Report 2021-104 Recommendation 12 Responses

Report 2021-104: Metropolitan Water District of Southern California: Its Leadership Has Failed to Promote Transparency or Ensure a Fair and Equitable Workplace (Release Date: April 2022)

Recommendation #12 To: Metropolitan Water District of Southern California

To prevent and address mistreatment of complainants and potential violations of its retaliation policy, by October 2022 MWD should do the following:

- Develop written procedures for identifying and intervening in potential retaliation while EEO investigations are ongoing.

- Dedicate a person to follow up with complainants after EEO investigations to ensure that incidents involving potential retaliation are not occurring, as well as track these follow-up discussions.

6-Month Agency Response

Metropolitan developed the EEO Complaint and Investigative Procedures, which includes the process for identifying and intervening in potential retaliation while EEO investigations are ongoing, guidance for reporting retaliation, monthly communication with involved parties during an investigation, and post investigation follow-up communication. These are also included in the H-07 (Equal Employment Opportunity) policy.

The Deputy Chief EEO Officer is responsible for ensuring following up with complainants during and after EEO investigations to determine whether or not incidents involving potential retaliation are occurring.

The EEO Procedures include guidance for reporting retaliation, monthly communication with involved parties during an investigation, and post investigation follow-up communication with complainants.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

We reviewed MWD's revised procedures and the job description of the Deputy Chief EEO Officer to confirm that they contain the required elements of the recommendation.

60-Day Agency Response

Metropolitan is developing written procedures for identifying and intervening in potential retaliation while EEO investigations are ongoing. These are included in the H-07 policy and further guidelines will be outlined in EEO investigation procedures.

The new EEO Section Manager is responsible for following up with complainants after EEO investigations to ensure that incidents involving potential retaliation are not occurring, as well as tracking these follow-up discussions.

California State Auditor's Assessment of 60-Day Status: Pending

The job description MWD provided for the EEO Section Manager does not address responsibilities for following up with EEO complainants to address potential retaliation. We informed MWD of this and will reevaluate this recommendation's status in October 2022.

All Recommendations in 2021-104

Agency responses received are posted verbatim.