You lay out some very good points to follow in order to aggressively address systemic racism and implicit bias in the workplace. I especially agree with outsourcing HR, many times local HR teams are too close to those they are investigating.

In the company I presently work for, the message from the upper echelons is clear that they are on board in confronting this issue. But the reality is that the middle management folks, who are the real gatekeepers, have been very quiet about this entire issue. I suspect that they are simply trying to ride it out. Mid-managers are the ones who are most in danger of being exposed for their adherence to the status quo. Things will not change for the majority of everyday people without firmly addressing the malfeasance of these office caretakers.