Well, it sounds like you have a very complex problem. I would approach this one more time with upper management. Give them a brief overview of Title VII if needed. Explain what the term "harassment" and "hostile working environment" means. Show them how this term (and I'm sure you have other examples as well) could be construed as harassment (if you truly think it can). Explain the dangers of not reacting to an employee who complains about such harassment and explain the necessity of establishing an affirmative defense. Do some research and show them the sums of money that have been paid out in damages. Then, suggest solutions. Recommend changes to the EEO policy (if needed) and suggest EEO training for everyone (and especially for supervisors).
I would do this once. If they still don't get it, I would just try to find opportunities to suggest improvements as you go along. It sounds like the organization is in need of a cultural change, and that doesn't happen overnight. I think all you can do is continue giving them the facts, and show them how it can affect the bottom line (not to mention employee morale).
I'm curious - does your bank issue savings bonds and if so, do you have an affirmative action plan? What is management's opinion on the AAP?