Background Information:

The Security Exchange Commission (SEC) established the Office of Minority and Women Inclusion (OMWI) in July of 2011, as required by Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  OMWI is responsible for all matters related to diversity in management, employment and business activities at the SEC. The SEC joined with other federal financial regulators in issuing the “Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies” (Joint Standards) in a final interagency policy statement dated June 10, 2015.  (https://www.sec.gov/page/omwi-section-landing). As a result, an auditing process and self-assessment was developed to assess all regulated entities, including Whitley Mortgage Associates, Inc.

This Vendor Diversity and Inclusion Policy ensures diverse and inclusive practices within our company policies and procedures.

The Vendor Diversity and Inclusion Policy is Approved and Supported by Management.

The Firm’s Policy on Commitment to the Vendor Diversity and Inclusion Policy:

Whitley Mortgage Associates, Inc. is committed to ensuring diverse and inclusive practices in recruitment, hiring, retention, intern selection, promotion, contracting with vendors and separation procedures. WMA’s Vendor Diversity and Inclusion Policy provides a roadmap for how to achieve and maintain diverse and inclusive practices.

Senior Level Official with Experience in Diversity and Inclusion Policies Appointed to Oversee and Direct Efforts:

WMA has identified Sarah Rynne as the Diversity and Inclusion Officer. Ms. Rynne is responsible for implementing the Diversity and Inclusion Policy and the Vendor Diversity and Inclusion Policy.

Vendor Diversity and Inclusion Progress Reports to Board of Directors:

Diversity and Inclusion progress, based on the Vendor Scorecard also known as the Vendor Matrix Review System, is reported to the Board of Directors, Senior Management, quarterly.

Outreach & Establishing Relationships:

It is a requirement of the “Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies,” and The Diversity and Inclusion Self-Assessment to establish relationships with, and provide information on, vendor and contractor opportunities to educational institutions. Whitley Mortgage Associates, Inc. engages in outreach opportunities including:

1. Minority and women organizations
2. Educational Institutions serving predominantly minorities and women
3. Participating in women’s and minority’s conferences, workshops and events that attract minority and women applicants and intern applicants.

Vendor Appraisal System:

WMA’s Diversity and Inclusion Officer and Office Manager implements a fair and equitable Vendor Scorecard also known as the Vendor Matrix Review System. This system incorporates quantitative measures (progress monitoring) to assess the effectiveness of the vendor or contractor when preparing annual reports for the Board of Directors. It can be found in Management. There is one or more review per year.

Developmental Program for Potential Contractors:

WMA values our community and seeks to offer specifically tailored Developmental Programs for Potential Contractors that will equip contractors to be able to provide goods or services for WMA. Potential contractors can submit their information through the “contact us” link on our website. WMA will evaluate possible candidates for this Developmental Program for Potential Contractors from a pool of contractor-applicants, using the WMA Contractor Candidate Evaluation Form. If selected, the contractor-applicant will meet with WMA Diversity and Inclusion Officer to tailor a Developmental Program for Potential Contractors to their specific service/good/industry.

Summary:

WMA’s Vendor Diversity and Inclusion Policy includes an Developmental Program for Potential Contractors. The Firm is committed to ensuring diverse and inclusive practices through the following:

Firm’s Vendor Diversity and Inclusion Strategic Plan:

Whitley Mortgage ensures diverse and inclusive practices in recruiting and developing contractors and vendors.

1. Provide Developmental Program for Potential Contractors opportunities (see below).
2. Continued implementation of the fair and equitable Vendor Matrix Review System when working with a candidate for the Developmental Program for Potential Contractors.
3. Participate in outreach to groups, organizations, educational institutions, and/or events that appeal to women and/or minorities, and establishing relationships with those groups, organizations and/or institutions.
4. Maintain database of minority-owned and women-owned vendors that will compete for upcoming contracts.
5. Participate in outreach to groups, organizations, educational institutions, workshops and/or events that appeal to women-owned businesses and/or minority-owned businesses, and establish relationships with those groups, organizations and/or institutions.
6. Publish upcoming opportunities to procure goods or services from vendors and contracting opportunities on our website, Social Media (in groups focused on women and minorities), and through email lists.
7. Publish information on the Developmental Program for Potential Contractors opportunities for potential contractors on the website.
8. Provide quarterly reports to Senior Management on Progress.

Firm Transparency:

WMA publishes all information related to Vendor Diversity and Inclusion on its website.