The following proposals will be put to shareholders at its May 25, 2022 annual meeting: Atlanta-based Home Depot, the largest home improvement retailer in North America, faced a shareholder proposal in 2021 that requested a political contributions congruency analysis. There are three essential features of an effective racial equity audit: The audit should be independent, and conducted by a firm with civil rights expertise; There must be robust stakeholder engagement to uncover issues across a company's products and services, workforce practices, and corporate policies; and. (go back), 7Statement on the Review of Climate-Related Disclosure, U.S. Securities and Exchange Commission, Acting Chair Allison H. Lee, February 24, 2021, available at https://www.sec.gov/news/public-statement/lee-statement-review-climate-related-disclosure. Wenah herself has been working on this project for many years. . 1 launched a proxy campaign in December 2020 to effect change on Exxons board of directors. Will Corporations Deliver Value to All Stakeholders? . [111] Despite the laundry list of examples Amazon cited in its No-Action Letter, the SEC did not concur that the proposal was excludable under Rule 14a-8(i)(7). In a world where we have seen data and technology used to foster discrimination, we are pleased to see Airbnb use them to fight bias on its platform. That movement, together with the disproportionate impacts of the COVID-19 pandemic have focused the attention of the media, the public and policy makers on systemic racism, racialized violence and inequities in employment, health care, and the criminal justice system. https://www.sec.gov/news/public-statement/lee-climate-change-disclosures, https://www.sec.gov/news/public-statement/coates-esg-disclosure-keeping-pace-031121, https://www.activistinsight.com/wp-content/uploads/dlm_uploads/2021/06/InsightiaESGActivism-1.pdf?utm_source=newsletter&utm_medium=email&utm_campaign=greenfin&utm_content=2021-06-30, https://www.trilincglobal.com/what-is-esg/, https://www.businessinsider.com/patagonia-mission-environmentalism-good-for-business-2018-12, https://www.blackrock.com/corporate/literature/fact-sheet/blk-responsible-investment-guidelines-us.pdf, https://www.issgovernance.com/file/policy/active/americas/US-Voting-Guidelines.pdf, https://www.reuters.com/article/exxon-shareholders-engine-no-1/exxon-faces-proxy-fight-launched-by-new-activist-firm-engine-no-1-idUSKBN28H2IO, https://www.socinvestmentgroup.com/critical-tool-for-shareholders, https://www.bloomberg.com/news/articles/2020-10-20/racism-and-inequity-have-cost-the-u-s-16-trillion-wall-street-economist-says, https://stories.starbucks.com/uploads/2020/02/Starbucks-Civil-Rights-Assessment-2020-Update.pdf, https://www.forbes.com/sites/korihale/2021/01/20/starbucks-steps-up-its-racial-justice-outreach-with-100-million-pledge/?sh=53b94b63389c, https://www.npr.org/2020/07/07/887628306/opinion-companies-have-a-duty-to-defend-democracy, https://www.mckinsey.com/~/media/mckinsey/business%20functions/organization/our%20insights/delivering%20through%20diversity/delivering-through-diversity_full-report.ashx, https://www.nerdwallet.com/article/investing/best-esg-funds, https://about.fb.com/wp-content/uploads/2020/07/Civil-Rights-Audit-Final-Report.pdf, https://www.forbes.com/sites/bhaktimirchandani/2021/06/28/what-you-need-to-know-about-the-2021-proxy-season/?sh=2e475fae7f5e, https://content.irmagazine.com/story/ir-magazine-summer-2021.pdf, https://about.bankofamerica.com/annualmeeting/static/media/BAC_2021_ProxyStatement_ADA.612694a6.pdf, https://www.sec.gov/Archives/edgar/data/831001/000120677421000735/citi3828191-def14a.htm, https://exchange.iccr.org/node/88686/text, https://www.sec.gov/Archives/edgar/data/0000019617/000001961721000275/a2021proxystatement.htm, https://www.sec.gov/news/speech/lee-climate-esg-board-of-directors, https://www.asyousow.org/our-work/social-justice/racial-justice, https://news.yahoo.com/big-us-companies-pushed-tally-014418300.html, https://news.bloomberglaw.com/banking-law/goldman-citi-stave-off-investor-calls-for-racial-audits-1, https://www.govinfo.gov/content/pkg/FR-1998-05-28/html/98-14121.htm, https://www.sec.gov/divisions/corpfin/cf-noaction/14a-8/2021/ctwcitigroup022621-14a8.pdf. According to this study, closing racial gaps would have generated an additional $16 trillion in economic output since [the year] 2000, and by closing the various gaps between Blacks and Whites, the U.S. could stand to gain an additional $5 trillion in economic activity over the next five years. [42] Racial Equity Audits could therefore prove to be a critical tool for companies looking to capture some of these unrealized gains. The Staff has stated that substantial implementation under the rule does not require the company to have implemented the proposal in full or exactly as proposed by the shareholder. In announcing the settlement, the NFHA stated, [t]he actions of Travelers disproportionately harmed low-income African Americans and women-headed households who use Housing Choice Vouchers., Shareholders have filed two proposals at Travelers, one requesting a racial equity audit, and the other asking for a report on the companys policies and practices to help ensure its insurance offerings, including those for law enforcement liability insurance, reduce and do not increase the potential for police brutality. The proponents argued that Home Depots political contributions appear to be misaligned with its public statements of its views and operational practices. The proposal received substantial support, with 38 percent of shares voted in favor. 1, Reuters, Svea Herbst-Bayliss, Gary McWilliams, December 7, 2020, available at https://www.reuters.com/article/exxon-shareholders-engine-no-1/exxon-faces-proxy-fight-launched-by-new-activist-firm-engine-no-1-idUSKBN28H2IO. The audits are conducted by third-party groups, which analyze companies' business modelsfrom policies to products and servicesto determine whether they cause, reinforce, or perpetuate. Home Depots PAC donated more than $450,000 in the 2019-20 election cycle, and more than $1.5 million in the past three cycles to the Members of Congress who objected to certifying the election results on January 6, 2021. The tactic in question is civil rights audits, also known as racial equity audits, which are third-party assessments of a company's role in addressing systemic racism. called upon to navigate the challenges presented by climate change, racial injustice, economic inequality, and numerous other issues that are fundamental to the success and sustainability of companies, financial markets, and our economy. [72] After the May 2020 killing of George Floyd, 66% of S&P 500 companies posted statements on their websites or social media accounts, 36% made financial contributions to racial justice organizations and 14% stated in their communications that Black Lives Matter. [73] While it has been observed that these companies were quick to issue statements supporting Black Lives Matter and promis[ed] to do more to be responsive to non-white consumers, employees and communities, [74] most companies on the receiving end of a Rule 14a-8 proposal to implement a Racial Equity Audit have actively resisted such proposal by seeking no-action relief from the SEC to exclude the proposal from their 2021 proxy statements, negotiating with proponents to withdraw their proposals, and, when the company had been unsuccessful with the foregoing, recommending that shareholders vote against the proposals. [52] Practitioners also stress the importance of identifying and engaging the process owners (e.g., the Chief Executive Officer, Chief Legal Officer or Chief Diversity, Equity and Inclusion Officer) as the persons who will actually drive the implementation of recommended initiatives. For example, in the supporting statement submitted by the Service Employees International Union (SEIU) to its Racial Equity Audit proposal included in the proxy statement for The Goldman Sachs Group, Inc.s (Goldman) 2021 annual meeting of shareholders, SEIU detailed Goldmans alleged contributions to systemic racism. The two leading proxy advisory firms, ISS and Glass Lewis & Co. LLC (Glass Lewis), have generally taken opposing views on Racial Equity Audits. A fiduciarys duty is to act in the best interest of their beneficiaries and traditionally translates to acting to obtain the highest return on investment, but it can be equally important that fiduciaries seek to minimize risk. [22]. (go back), 128SEIU and Change to Wins investment funds pushing for racial diversity in financial institutions, available at https://www.seiu.org/blog/2021/4/seiu-and-change-to-wins-investment-funds-pushing-for-racial-diversity-in-financial-institutions. All Homes and Experiences referenced on the Airbnb Newsroom are intended purely to inspire and illustrate. Citigroup Inc. (Citi), Wanted "no action" relief of the Securities and Exchange Commission to exclude the requests from its 2021 proxy statements, a request which was denied. (go back), 90See e.g., Citigroup No-Action Letter, supra note 78; J&J No-Action Letter, supra note 78; JPMorgan No-Action LetterFebruary, supra note 77; Amazon No-Action Letter, supra note 83. Racial equity audits and civil rights audits have been used to identify and reduce sources of . "The reason we started Airbnb was to connect people, to make sure that they feel like they belong in the communities they visit and the biggest obstacle to belonging is . (go back), 21Cal. In the U.S. market there are now over 600 ESG funds and exchange-traded funds for investors to choose from with approximately $161 billion in assets under management (AUM), which is more than double the AUM of ESG funds in 2010. (go back), 20Proxy Voting Guidelines Benchmark Policy Recommendations, ISS, effective for meetings on or after February 1, 2021, available at https://www.issgovernance.com/file/policy/active/americas/US-Voting-Guidelines.pdf. (go back), 47The Best ESG Funds for Great Returns & Low Costs, Forbes, Rob Berger and Benjamin Curry, July 1, 2021, available at https://www.forbes.com/advisor/investing/best-esg-funds/. (go back), 27Racial Equity Audit Proposal Q&A CtW Investment Group and the Service Employees International Union, available at https://static1.squarespace.com/static/5d374de8aae9940001c8ed59/t/605cdec4e6861277202f0b46/1616699076603/Racial+Equity+Audit+QA_CtW_SEIU+%28002%29.pdf. All rights reserved. In a recent review of federal mortgage data from 2020 by Bloomberg, the outlet found that Wells Fargo has the worst record among major lenders when it came to disparities in approvals of refinancings by Black homeowners, approving fewer than half of Black homeowners refinancing applications in 2020. (go back), 106Other shareholders joining the proposal were: (1) the Praxis Growth Index Fund; (2) CommonSpirit Health; (3) the Adrian Dominican Sisters; (4) Catherine Donnelly Foundation; (5) Monasterio Pan de Vida; (6) Reynders, McVeigh Capital Management, LLC; (7) the Congregation of the Sisters of St. Joseph of Peace; (8) the Sisters of the Holy Names of Jesus and Mary U.S.-Ontario Province Corporation; and (9) Newground Social Investment on behalf of the Robert H. and Elizabeth Fergus Foundation and Eric Menninga. [115] The companys environmental impact has also been called out for allegedly disproportionately affecting minority communities. (go back), 96See e.g., Goldman Sachs Proxy Statement, supra note 35 (We share the proponents focus on advancing racial equity.); Citigroup Proxy Statement, supra note 69 (While we disagree with the overall approach in this Proposal, we are completely aligned with its stated goal of addressing racial inequity in the financial sector.); see also Lawmakers debate bill mandating racial equity audits at firms, The Hill, Abigail Goldberg-Zelizer, June 30, 2021, available at https://thehill.com/policy/finance/561026-lawmakers-debate-bill-mandating-racial-equity-audits-at-firms; Shareholders want to hold corporate giants accountable for their commitments to racial equity and justice. Shareholders have filed proposals relating to the impacts of the use of Amazons surveillance and facial recognition technology by governments and law enforcement bodies; its use of concealment clauses regarding harassment, discrimination, and other unlawful acts in the workplace; its lack of reporting on its lobbying activities; and its employees right to collective bargaining, among other issues. [95], Companies Recommended Voting Against Racial Equity Audit Proposals. (go back), 134 ISS Opens Global Annual Benchmark Policy Survey and Separate Climate Survey, ISS, July 28, 2021, available at https://insights.issgovernance.com/posts/iss-opens-global-annual-benchmark-policy-survey-and-separate-climate-survey/. [41] A study by a Citigroup, Inc. (Citi) global economist found that addressing racial disparities can have even broader macro benefits. Following the audit at Facebook, the company . Amongst the various ESG developments gaining traction in the markets is the recent push by shareholders for companies to conduct Racial Equity Audits, which generally consist of an objective investigation into a companys practices, policies and histories to determine such companys impact on social issues and areas for improvement. Racial Equity Audits are the practice of independently reviewing an organisation's policies and ascertaining how well they encourage and promote inclusion, diversity, and racial equality. [140] The legislation is sponsored by Rep. Joyce Beatty and co-sponsored by Reps. Nikema Williams and Jesus G. Garcia and is currently under committee review. Below is a chart listing the shareholder proposals submitted at various companies during the 2021 proxy season, the proponent, the regulatory basis to exclude the proposal invoked by the company and the SECs response to the companys request for exclusion. [65] Certain of these racial justice proposals submitted by shareholders included proposals calling for Racial Equity Audits. Julie Wenah, Community Counsel and Acting Regional Counsel for Africa at Airbnb, was a speaker at Scaling Social Impact in a Remote World. Laura Murphy, the ACLU veteran who pioneered business civil rights audits and led the analysis of Airbnb and. [38] Racial Equity Audits can be designed to help identify if and where these issues exist within a company so that management can address them most effectively. (go back), 10ESG Activism Becomes the Norm, ESG Activism, Insightia, 2021, available at https://www.activistinsight.com/wp-content/uploads/dlm_uploads/2021/06/InsightiaESGActivism-1.pdf?utm_source=newsletter&utm_medium=email&utm_campaign=greenfin&utm_content=2021-06-30. While the company opposed all seven, at least four of those resolutions, including the first racial equity audit proposal at the company, two proposals for reports on the human rights implications of certain surveillance products, and a lobbying disclosure proposal received substantial support of over 30 percent. BlackRock Inc. announced in April that it plans on undergoing an audit in 2022. (go back), 36Johnson & Johnson, 2021 Notice of Annual Meeting & Proxy Statement, Schedule 14A, filed with the SEC on March 10, 2021, available at https://www.sec.gov/Archives/edgar/data/200406/000020040621000011/jnjproxy2021.htm [hereinafter J&J Proxy Statement]. (go back), 122NYS Comptroller DiNapoli Statement on Major Support for Racial Equity Audit at Amazon, Office of the New York Comptroller, May 28, 2021, available at https://www.osc.state.ny.us/press/releases/2021/05/nys-comptroller-dinapoli-statement-major-support-racial-equity-audit-amazon. (go back), 29Webinar, Susan Baker, Director of Shareholder Advocacy, Trillium Asset Management, supra note 23. Data collected through Project Lighthouse will help the company create tools and policies to combat bias against Black users and other people of color, Brian Chesky, Airbnb's CEO and co-founder, told USA TODAY. 14B, September 15, 2004, available at https://www.sec.gov/interps/legal/cfslb14b.htm. We saw this occur in California with Senate Bill 826 and Assembly Bill 979 discussed in further detail above. After a notice period, the data analysis will begin. (go back), 117See Webinar, Thomas DiNapoli, New York State Comptroller, supra note 23. Id. If a company lags behind in this quickly developing area, we believe shareholders may become more willing to launch shareholder campaigns focused on ESG issues, including demanding objective results through Racial Equity Audits. [2] Thirdcorporate governance, which considers how a company governs itself and holds itself accountable taking into account the structure and diversity of a companys board of directors, the separation between management and the board of directors, executive compensation, equal and fair pay amongst employees, and the extent to which a company or its management or board of directors are undertaking lobbying efforts, making political and charitable donations, or engaging in corruption or bribery. (go back), 50Webinar, Pamela Coukos, Co-Founder of Working Ideal, supra note 23; supra note 27. [141]. Indeed, the House Financial Services Subcommittee on Diversity and Inclusion is currently reviewing legislation that would require banks to conduct Racial Equity Audits every two years in an effort to promote diversity and equity. 16, 1992)). Today, building upon 8 years of learnings and experience providing temporary housing to 75,000 refugees, asylum seekers and people displaced by disasters or other crises across 104 countries, Airbnb.org is announcing a series of commitments to diversity, equity and inclusion. Most companies who may have been unsuccessful in seeking no-action relief from the SEC to exclude the proposal or in negotiating a resolution with a shareholder to withdraw the proposal have recommended that shareholders vote against the proposals. [81], Rule 14a-8(i)(7) allows exclusion of proposals related to a companys ordinary business operations. (go back), 91See SEC, Division of Corporate Finance Staff Legal Bulletin No. . https://www.sec.gov/rules/final/34-40018.htm (citing Reebok Intl Ltd. (Mar. The . [32] For example, following the voluntary Racial Equity Audit conducted by Starbucks after the 2018 incident discussed above, the company began requiring implicit bias training for employees, setting public corporate diversity goals and implementing a number of other social initiatives. . This project was designed with guidance from data privacy experts and advocates, including the Center for Democracy & Technology, Dr. Latanya Sweeney and The Data Privacy Lab at Harvard, and Upturn. In a moment when many corporations are making hollow declarations of support for Black lives, Airbnb is commiting to do the work of addressing discrimination thats been an unintended consequence of the companys rapid growth. We would all be better served if more companies followed Airbnbs lead in developing robust internal systems for considering and combatting discrimination issues as products and tools are being designed and before theyre rolled out, said Vanita Gupta, president and CEO of The Leadership Conference on Civil and Human Rights. (go back), 108Amazon No-Action Letter, supra note 83. Racial Equity Audits may also find that a companys existing policies and practices are not sufficient to address or may be perpetuating systemic social issues. In addition to Starbucks, Airbnb and Facebook have completed audits. (go back), 56Facebooks Civil Rights AuditFinal Report, Facebook, July 8, 2020, available at https://about.fb.com/wp-content/uploads/2020/07/Civil-Rights-Audit-Final-Report.pdf. Exxon has faced pressure from shareholders to shift practices to reduce greenhouse gas emissions. Racial equity audits of corporations originated within the racial justice movement recently. . . Civil rights advocates and proponents of social justice have long touted the moral and ethical considerations of closing the racial divide in America. 1What is ESG?, ADEC Innovations ESG Solutions, available at https://www.esg.adec-innovations.com/about-us/faqs/what-is-esg/. Then at the end of 2018, Airbnb sought to further mitigate bias by developing a policy that hides Airbnb guest profile photos until after the booking is accepted. Every company has a different mix of products, operations and services; therefore, according to practitioners in the area, it is important for participants in a Racial Equity Audit to identify the scope of the audit and benchmarks prior to conducting the audit. The policy asks hosts to treat guests with respect and without judgment or bias based on factors like race. At a time when we cannot rely on government alone to further social justice goals, unusual allies become more important than ever. Other racial equity problems include the companys review and promotion systems creating an unlevel playing field with large disparities in performance review ratings between Black and white employees.. One of key takeaways from Airbnb and Twitters leadership on racial equity is that the commitment to justice and inclusion must span businesses and products. (citing Exchange Act Release No. [17], Improved ESG criteria is not a new area for activist investors. [23] In the aftermath of the killing of George Floyd in May 2020 and the subsequent civil rights movement and unrest, many companies announced a number of initiatives and measures to address social justice issues, including committing financial resources and reviewing their own policies and practices. . (go back), 88See JPMorgan No-Action LetterFebruary, supra note 77. Some companies are turning to law firms like Covington to do the work. Also speaking at sf.citis Scaling Social Impact event, she said: in an ideal world, if we were all showing up and doing [diversity and inclusion] work the right way, my role wouldnt exist. So much of feeling included, she continued, is about individual connections. Financial institutions and asset management firms have become the focus of Racial Equity Audit shareholder proposals. The findings will be used to examine and address disparities in how Black users and other people of color experience Airbnb, out of fear of mistreatment or due to discrimination and bias. The companys response to unionization efforts by its predominantly Black workforce at a warehouse in Bessemer, Alabama raised further concerns about justice issues. In August 2021, a National Labor Relations Board hearing officers report on a union election there found that the company committed multiple violations of employees rights. What that means for tech companies more broadly is that inclusion must be embedded in every fabric of the organization. Some concrete examples, offered Brand, are pay equity, supplier diversity, and employee resource groups. Amazon, the second-largest employer in the US, faces numerous shareholder proposals attempting to address its lack of transparency relating to risks associated with internal and external racial justice issues. Dalana Brand is the Vice President People Experience and Head of Inclusion and Diversity at Twitter. [69], Proponents contend that Racial Equity Audits would help public companies identify, prioritize, remedy and avoid adverse impacts on nonwhite stakeholders and communities of color [70] and would help a companys board of directors assess such companys behavior through a racial equity lens in order to obtain a complete picture of how it contributes to, and could help dismantle, systemic racism. [71]. In June 2020, Scharf defended his early choices, arguing that the unfortunate reality is that there is a very limited pool of Black talent to recruit from with this specific experience.. Related research from the Program on Corporate Governance includesThe Illusory Promise of Stakeholder Governance(discussed on the Forumhere) andWill Corporations Deliver Value to All Stakeholders?, both by Lucian A. Bebchuk and Roberto Tallarita;For Whom Corporate Leaders Bargainby Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita (discussed on the Forumhere); andRestoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American EconomyA Reply to Professor Rockby Leo E. Strine, Jr. (discussed on the Forumhere). (go back), 8Public Input Welcomed on Climate Change Disclosures, U.S. Securities and Exchange Commission, Acting Chair Allison H. Lee, March 15, 2021, available at https://www.sec.gov/news/public-statement/lee-climate-change-disclosures. (go back), 77Rule 14a-8 No Action Letter re: JPMorgan Chase & Co.2021 Annual Meeting, Supplemental Letter dated January 11, 2021, Relating to Shareholder Proposal Submitted by CtW Investment Group, Skadden, Arps, Slate, Meagher & Flom LLP, February 16, 2021, available at https://www.sec.gov/divisions/corpfin/cf-noaction/14a-8/2021/ctwjpmorgan032621-14a8.pdf [hereinafter JPMorgan No-Action LetterFebruary]. Id. New York State Common Retirement Fund et al. In this case, failure to have a Racial Equity Audit policy or refusal to implement such a policy after shareholders have approved a proposal to implement one may become a criteria an advisory firm would consider in making a recommendation for or against the re-election of a companys chairperson of the governance committee and/or the re-election of other directors at the companys annual meeting. What Makes Patagonia A World Leader in Sustainability, Medium, Tom & Jerry, January 13, 2021, available at https://medium.com/climate-conscious/what-makes-patagonia-a-world-leader-in-sustainability-486073f0daa. In 2017, Airbnb released a feature called Instant Book, which sought to combat prejudice by allowing guests to book an Airbnb listing without prior approval. A report on the audit, prepared at reasonable cost and omitting confidential or proprietary information, should be publicly disclosed on BofAs website. Airbnb also created a dedicated Anti-discrimination product team to prioritize this work, and this team now leads Project Lighthouse. (go back), 104Amazon.com, Inc., Notice of 2021 Annual Meeting of Shareholders and Proxy Statement, Schedule 14A, filed with the SEC on April 15, 2021, available at https://www.sec.gov/Archives/edgar/data/1018724/000110465921050333/tm2035374-1_def14a.htm [hereinafter Amazon Proxy Statement]. [31] Following an audit, some companies have used the findings to develop a strategic plan to capitalize on opportunities to address racial equity moving forward. This was led by an external expert and included extensive consultations with civil rights organizations, which resulted in tangible improvements in Airbnbs business practices. Both tech companies have been working to end racism and discrimination for years. [51], Practitioners also believe that the audit process can be important for companies as a way to build trust with their stakeholders. [105] Comptroller DiNapoli was joined by other Amazon shareholders [106] in requesting Amazons board of directors to commission a Racial Equity Audit that would analyze two main issues: (1) Amazons impacts on civil rights, equity, diversity, and inclusion, and (2) the impacts of those issues on Amazons business. [107] In response, Amazon sent a letter to the SEC seeking to exclude the proposal from its 2021 proxy materials. In 2018, Travelers paid out $450,000 to the National Fair Housing Alliance in a settlement of a lawsuit that claimed Travelers had denied insurance to landlords who rented to voucher recipients. Color of Change successfully called for and worked with AirBnB to undertake such an audit. (go back), 82See Final Rule: Amendments to Rules on Shareholder Proposals, Release No. More details are publicly available in a technical paper. Airbnb Inc., which faced a spate of backlash for charges of racial profiling of guests before initiating tougher standards, has bounced nearly 4,000 accounts from its home-sharing app this year for violating its nondiscrimination policy. . (go back), 33On the Progress of its Efforts to Promote Civil Rights, Equity, Diversity, and Inclusion, Starbucks, February 24, 2020, available at https://stories.starbucks.com/uploads/2020/02/Starbucks-Civil-Rights-Assessment-2020-Update.pdf; supra note 27. The most recent and prominent example of the intersection between shareholder activism and ESG was the 2021 proxy contest at Exxon. In a conversation hosted by sf.citi, San Franciscos tech trade association, executives at Airbnb and Twitter shared how their companies are working to build more inclusive workplaces and products. 20091 (August 16, 1983)). (go back), 123Racial Equity Audit, SOC Investment Group, 2021, available at https://www.socinvestmentgroup.com/racial-equity-audit. (go back), 83See Rule 14a-8 No-Action Letter re: Amazon.com, Inc. [11], ESG considerations are becoming increasingly relevant to shareholder activists. A National Labor Relations Board complaint alleged that the company enforced its dress code selectively and disparately against workers that displayed the slogan and engaged in other related protected concerted activities.. And prominent example of the intersection between Shareholder activism and ESG was the 2021 proxy at! Long touted the moral and ethical considerations of closing the racial divide in America its. 23 ; supra note 27 the analysis of Airbnb and detail above at reasonable cost omitting! Firms like Covington to do the work occur in California with Senate Bill 826 and Assembly Bill 979 in... Adec Innovations ESG Solutions, available at https: //www.socinvestmentgroup.com/racial-equity-audit and without judgment or bias based on like. Respect and without judgment or bias based on factors like race 95 ] Rule! Identify and reduce sources of are publicly available in a technical paper predominantly Black workforce at a warehouse in,. Team now leads project Lighthouse?, ADEC Innovations ESG Solutions, available https. Inclusion and diversity at Twitter ACLU veteran who pioneered business civil rights have. 15, 2004, available at https: //www.sec.gov/interps/legal/cfslb14b.htm voted in favor, Improved ESG criteria not! Investment Group, 2021, available at https: //about.fb.com/wp-content/uploads/2020/07/Civil-Rights-Audit-Final-Report.pdf the policy asks hosts to treat with! Experiences referenced on the Audit, prepared at reasonable cost and omitting or! Is about individual connections Susan Baker, Director of Shareholder Advocacy, Trillium Asset Management have.?, ADEC Innovations ESG Solutions, available at https: //www.sec.gov/rules/final/34-40018.htm ( citing Reebok Intl Ltd. (.... And Head of inclusion and diversity at Twitter in December 2020 to effect change on Exxons board directors... Available at https: //about.fb.com/wp-content/uploads/2020/07/Civil-Rights-Audit-Final-Report.pdf, Gary McWilliams, December 7, 2020 available! Audit Shareholder proposals, Release No an Audit SEC seeking to exclude the proposal received substantial support, 38. Successfully called for and worked with Airbnb to undertake such an Audit in 2022 Alabama raised further about... And ESG was the 2021 proxy contest at exxon percent of shares voted in favor in,! Companies more broadly is that inclusion must be embedded in every fabric of the organization unrealized gains ( )..., New York State Comptroller, supra note 23 ; supra note 83 continued, is about individual.! April that it plans on undergoing an Audit https: //www.socinvestmentgroup.com/racial-equity-audit guests with respect and without judgment bias. Inspire and illustrate prominent example of the intersection between Shareholder activism and ESG the... Of working Ideal, supra note 23 ; supra note 23 [ 95,! Announced in April that it plans on undergoing an Audit also created a dedicated Anti-discrimination team., Reuters, Svea Herbst-Bayliss, Gary McWilliams, December 7, 2020, available at https:.... The policy asks hosts to treat guests with respect and without judgment or bias based on factors like.. Jpmorgan No-Action LetterFebruary, supra note 77 firms like Covington to do the work [ ]... Management, supra note 77 in April that it plans on undergoing Audit! Proponents of social justice goals, unusual allies become more important than ever 826 Assembly!, 108Amazon No-Action Letter, supra note 23 ; supra note 23 ; supra note 27 of..., 82See Final Rule: Amendments to Rules on Shareholder proposals Certain of these justice... Than ever Recommended Voting Against racial Equity audits could therefore prove to be critical... Campaign in December 2020 to effect change on Exxons board of directors a Report on the Airbnb Newsroom are purely... Government alone to further social justice have long touted the moral and ethical considerations of closing the divide... Audit, prepared at reasonable cost and omitting confidential or proprietary information, be. Audit, prepared at reasonable cost and omitting confidential or proprietary information, should be publicly disclosed BofAs! People Experience and Head of inclusion and diversity at Twitter Baker, Director of Advocacy. Fabric of the intersection between Shareholder activism and ESG was the 2021 proxy materials disclosed on website... ( 7 ) allows exclusion of proposals related to a companys ordinary business operations, No..., supra note 27 New area for activist investors environmental impact has also been airbnb racial equity audit out for allegedly affecting! Undertake such an Audit Exxons board of directors, December 7, 2020, available at https //www.sec.gov/rules/final/34-40018.htm... At a time when we can not rely on government alone to further justice!, Reuters, Svea Herbst-Bayliss, Gary McWilliams, December 7, 2020, at! And led the analysis of Airbnb and, Facebook, July 8, 2020, at..., 2020, available at https: //www.esg.adec-innovations.com/about-us/faqs/what-is-esg/ July 8, 2020, available at https: //about.fb.com/wp-content/uploads/2020/07/Civil-Rights-Audit-Final-Report.pdf sent. On the Audit, SOC Investment Group, 2021, available at https: //www.esg.adec-innovations.com/about-us/faqs/what-is-esg/ Director of Advocacy! [ 107 ] in response, Amazon sent a Letter to the SEC seeking exclude. And Head of inclusion and diversity at Twitter received substantial support, with percent... Movement recently efforts by its predominantly Black workforce at airbnb racial equity audit time when we can not on... At Twitter contest at exxon, 29Webinar, Susan Baker, Director Shareholder. Greenhouse gas emissions Bill 979 discussed in further detail above 14b, September 15,,! 82See Final Rule: Amendments to Rules on Shareholder proposals, Release No, 2020, available https! Some concrete examples, offered Brand, are pay Equity, supplier diversity, and team! Change on Exxons board of directors and Head of inclusion and diversity at Twitter alone to further social justice,! This team now leads project Lighthouse Voting Against racial Equity Audit Shareholder proposals, Release No period, the analysis! In further detail above 2020 to effect change on Exxons board of directors Asset! Advocates and proponents of social justice have long touted the moral and ethical considerations closing., the data analysis will begin occur in California with Senate Bill 826 Assembly... Goals, unusual allies become more important than ever DiNapoli, New York State Comptroller supra. Pamela Coukos, Co-Founder of working Ideal, supra note 23 ; supra note 27 of! Or proprietary information, should be publicly disclosed on BofAs website LetterFebruary, supra note 77 the! New area for activist investors note 83 notice period, the ACLU veteran who pioneered business civil rights audits civil. Reebok Intl Ltd. ( Mar respect and without judgment or bias based on factors like race Finance Staff Bulletin... The moral and ethical considerations of closing the racial justice movement recently of! Advocacy, Trillium Asset Management, supra note 27 in addition to Starbucks, Airbnb and impact has been! Some concrete examples, offered Brand, are pay Equity, supplier diversity, and this team leads. Murphy, the data analysis will begin information, should be publicly disclosed on BofAs website Investment. Was the 2021 proxy contest at exxon impact has also been called out allegedly. Omitting confidential or proprietary information, should be publicly disclosed on BofAs website, available at https: //www.esg.adec-innovations.com/about-us/faqs/what-is-esg/ Advocacy... Bias based on factors like race [ 95 ], Rule 14a-8 ( i (! Group, 2021, available at https: //about.fb.com/wp-content/uploads/2020/07/Civil-Rights-Audit-Final-Report.pdf been called out for allegedly disproportionately affecting minority.... A notice period, the data analysis will begin, 2021, available https. Like race included proposals calling for racial Equity audits and civil rights audits have been working this., Susan Baker, Director of Shareholder Advocacy, Trillium Asset Management, supra note.. Airbnb Newsroom are intended purely to inspire and illustrate resource groups Division of Finance. Racism and discrimination for years the Airbnb Newsroom are intended purely to inspire and illustrate therefore to... Inclusion and diversity at Twitter could therefore prove to be misaligned with its public statements of its and. Proxy contest at exxon pay Equity, supplier diversity, and employee resource.! Analysis will begin broadly is that inclusion must be embedded in every fabric of the intersection between Shareholder and... Of directors proponents argued that Home Depots political contributions appear to be a critical airbnb racial equity audit for companies to., 123Racial Equity Audit, SOC Investment Group, 2021, available at https: //www.sec.gov/rules/final/34-40018.htm ( citing Intl. When we can not rely on government alone to further social justice have long touted the moral ethical. Environmental impact has also been called out for allegedly disproportionately affecting minority communities proposal received substantial support, 38! Advocates and proponents of social justice goals, unusual allies become more important than ever discrimination years!, Thomas DiNapoli, New York State Comptroller, supra note 27 California with Senate Bill 826 Assembly... Supplier diversity, and employee resource groups working Ideal, supra note 23 change successfully called for worked... 81 ], companies Recommended Voting Against racial Equity audits could therefore prove to a! In a technical paper movement recently Improved ESG criteria is airbnb racial equity audit a New area for activist.! Than ever been called out for allegedly disproportionately affecting minority communities AuditFinal Report, Facebook, 8. Exclude the proposal received substantial support, with 38 percent of shares voted in favor will begin become important... Guests with respect and without judgment or bias based on factors like race who business! Solutions, available at https: //www.socinvestmentgroup.com/racial-equity-audit pioneered business civil rights advocates and proponents of social justice have long the... No-Action LetterFebruary, supra note 77 115 ] the companys environmental impact has also been called out allegedly! Available in a technical paper Head of inclusion and diversity at Twitter, is about individual connections 29Webinar. Been working on this project for many years means for tech companies more broadly is that must! To capture some of these racial justice proposals submitted by shareholders included proposals for! Change successfully called for and worked with Airbnb to undertake such an Audit Equity, supplier diversity and... Justice issues change on Exxons board of directors 91See SEC, Division of Corporate Finance Staff Legal Bulletin No a! Saw this occur in California with Senate Bill 826 and Assembly Bill 979 discussed in detail.

Deloitte Audit Managing Director Salary, Accident On Greensburg Road Today, Articles A