Comptroller Stringer and NYC Retirement Systems Announce 34 S&P 100 Companies Will Publicly Disclose Workforce Demographics

(New York, NY) – Today, New York City Comptroller Scott M. Stringer, on behalf of the New York City Employees’ Retirement System, Teachers Retirement System of the City of New York and New York City Board of Education Retirement System (the “Systems”), announced that 34 S&P 100 companies which issued statements supporting racial equality will publicly disclose the composition of their workforce by race, ethnicity, and gender. This victory is a direct result of a national campaign launched in July by Comptroller Stringer and the Retirement Systems’ which called on 67 companies to match their statements affirming their commitments to racial equality and diversity and inclusion with concrete action, by publicly disclosing their annual EEO-1 Report data.

“It is not enough to condemn racism in words. I applaud these leading companies for taking this critical first step where they will make a direct impact within their own workplaces and set the tone for EEO-1 Report disclosure across the market,” said New York City Comptroller Scott M. Stringer. “By publicly disclosing the demographics of employees by race, gender, and ethnicity – including leadership roles and senior management – these companies will provide crucial information for shareowners to better understand diversity and workforce practices – and identify areas for growth. Companies are strongest when their workforce reflects the diversity of America, and I commend the CEOs of these leading companies for taking steps toward better transparency and representation. We still have much more work to do, and together with the New York City Retirement Systems we will continue building on this success to hold companies accountable and create meaningful, systemic change in corporate America.”

The Consolidated EEO-1 Report is the “gold standard” for diversity disclosure and will enable investors to evaluate the performance of portfolio companies in terms of their ability to hire, retain, and promote employees of color and women. At present, there are only 29 public companies that currently disclose their Consolidated EEO-1 Report, of which only 14 are in the S&P 100.  The Comptroller’s campaign results in a 243% increase to 48 S&P 100 companies becoming more transparent about their employees.

The 34 companies that have begun or committed to disclose EEO-1 Report data are:

• AbbVie Inc.
• Amazon.com, Inc.
• American International Group, Inc.
• American Tower Corporation (REIT)
• Amgen Inc.
• Biogen Inc.
• BlackRock, Inc.
• Bristol-Myers Squibb Company
• Capital One Financial Corporation
• Chevron Corporation
• Citigroup Inc.
• ConocoPhillips
• Duke Energy
• Exelon Corporation
• General Motors Company
• Gilead Sciences, Inc.
• Goldman Sachs
• Mastercard Incorporated
• Medtronic PLC
• Morgan Stanley
• PayPal Holdings, Inc.
• PepsiCo, Inc.
• Pfizer Inc.
• QUALCOMM Incorporated
• Starbucks Corporation
• Target Corporation
• The Southern Company
• The Allstate Corporation
• The Coca-Cola Company
• UnitedHealth Group Incorporated
• U.S. Bancorp
• Verizon Communications Inc.
• Visa Inc.
• Wells Fargo & Company

In July, Comptroller Stringer and the Retirement Systems sent letters to the CEOs of 67 S&P 100 companies citing the need for these companies to publicly release data that would enable investors to measure the success of their diversity and inclusion practices, which are fundamental to the creation of long-term shareowner value. Companies were asked to provide a written commitment by August 30, 2020 to publicly disclose their EEO-1 Report effective upon its next submission to the U.S. Equal Employment Opportunity Commission (EEOC) in 2021 or risk potential submission of shareholder proposals or opposition to the election of director nominees standing for re-election at the next annual shareowner meeting. For the focus list of companies, click here.

Specifically, the Comptroller and the Systems requested the Consolidated EEO-1 Report itself, which provides the actual number for each employment category. This disclosure gives investors and the public a comprehensive breakdown of a company’s U.S. workforce by race, ethnicity and gender according to 10 employment categories, including, importantly, senior management, defined to incorporate individuals within two reporting levels of the CEO.

Full disclosure of the EEO-1 Report provides investors with critical information that disclosure of diversity metrics selectively collected by management or partial EEO-1 disclosure does not. In particular, full public disclosure provides:

• Standardized, quantitative, relevant and comparable employment data across companies and industries, so that investors can assess the representation and progress of black employees and other employees of color and women at various levels of the corporation;
• Specific data on senior management diversity – in addition to setting a strong tone at the top for diversity, research by McKinsey suggests that companies in the top quartile for gender and ethnic/cultural diversity on executive teams have stronger financial performance;
• Particularized data that will allow investors to assess the representation and progress of specific racial and ethnic groups by gender, such as black female employees. Disclosing only percentage representations prohibits meaningful, year-over-year comparisons.

Disclosure of EEO-1 Report data also provides the board and management with distinct advantages. In the first instance, it provides a cost-effective means to demonstrate substantive progress in diversity and inclusion practices since the company already collects the data for submission to the EEOC. In addition, some companies resist disclosing their Consolidated EEO-1 Report because they believe the mandated categories do not align with their particular organizational structure, however, disclosure of EEO-1 Report data does not prohibit any qualitative or quantitative disclosures that management believes reflect a company’s organizational structure or demonstrate the company’s performance.

Moreover, to the extent there is widespread adoption, another salutary effect of the disclosure of EEO-1 Report data may be the ability of the board also to benchmark the company’s own data to those of its peers, thereby facilitating the board’s oversight of company human capital management practices.

Comptroller Stringer serves as the investment advisor to, and custodian and a trustee of, the New York City Retirement Systems.

In addition to Comptroller Stringer, the participating New York City Retirement Systems’ trustees are:

New York City Employees’ Retirement System (NYCERS): Mayor Bill de Blasio’s Representative, John Adler (Chair); New York City Public Advocate Jumaane Williams; Borough Presidents: Gale Brewer (Manhattan), Sharon Lee (Queens), Eric Adams (Brooklyn), James Oddo (Staten Island), and Ruben Diaz, Jr. (Bronx); Henry Garrido, Executive Director, District Council 37, AFSCME; Tony Utano, President Transport Workers Union Local 100; Gregory Floyd, President, International Brotherhood of Teamsters, Local 237.

Teachers’ Retirement System (TRS): Mayor Bill de Blasio’s Appointee, John Adler; Chancellor’s Representative, Lindsey Oates, New York City Department of Education; Natalie Green Giles; and Debra Penny (Chair), Thomas Brown and David Kazansky, all of the United Federation of Teachers.

Board of Education Retirement System (BERS): Schools Chancellor Richard Carranza; Mayoral: Isaac Carmignami, Natalie Green Giles, Vanessa Leung, Gary Linnen, Lori Podvesker, Shannon Waite, Michael Kraft (Manhattan BP), Debrorah Dillingham (Queens BP), April Chapman (Brooklyn BP), Geneal Chacon (Bronx BP) and Peter Calandrella (Staten Island BP); Thomas C. Sheppard, Kathy Park Price, Natalie Green Giles, Russell Buckley, Chris Attianese, Shaun D. Francois; and employee members John Maderich of the IUOE Local 891 and Donald Nesbit of District Council 37, Local 372;

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