FBI MULTI-YEAR AFFIRMATIVE EMPLOYMENT PROGRAM PLAN FY 1988 - FY 1992

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Document Number (FOIA) /ESDN (CREST): 
CIA-RDP90-00530R000801890001-0
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RIFPUB
Original Classification: 
K
Document Page Count: 
94
Document Creation Date: 
December 23, 2016
Document Release Date: 
October 4, 2012
Sequence Number: 
1
Case Number: 
Publication Date: 
September 2, 1988
Content Type: 
REPORT
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Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 0 c. ? ?.7 ? ? ? ? ? ? ? FBI MULTI-YEAR AFFIRMATIVE ?EMPLOYMENT PROGRAM PLAN FY 1983 - FY 1992 September 2, 1988 Frank: I have been advised by our agency's EEO Officer that while the attached plan has been signed by the Director, the Bureau has not received written approval by the U.S. Department of Justice. e- n N. Meisten III Assistant Personnel Officer FBI . Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN MULTI-YEAR AFFIRMATIVE EMPLOYMENT PROGRAM PLAN 1988-1992 FEDERAL BUREAU OF INVESTIGATION 9th Street and Pennsylvania Avenue Washington, D. C. 20515 ORGANIZATIONAL LEVEL: Bureau NUMBER OF EMPLOYEES COVERED BY PLAN: TOTAL: 22,477* Professional - 188 Administrative - 11,092 Technical - 3,388 Clerical - 6,961 Other - 848 Barbara B. Browning 324-4128 Telephone number Contact person %*6A17/191* signatu d te Melvin L. Jeter Equal Employment Opportunity Officer Certifies that this plan is in compliance with EEO-MD-714 as mod.,fied by the Department of Justice 2 itiA/ igek signature date William S. Sessions Director Certifies that this plan is in compliance with EEO-MD-714 as modified by the Department of Justice *9/30/87, based on statistics in Fiscal Year 1987 update Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 TABLE OF CONTENTS INTRODUCTION 1 FBI POLICY STATEMENT 2 ORGANIZATIONAL CHARTS ? CERTIFICATION OF QUALIFICATIONS OF EEO OFFICIALS PLAN FOR PREVENTION OF SEXUAL HARASSMENT STATEMENT OF ADEQUATE MONITORING/ EVALUATION SYSTEM ? ? ? ? ? ? ? I/ ORGANIZATION AND RESOURCES Program Analysis Problem/Barrier Identification Report of Objectives and Action Items 4 5 6 7 WORK FORCE 8 DISCRIMINATION COMPLAINTS 9 Program Analysis Problem/Barrier Identification Report of Objectives and Action Items RECRUITMENT AND HIRING Program Analysis Problem/Barrier Identification Report of Objectives and Action Items EMPLOYEE DEVELOPMENT PROGRAMS Program Analysis Problem/Barrier Identification Report of Objectives and Action Items PROMOTIONS Program Analysis Problem/Barrier Identification Report of Objectives and Action Items SEPARATIONS Program Analysis Problem/Barrier Identification Report of Objectives and Action Items 10 11 12 13 PROGRAM EVALUATION 14 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 INTRODUCTION The FBI operates a centralized personnel management system from FBI Headquarters (HQ), Washington, D. C. Under this system, ? all basic personnel policy applicable throughout the service is approved and implemented from FBIHQ, and the system is geared to achieve uniformity throughout our organization. Special Agents in Charge (SACs) of field offices have been delegated authority to apply the Bureau's personnel management system, and we do not have servicing personnel offices at each field 41 installation. Personnel actions of all sorts originate and are recommended by SACs, but must be in accordance with Bureau regulations, as well as reviewed and approved at FBIHQ. These actions include appointments, promotions, demotions, disciplinary and adverse actions, position classification and organization structuring. ? All positions in the FBI are in the excepted service and each field office is structured almost identically, deviating only in numbers of personnel in the various grade levels. There are no autonomous organizational structures either geographically or functionally in the FBI. Communication between FBIHQ and our field divisions is on a constant and continuing basis. In view of the FBI's highly centralized personnel management system, which controls all major FBI personnel actions, the assignment of each Special Agent (Criminal Investigator - Series 1811) to any of our 58 field offices is determined by FBIHQ ? according to the needs of the Bureau. Therefore, minority/gender data for the individual field offices does not reflect an office's efforts in the area of recruitment. Also, recruitment for the Special Agent position as well as all FBIHQ support positions is done on a national level by all field offices. Additional information on recruitment is in the program analysis section. Accordingly, one report, Affirmative Employment Multi-Year Program Plans for Fiscal Years 1988 - 1992, has been developed for the entire FBI. Work force data is based on statistics at the end of Fiscal Year 1987 (September 30, 1987) reflecting the categories of Professional, Administrative, Technical, 41 Clerical and Other (PATCO) and one tabulation by grade level. This plan pertains to the two major operating components (FBIHQ and field offices) within the FBI organizational structure, which are both controlled on a national level through the FBI's centralized personnel management system. ? Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Declassified and Approved For Release 2013/10/24 : CIA-RDP90-00530R000801890001-0 In accordance with the previous multi-year plan and Department of Justice guidance, numerical goals and timetables are not established in the Plan. Statistical data continues to be compiled on a monthly basis as a means of monitoring and our field offices are continually kept aware of the recruitment of women and minorities through the inspection process and annual performance evaluation of the critical elements of Affirmative Action and Applicant Recruitment for Special Agent in Charge. Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 FBI POLICY STATEMENT EQUAL EMPLOYMENT OPPORTUNITY AND FEDERAL AFFIRMATIVE EMPLOYMENT PLANS As Director of the FBI, it is my sincere intention AF to carry out the laws and support the principles of Equal Employment Opportunity and the Affirmative Recruitment Program Plans. I am aware of the emphasis placed on hiring and strides made by the FBI in the recruitment of women and minorities, particularly among the Special Agent ranks. Working together with the various levels of management, I strongly support the ? initiatives pertaining to affirmative recruitment and to increase the number of minorities and women in managerial and supervisory positions among Special Agents and support personnel. In addition, I want tc express my unequivocal support of equal opportunity in all personnel actions, and the entitlement AP of all employees to work in a professional environment, free from harassment. Discrimination on the basis of race, color, religion, national origin, sex (including sexual harassment), age, and handicap (mental or physical) is unlawful. I hereby mandate every member of my management team to actively support these principles. While management sets the tone, it is ? incumbent upon each employee of the FBI to adhere to the spirit and intent of laws pertaining to Equal Opportunity while fulfilling his/her responsibil ies. ? ? ? ? ? William S. Sessions Director Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 ? ? a a a a a a a Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 U.S. Department of Justice ? Federal Bureau of Investigation ? ? Organization of the FBI DIRECTOR EXI:CLITIVE ASSISTANT DIRECTOR. LAW ENFORCEMENT SERVICES IDENTIFICATION DIVISION TRAINING DIVISION LABORATORY DIVISION EXECUTIVE ASSISTANT DIRECTOR. ADMINISTRATION 1 OFFICE OF CONGRESSIONAL AND PUBLIC AFFAIRS LEGAL COUNSEL DIVISION ADMINISTRATIVE SERVICES DIVISION RECORDS MANAGEMENT DIVISION FIELD OFFICES TECHNICAL SERVICES DIVISION EXECUTIVE ASSISTANT DIRECTOR. INVESTIGATIONS INSPECTION DIVISION INTELLIGENCE DIVISION OFFICE OF LIAISON AND INTERNATIONAL AFFAIRS CRIMINAL INVESTIGATIVE DIVISION ALBANY II CHARLOTTE 21 HOUSTON 2 ALIWOUENDUE 12 MOM 22 OWIANAPOLIS 43 ALE PUMA 13 CINCINNATI 23 JACKSON 4 ANCHONAGE 14 CLEVELAND 24 JACKS/MLLE S ATLANTA 15 COLUMMA 25 KA/GAS PTV SAL MORE 16 DALLAS 26 KNOXVILLE DAMeiGNAM 1/ COMM 22 LAS OCAS II BOSTON III Nom 211 LIME ROC* s suITALO II Et PASO 29 LOS ANGELES 10 WM 20 HONOLULU 30 LOWSVILE 53 55 14 20 ?4. 35 2 *Field Offices consolidated, now Washington Metropolitan 30A Field Office. Revised Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R0008018900011-6 -rts forthcoming. 37 31 MEMPHIS 41 OKLA/01A OTT 51 SAN ANTC440 36 33 Mt WAUKEE 43 ha ADE111114 5523 USA: faIRACISCO 39 32 MINS 42 Swum 3 S9 354 mostIANNEEAPOUS 4494 nlVerissimei141 s554 SAN KAN SAVANNAH 40 36 NEWARK 46 PORTLAND St SEATTLE 37 NEW HAVEN 4/ 110111040 57 SPRWGWELD 31 NEw mums 48 SACRAMENTO SS TAMPA 431 NEW YO 49 ST LOWS * 59 wAsiacialtoc 0 swoL,RK 00 SALT LAO CITV a a a a a a? Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 a DEPARTMENT OF JUS'TICE FEDERAL BUREAU OF INVESTIGATION OFRCE OF LEGAL COUNSEL ATTORNEY GENERAL DEPUTY ATTORNEY GENERAL ?MCI OF LEGAL POUCY OIFRCE OF INTELLIGENCE POLICY AND REVIEW OFRCE OF FROFESSIONJU. RESPONSIMUTT ASSOCIATE ATTORNEY GENERAL Vo??????1?mor EXECUTIVE OCE U.S. ATTOMIFfS DRUG ENFORCEMENT ADNINISTRA- TION OFRCE OF LEGISLATIVE AND WIER- GOVERNMENTAL, AFFAIRS ? JUSTICE MANAGEMENT DIVISION OFRCE OF PUSUC AFFAIRS FOR ???????? MNAL BUREAU OF PRISONS IMIOGRATION AND NATURAL- IZATION SERVICE CIVIL RIGHTS DIVISION UM AND NATURAL RESOURCES DIVISION TAX DWISION FEDOULL. PRISON INDUSTRIES. INC. U.S. ATTORNEYS U.S. MARSHALS SERVICE ?OFFICE OF JUSTICE PROGRAMS U.S. NATIONAL CENTRAL BUREAU INTERPOL PMDON ATTORNEY U.S. PAROLE COMMISSION EMCUIVE OFRCE FOR IMMIGRATION REVIEW COMMUNITY NEURONS SERVICE EXECUTIVE OFRCE FOR U.S. TRUSTEES FOREIGN CLAM SETTLEMENT COMMISSION U.S. TRUSTEES ?FORMERLY OFFICE OF JUSTICE ASSISTANCE, RESEARCH, AND STATISTICS Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 ? ? AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN ? CERTIFICATION OF QUALIFICATIONS OF EEO OFFICIALS I certify that the qualifications of all staff officials, responsible for the administration of the EEO program, including the EEO Officer, Deputy EEO Officer, Black Affairs Program, Hispanic Employment Program, Selective Placement Program (handicapped program) and Federal Women's Prcgram Managers have been reviewed by competent authority and incumbents of these positions meet standards outlined in Qualifications Standards Handbook X-118 under "Equal Employment Opportunity Specialist GS-260." Evidence that the review has been made and its findings are on file and available for review by EEOC officials. I further certify that the provisions of FPM Letter 713-37, "Documenting EEO Collateral Duties in Official Position 41 Descriptions" have been met, initially by memorandum dated April 14, 1978, which was recently updated. ? ? ? S ? David Rarity, Dat Personnel Off' er Administrati e Services Division Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN PLAN FOR THE PREVENTION OF SEXUAL HARASSMENT POLICY STATEMENT The FBI is committed to providing a woxic environment free of sexuaa harassment. An official statement of the Department's policy was initially issued by the Assistant Attorney for Administration, Department of Justice on February 4, 1980. This communication'was disseminated to all employees and subsequently used as a handout with lectures pertaining to equal employment opportunity and sexual harassment. Sexual harassment is defined as any deliberate or repeated unsolicited oral or written comment, statement, anecdote, gesture, physical contact, display of books, magazines or pictures of a sexual nature that are offensive and unwelcomed. A supervisor who uses implicit or explicit coercive behavior to control, influence, or affect the career, salary or job of an employee by any one of the above-mentioned modes is engaging in sexual harassment. Any employee who engages in conduct of this nature is not only interfering in the work productivity of the Department but also undermines the integrity of the employment relationship. All employees should be allowed to work in an environment free from unsolicited and unwelcomed sexual overtures. Abuse of this right impedes morale and the merit system itself. At the same time, the Department of Justice does not intend to regulate the social interaction or relationships freely entered into by its employees., FBI Director William S. Sessions' policy statement to all employees, "Equal Employment Opportunity and Federal Affirmative Employment Plans" dated January 5, 1988, included sexual harassment as an unlawful basis of discrimination. He expressed unequivocal support of equal opportunity in all personnel actions, and the entitlement of all employees to work in a professional environment. Complaints of sexual harassment in the work place may be filed under 29 Code of Federal Regulations (CFR) Part 1613 and are cognizable under Title VII of the Civil Rights Act of 1964, as amended. ISSUANCE OF APPROPRIATE SANCTIONS: The FBI's Manual of Administrative Operations and Procedures (MAOP) contains information that sexual harassment is a basis ? to file a complaint of discrimination. Procedures to file ? Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 9 ? Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 PLAN FOR THE PREVENTION OF SEXUAL HARASSMENT - PAGE 2 a complaint, authority of the Equal Employment Opportunity Commission and Justice Departmental Orders are also cited in the MAOP. ? TRAINING MANAGERS/SUPERVISORS/EMPLOYEES: The definition of sexual harassment and examples to generate discussion are presented at lectures by the EEO Officer, Deputy EEO Officer and Special Emphasis Program Managers. FBI managers and supervisors who attend special training courses such as ? the Management Aptitude Program (Agents entering mid-level management positions), the Executive Development Institute (CS 15 and above) and support personnel who attend management training in-services and seminars are provided with information on sexual harassment and are provided handouts for future reference. ? OTHER ACTIONS: a. An explanation of sexual harassment and how to seek redress has been included as a part of the orientation of new support employees and Special Agents. ? b. The EEO Complaint Report submitted monthly to the Department of Justice includes bases for complaints. Monitoring of this report provides various levels of management an opportunity to observe the basis of each case and keep abreast of the need to address sexual harassment through increased training or consider other factors if a trend is indicated. Ib c. Significant court cases (including sexual harassment issues) are reviewed by the Legal Counsel Division to determine impact, if any, on the FBI and its policies and procedures. A synopsis is prepared for the Director and upper-level ? management with dissemination as appropriate to the area of interest in the event policy review and subsequent change is indicated. ? d. Additional visual aids (video cassettes) will be utilized to enhance the training pertaining to EEO issues. The vignettes include a module on sexual harassment which further explain the perceptions surrounding sexual harassment and behaviors that may give rise to complaints. e. The Inspection Staff conducts on-site inspections periodically which include a review of the entity's EEO program for compliance with instructions issued by FBIHQ and the Department of Justice. Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 0 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 UNITED STATES GOVERNMENT Memorandum TO : Department of Justice Employees FROM : Kevin D. Rooney Assistant Attorney General for Administration StiaTECT: Sexual Harassment FEB 04 1980 DATE: - Although there has been, no evidence of widespread sexual harassment within the Department of Justice, the recent Congressional and public attention given to this problem necessitates clarification of the Depart- ment's position. Sexual harassment is unacceptable conduct in the workplace and is a prohibited personnel practice as outlined in the Civil Service Reform Act of 1978 (5 U.S.C. 2302). Any employee conduct which violates this code will not be condoned. Sexual harassment is defined as any deliberate or repeated unsolicited oral or written comment, statement, anecdote, gesture, physical contact, display of books, magazines or pictures of a sexual nature that are offensive and unwelcomed. 41 Within this Department, a supervisor who uses implicit or explicit coercive behavior to control, influence, or affect the career, salary or job of an employee by any one of the above-mentioned modes is engaging in sexual. harassment. Any employee who engages in conduct of this nature Is not only interfering in the work productivity of the Department but also undermines the integrity of the employment relationship. All employees should be allowed to work in an environment free from unsolicited and unwelcomed sexual overtures. Abuse of this right impedes morale and the merit system itself. At the same time, the Department of Justice does not intend to regulate the social interaction or relationships freely entered into by its employees. In the very near future, the Merit Systems Protection Board (MSPB) will be conducting a government-wide survey to ascertain the extent, of this problem so as to devise corrective measures to halt it. . Complaints of such harassment should be directed to EEO counselors, Federal Women's Program Managers or other appropriate officials. These complaints will be examined impartially and resolved promptly. ? ? Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan '21 Mir D0114miwn Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Form 080-197 5-79 Declassified and Approved For Release 2013/10/24: CIA-R6P90-00530R000801890001-0 " ? -13 ? ? ? ? ? ? ? ? Federal Bureau of Investigation Washington, D.C. 20535 January 5, 1988 MEMORANDUM TO ALL EMPLOYEES RE: EQUAL EMPLOYMENT OPPORTUNITY AND FEDERAL AFFIRMATIVE EMPLOYMENT PLANS As Director of the FBI, it is my sincere intention to carry out the laws and support the principles of Equal Employment Opportunity and the Affirmative Recruitment Program Plans. I am aware of the emphasis placed on hiring and strides made by the FBI in the recruitment of women and minorities, particularly among the Special Agent ranks. Working together with the various levels of management, I strongly support the initiatives pertaining to affirmative recruitment and to increase the number of minorities and women in managerial and supervisory positions among Special Agents and support personnel. In addition, I want to express my unequivocal support of equal opportunity in all personnel actions, and the entitlement of all employees to work in a professional environment, free from harassment. Discrimination on the basis of race, color, religion, national origin, sex (including sexual harassment), age, and handicap (mental or physical) is unlawful. I hereby mandate every member of my management team to actively support these principles. While management sets the tone, it is incumbent upon each employee of the FBI to adhere to the spirit and intent of laws pertaining to Equal Opportunity while fulfilling his/her responsibilities. William S. Sessions Director 1-5-8E tabet. MEMORANDUM TO ALL EMPLOYEES 1-88 Nopk, ? Bicentennial of the United States Constitution (1787.1987) FBI/DOJ Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 41 AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN STATEMENT OF ADEQUATE MONITORING/EVALUATION SYSTEM Monthly, a memorandum is prepared in the Office of EEO Affairs ? which shows the number of Black, Hispanic, American Indian, Asian American, and male/female employees (Special Agent and support personnel). Gain or Loss since the previous month and since date of Director Sessions' oath of office are indicated. This means of monitoring indicates the status of the FBI's workforce profile and is disseminated to the Director, Executive ? Assistant Directors, Assistant Director, Administrative Services Division, National Applicant Recruiter and Unit Chief of the Special Agent and Support Applicant Unit. Upon request, it is provided to approved Bureau speakers making presentations to various educational institutions, social and civic organizations and press releases. Semiannually and upon request, this information ? along with statistical data by grade level of Special Agents in the Career Development Program from entry level (Relief Supervisors) through super grade positions is updated for the Director and upper level management. The Career Board frequently requests this data to supplement information which they routinely receive. Annual reports regarding statistical accomplishments ? and initiatives instituted are reported to the Department of Justice (DOJ) for inclusion in the DOJ's report to the Equal Employment Opportunity Commission (EEOC). ? With respect to statistical data and program accomplishments the following means of review for compliance are in effect: a. Inspections of field offices and headquarters divisions are conducted which include an audit checklist for compliance with EEO regulations. b. Reports prepared by the Office of EEO Affairs for the ? Inspection Staff prior to the on-site inspection include the following: ? ? 1. Recruitment statistics of Special Agents over the past twelve months indicating race, national origin and gender compared against the relevant administrative Civilian Labor Force for the locale are provided. 2. The composition (race, national origin and gender) of the support staff compared against the clerical Civilian Labor Force for the locale are provided. 3. Number and nature of EEO complaints pending in the office being inspected is provided. Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 S Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 STATEMENT OF ADEQUATE MONITORING/EVALUATION SYSTEM - PAGE 2 4. The identity of EEO Counselors and Upward Mobility Counselor based on FBIHQ records is provided. C. In addition to the Office of EEO Affairs providing information for the inspection of all entities, the Office of EEO Affairs is inspected every two years. d. The Annual Accomplishments Report to the Attorney General includes Affirmative Action accomplishments. ? e. Participation by the EEO Officer and/or EEO Program Managers in meetings such as the Career Board's annual planning session where problem areas are discussed and plans are ? made for policy and/or procedural changes. (Statistical reports are presented by the Office of EEO Affairs and women and minorities are in attendance to ensure any specific 41 concerns are made known.) ? 41 ? f. Independent of the Office of EEO Affairs, each Assistant Director reports quarterly to the Executive Assistant Director, Administration, the statistics for the respective division in a memorandum captioned Minority and Female Special Agents, Promotional Opportunities at FBI Headquarters. The table indicates the number and percentage of change over a given period among minority and women Supervisory Special Agents. g? On-site reviews are conducted by the EEOC. h.. Micro computers will become operational in the Office of EEO Affairs office space over the -next few months. Although the EEO Program is currently supported by automated statistical data on the workforce profile, the Personal Computer Advanced Technology (PCAT) will provide access to the main frame for personnel information, the capability to update training information, to develop a program to record complaint information in an automated format, to generate special reports, to promptly retrieve data and to enhance the word processing system. i. Accountability for Affirmative Action/Equal Employment 41 Opportunity through annual performance evaluation of a separate critical element for managers covered by the Executive Performance Appraisal System (GS 16 and above). ? Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 S ? 10 Declassified and Approved For Release 2013/10/24: CIA-RDP90-00530R000801890001-0 AFFIRMATIVE EMPLOYMENT PROGRAM FOR MINORITIES AND WOMEN PROGRAM ANALYSIS ORGANIZATION AND RESOURCES The Office of Equal Employment Opportunity Affairs (OEEOA) is an integral part of the FBI's management structure. It is located at FBI Headquarters, Washington, D. C., in the Administrative Services Division. The office is under the direction of a Unit Chief, who also serves as the FBI's EEO Officer and reports directly to the Assistant Director, Administrative Services Division. It was intentionally organized independent of the Personnel Officer and personnel entities to avoid any perception of a conflict of interest. As a component of the Administrative Services Division, the OEEOA is included in the division's budget decision unit within the FBI funding structure. Funds are provided on an as requested basis for EEO staff training, special emphasis program expenses, travel, program development and implementation. The EEO function and activities have not been financially constrained. Program needs have been adequately funded to meet program requirements and enhancements. The OEEOA is staffed by a complement of nine full-time employees. They receive assistance in program implementation through Special Emphasis Program Coordinators in 14 major field offices. The Special Emphasis Programs consist of Black Affairs, Hispanic Employment, Federal Women's Program and Selective Placement ? Program (handicapped). ? ? ? As of September 30, 1987, the FBI workforce totaled 22,477. Each organizational entity (field office or headquarters division) is required to have a minimum of two trained (through the Office of Personnel Management, Basic EEO Counseling Course) EEO Counselors who are not serving in a supervisory or managerial role. The distribution of EEO Counselors within the FBI exceeds the initial rule of thumb which suggested that agencies designate at least one EEO Counselor in every major installation of 50 or more employees. Over 400 Special Agent and support personnel have received training to serve as EEO Counselors. Of these, because higher level managers and supervisors (SACs, Assistant SACs, Deputy Assistant Directors and Unit Chiefs) are ineligible to be utilized