Diversity, Equity, and Inclusion
The foundation of the DEI program is built on the belief that transparency and public disclosure are essential for responsible corporate practices. By sharing meaningful data on workforce composition, along with metrics on promotion, recruitment, and retention of diverse employees, a company demonstrates its commitment to accountability and openness about its internal processes. This practice not only fosters trust but also provides investors and stakeholders with valuable data to evaluate and compare the effectiveness of its diversity initiatives
As You Sow
DEI researchers regularly visit corporate websites, CSR and DEI reports, career and investor relations pages, and public filings via the SEC EDGAR website, to identify the state of a company’s diversity data disclosure. The findings are then tracked in an internal database in two ways: a binary format, acting as a yes or no, and the actual quantitative data itself.
If a company releases the data set identified, it receives all of the possible points for that individual indicator. The weighting of each data set is a reflection of how important the information is from a transparency perspective, relative to an investors’ ability to understand the effectiveness of a corporate DEI program.
As You Sow and Whistle Stop Capital Collaboration
The DEI program is a collaboration between As You Sow and Whistle Stop Capital. The program evaluates companies on the disclosure of materials related to the DEI actions within an organization. The research predominantly examines which companies are releasing standardized, comparable and meaningful workplace equity data. The intention of the DEI data collection is to provide a public resource showing the current level of corporate disclosure surrounding DEI.
Frequency of data updates
DEI data is updated and produced quarterly for data licensees. Each quarter, researchers search company websites, regulatory filings, and other sources to accurately assign Key Performance Indicator (KPI) scores to companies. These scores reflect the company’s overall standing in relation to Diversity, Equity, and Inclusion efforts. Companies also have the opportunity to engage with DEI Program staff by submitting relevant documentation, which researchers review to determine whether it satisfies specific criteria.
Key Performance Indicators
As of September 2023, there are 31 different DEI Key Performance Indicators categorized into six different pillars. All of them focused on the disclosure of various DEI statistics and materials. These metrics are used to assign an overall DEI score for each company.
Key Pillars
Workforce Composition
This pillar is composed of two different metrics that focus on releasing data for a company’s workforce demographics.
- Workforce Composition Disclosure: Looks at if a company discloses data on the composition of its workforce. (5%)
- Yes, the company discloses data on the gender and/or racial composition of its workforce. (1)
- No, the company does not disclose data on the gender and/or racial composition of its workforce. (0)
- Equal Employment Opportunity (EEO-1): Looks at if a company publicly discloses their annual EEO-1 form, which tracks gender, race, and ethnicity of employees across numerous job titles. (20%)
- Yes, the company publicly releases their EEO-1 Form. (1)
- No, the company does not publically release their EEO-1 Form. (0)
Pay Equity Data Reporting
This pillar is composed of four different metrics that focus on the disclosure of pay equity data between different demographic blocks.
- Mean Pay Gap by Gender Disclosure: Looks at if a company discloses U.S. specific data on its mean gender pay gap, if one exists. If a gap does not exist, do they claim pay equity by gender. (1.25%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Median Pay Gap by Gender Disclosure: Looks at if a company discloses U.S. specific data on its median gender pay gap, if one exists. If a gap does not exist, do they claim pay equity by race/ethnicity. (1.25%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Mean Pay Gap by Race and Ethnicity Disclosure: Looks at if a company discloses U.S. specific data on its mean gender pay gap, if one exists. If a gap does not exist, do they claim pay equity by race/ethnicity. (1.25%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Median Pay Gap by Race and Ethnicity Disclosure: Looks at if a company discloses U.S. specific data on its median gender pay gap, if one exists. If a gap does not exist, do they claim pay equity by race/ethnicity. (1.25%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
Promotion
This pillar is one of three pillars focused on critical inclusionary data disclosure by companies. The pillar is composed of nine different metrics each focused on a different demographic group and their promotion rates.
- Promotion Rates Disclosure of Male Employees: Looks at if a company discloses data on internal promotion rates of male employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Promotion Rates Disclosure of Female Employees: Looks at if a company discloses data on internal promotion rates of female employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Promotion Rates Disclosure of White Employees: Looks at if a company discloses data on internal promotion rates of white employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Promotion Rates Disclosure of Black Employees: Looks at if a company discloses data on internal promotion rates of black employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Promotion Rates Disclosure of Hispanic Employees: Looks at if a company discloses data on internal promotion rates of Hispanic employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Promotion Rates Disclosure of Asian Employees: Looks at if a company discloses data on internal promotion rates of Asian employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Promotion Rates Disclosure of Native American or Native Alaskan Employees: Looks at if a company discloses data on internal promotion rates of Native American or Native Alaskan employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Promotion Rate Disclosure of Pacific Islander or Native Hawaiian Employees: Looks at if a company discloses data on internal promotion rates of Pacific Islander or Native Hawaiian employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Promotion Rate Disclosure of Employees of Two or More Races: Looks at if a company discloses data on internal promotion rates of Pacific Islander or Native Hawaiian employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
Recruitment / Hiring
This pillar is one of three pillars focused on critical inclusionary data disclosure by companies. The pillar is composed of nine different metrics each focused on a different demographic group and their recruitment rates.
- Recruitment or Hiring Rates Disclosure of Male Employees: Looks at if a company discloses data on recruitment rates of male employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Recruitment or Hiring Rates Disclosure of Female Employees: Looks at if a company discloses data on recruitment rates of female employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Recruitment or Hiring Rates Disclosure of White Employees: Looks at if a company discloses data on recruitment rates of white employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Recruitment or Hiring Rates Disclosure of Black Employees: Looks at if a company discloses data on recruitment rates of black employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Recruitment or Hiring Rates Disclosure of Hispanic Employees: Looks at if a company discloses data on recruitment rates of Hispanic employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Recruitment or Hiring Rates Disclosure of Asian Employees: Looks at if a company discloses data on recruitment rates of Asian employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Recruitment or Hiring Rates Disclosure of Native American or Native Alaskan Employees: Looks at if a company discloses data on recruitment rates of Native American or Native Alaskan employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Yes, company does disclose. (1)
- Recruitment or Hiring Rates Disclosure of Pacific Islander or Native Hawaiian Employees: Looks at if a company discloses data on recruitment rates of Pacific Islander or Native Hawaiian employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Recruitment or Hiring Rates Disclosure of Employees of Two or More Races: Looks at if a company discloses data on recruitment rates of employees of two or more races. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
Retention
This pillar is one of three pillars focused on critical inclusionary data disclosure by companies. The pillar is composed of nine different metrics each focused on a different demographic group and their retention rates.
- Retention or Turnover Rate Disclosure of Male Employees: Looks at if a company discloses data on retention rates of male employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Retention or Turnover Rate Disclosure of Female Employees: Looks at if a company discloses data on retention rates of female employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Retention or Turnover Rate Disclosure of White Employees: Looks at if a company discloses data on retention rates of white employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Retention or Turnover Rate Disclosure of Black Employees: Looks at if a company discloses data on retention rates of black employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Retention or Turnover Rate Disclosure of Hispanic Employees: Looks at if a company discloses data on retention rates of Hispanic employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Retention or Turnover Rate Disclosure of Asian Employees: Looks at if a company discloses data on retention rates of Asian employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Retention or Turnover Rate Disclosure of Native American or Native Alaskan Employees: Looks at if a company discloses data on retention rates of Native American or Native Alaskan employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Retention or Turnover Rate Disclosure of Pacific Islander or Native Hawaiian Employees: Looks at if a company discloses data on retention rates of Pacific Islander or Native Hawaiian employees. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
- Retention or Turnover Rate Disclosure of Employees of Two or More Races: Looks at if a company discloses data on retention rates of employees of two or more races. (2.2%)
- Yes, company does disclose. (1)
- No, company does not disclose. (0)
Explicit and Quantifiable DEI Goals
This pillar is composed of just one metric that is focused on the disclosure of an explicit Diversity, Equity, and Inclusion (DEI) goal.
- Explicit DEI Goal: Examines if a company has a diversity goal that is quantifiable and time-bound.
. (10%)
- Yes, the company discloses an explicit DEI goal. (1)
- No, the company does not disclose an explicit DEI goal. (0)
