Is there a requirement to have a policy regarding HR submitted to the Board of Directors that outlines their stance and/or committment to ensuring the ADA, Affirmative Action and other such items are followed by the HR department? This end of the business is new to me and I'm not sure whether we are required to have one. Currently we have a policy statement about ADA but nothing about Sexual Harrassment, EEO, etc. There is a statement in the Employee Handbook from the President of the Bank stating the company is dedicated to the princiles of the ADA...but nothing else. Is that sufficient to satisfy any regulatory requirement that may exist?

The HR policy has less to do with the Board and more to do with insurance coverage and law suits. The HR policy should be reviewed by a qualified attorney to assure that the policy statements cover all of the areas, including Sexual Harrassment.

With that said, I'm not sure if there are any regulatory requirements covering specific statements that must appear in the HR policy, but I do know that an HR policy is required by regulators in a start up bank environment. Insurance companies regularly ask if specific issues are covered, including Sexual Harrassment and actually review that policy when HR issues are incorporated within the coverage.

The only policy that our board reviews on a regular basis is our affirmative action policy -