BLM also provides reasonable accommodations to employees and applicants with disabilities and for sincerely held religious beliefs, observances, and practices.

Our policy is intentionally firm, and it requires all BLM employees (including students, interns, volunteers, as well as contractors who perform services for the BLM) to avoid any and all behaviors, actions, and conduct that could be deemed discriminatory. All leaders, managers, supervisors, and employees are encouraged to visit the U.S. Equal Employment Opportunity Commission’s (EEOC) webpage on Discrimination by Type and seek to gain a better understanding of all the protections afforded by Title VII of the Civil Rights Act of 1964, as amended, and all other applicable statutes.

Our employees are truly our most precious resources. They are entitled and expected to work in an environment that not only adheres to the laws of the land but also welcomes and embraces the uniqueness of diverse groups from all corners of the world. Accountability starts with BLM’s Executive Leadership Team (ELT). This matter is a top priority for the entire ELT, and it must also be a top priority for all our leaders throughout the Bureau. Managers and supervisors have the responsibility to take appropriate action to include disciplinary and adverse actions (reprimand, suspension, and/or removal from Federal service) for any person(s) found to have committed discrimination. It is expected that all allegations of discrimination be brought to the immediate attention of your respective EEO Office. We have a team of professionals who stand ready to assist and address questions and concerns or guide you through the EEO process.

If any employee believes they have been subjected to discrimination, they must contact the EEO Office or an EEO Counselor and present the claim(s) within 45-calendar days of the action or becoming aware of the alleged discriminatory action. Where an individual has expressed a desire to initiate the EEO complaint process, EEO Managers will ensure that the EEO process is initiated within three (3) business days of an aggrieved person presenting a claim of discrimination. EEO Managers will also provide general information on other avenues of redress available to employees where an employee determines EEO is not applicable to their issue(s) of concern.

All informal complaints will be addressed promptly, thoroughly, and impartially via EEO counseling or Alternative Dispute Resolution (ADR). If the issues are not resolved during the informal phase, a Notice of Final Interview and Right to File a Formal Complaint is issued, and the counselee, upon receipt of the notice, will have 15 calendar days to file a formal EEO complaint. All formal complaint claims that are accepted are investigated by EEO Investigators who are neutral and external to the BLM. Investigations are quite extensive and are expected to be completed within 180 days from the date the complaint was filed unless the complainant agrees to an extension. All Federal employees are required to participate during the EEO complaint process and must be responsive to EEO Officials, Counselors, and Investigators and must comply with requests for cooperation put forth by the BLM Office of Civil Rights (OCR). Furthermore, management officials who are named and accused of allegedly discriminating against an employee must ensure they respond to official inquiries without delay and demonstrate full cooperation throughout the entire EEO process.

Reprisal for participating in the EEO process or for otherwise opposing discrimination is strictly prohibited and will not be tolerated. If retaliation is found, the BLM will take the appropriate corrective and disciplinary action.

This BLM EEO policy statement aligns with the spirit and the intent of Personnel Bulletin 18-01 (PB 18-01) issued by the Department. To that end, we recommend you familiarize yourself with PB 18-01, which seeks to prevent and prohibit all forms of workplace discrimination, retaliation, and harassing conduct based upon an individual’s protected status, regardless of whether the conduct violates the law. PB 18-01 requires that managers and supervisors take prompt and effective remedial action in response to unlawful discrimination/retaliation and harassing conduct, including the use of appropriate non-disciplinary or disciplinary action, up to and including removal from Federal service. All BLM employees are expected to read and adhere to PB 18-01.

There are distinct differences between the Prevention of Harassment Program (POHP) and the EEO process. The POHP seeks to eliminate harassing conduct, regardless of whether such conduct violates the law. The EEO process is designed to conduct investigations into allegations of discrimination for the purpose of determining whether unlawful discrimination occurred. The BLM Servicing Human Resources Offices have oversight over all non-EEO related harassment matters.

It is also important to highlight that the EEO process allows for limited confidentiality. During the informal phase, an employee may elect to remain anonymous. However, should the complaint proceed to the formal phase, confidentiality cannot be maintained. EEO Officials will take the necessary steps to keep complaints of discrimination confidential to the greatest extent possible but there are times when information will be shared with agency officials who have a need-to-know. In accordance with EEOC guidance, all allegations of harassment presented to EEO personnel are immediately reported to POHP personnel. No anonymity is provided in the POHP process. According to Section 8.A. of PB 18-01: Management must take action to investigate all allegations of harassing conduct, even if the employee raising the allegation requests confidentiality. All reports of harassing conduct and related information will be maintained on a confidential basis to the greatest extent possible. The identity of the employee alleging violations of this policy will be kept confidential, except as necessary to conduct an appropriate investigation into the alleged violations, to take appropriate disciplinary or corrective action, to comply with the reporting requirements of this policy, or when otherwise required by law.

We also recommend that all managers, supervisors and employees take the time to familiarize themselves with the DOI Reasonable Accommodations and Personal Assistance Services policies. The BLM will provide reasonable accommodation for the known physical and intellectual limitations of qualified employees and applicants with a disability unless the accommodation imposes an undue hardship to the Agency. Additionally, the BLM will provide Personal Assistance Services to employees who, because of targeted disabilities, require such assistance during work hours or in order to participate in work-related travel.

Please refer to the Required BLM Training SharePoint site for information on mandatory EEO training requirements and how these requirements can be met. Training programs to help managers, supervisors, and employees meet the mandatory EEO training requirements will be offered regularly by BLM OCR and EEO personnel, as well as in courses available via DOI Talent.

Our agency embraces a work environment that values diversity and fosters mutual respect, tolerance, cooperation, inclusiveness, and equity for all. EEO is an integral component of sound leadership principles that are essential to mission accomplishment. Managers and employees are highly encouraged to use ADR whenever possible as a means of openly discussing workplace disputes and possibly resolving complaints at the lowest levels.

Budget Impact: None.

Background: In accordance with 29 CFR § 1614, the EEOC requires Federal agencies to issue an EEO Policy Statement to all employees on an annual basis. 

Manual/ Handbook Sections Affected: None.

Instruction Memorandums Affected:  This PIM supersedes IM 2018-101, Equal Employment Opportunity (EEO) Policy Statement.

Coordination: This PIM was coordinated by the BLM Office of Civil Rights, HQ 710 Division of Human Resources Policies and Programs and with Senior Leadership.

Contact: All general questions related to EEO policies should be directed to your servicing EEO Office. Should you have questions regarding this PIM, contact La Shon D. Cole, Director, Office of Civil Rights, at lcole@blm.gov or (602) 906-5537.



Signed by:                                                       Authenticated by:      

Michael D. Nedd                                            Brianna Huerta          

Deputy Director, Operations                          Division of Regulatory Affairs

and Directives, (HQ-630)    

Fiscal Year