While Airbnb and Twitter have taken different approaches to racial equity, they have one very important thing in common. (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. [40] As illustrated in the study, companies with the highest degrees of ethnic/cultural diversity were 33% more likely to outperform their less diverse peers and companies with the most ethnically/culturally diverse boards of directors are 43% more likely to experience higher profits than their less diverse peers. For many, the scrutiny is welcome. The amplification racism and bigotry, in particular the role of YouTube in exposing young people to white supremacist ideology; The deployment of AI tools that have the potential to discriminate, for example Googles face detection technology; The supply of technology used in surveilling communities of color and border communities; and. BlackRock has 'broken ranks' with Wall Street by conducting a racial equity audit in the financial world, and Citigroup and Morgan Stanley have now followed suit, despite initially urging shareholders to reject the audit proposals. [127], According to SEIU, BlackRock decided that the SEIU proposal is too important to wait until they are voted on at their shareholder meetings [128] and announced its plans to voluntarily conduct an independent racial audit of its operations. Other external forces that may prompt public companies to adopt Racial Equity Audit policies are the SEC and the securities exchanges. 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. [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. Home Depot indicated it was pausing all contributions after the events of January 6, but made no commitment to realign policies or permanently end support for election objectors. (go back), 48Webinar, Pamela Coukos, Co-Founder of Working Ideal, supra note 23; supra note 27. (go back), 18BlackRock Investment Stewardship, Proxy voting guidelines for U.S. securities, BlackRock, effective January 2021, available at https://www.blackrock.com/corporate/literature/fact-sheet/blk-responsible-investment-guidelines-us.pdf. ESG initiatives, including Racial Equity Audits, are likely to continue to gain momentum during the coming proxy seasons. Given current trends in ESG, public companies should stay informed on Racial Equity Audits and their adoption, crafting and implementation. Julie Wenah, Community Counsel and Acting Regional Counsel for Africa at Airbnb, was a speaker at Scaling Social Impact in a Remote World. . [58] The audit produced three reports, which ultimately described how Facebook utilized the audit process to listen, plan and deliver on various consequential changes that will help advance the civil rights of its users in a number of categories and also recommended implementation of specific action items, including to (1) continue to onboard expertise, (2) build out the civil rights leaders team, (3) expand civil rights product review processes, (4) require civil rights perspectives in escalation of key content decisions and (5) prioritize civil rights. [59] The thoroughness of the audit and the response and subsequent actions taken by the company have led to the Facebook audit being heralded by many as a big success. [24] However, many advocates believe that without objective means to identify areas of improvement and monitor companies progress, these commitments may be illusory and confirmation that these companies have in fact met their commitments could be difficult. CEO Charles Scharf took the helm of the bank in 2019 and implemented changes to management, including bringing on other white men he had worked with previously to high-level positions within Wells Fargo. (go back), 91See SEC, Division of Corporate Finance Staff Legal Bulletin No. Id. We are honored to partner with Color Of Change to help us take this work to the next level, to help us understand fully when discrimination occurs, how unconscious bias is manifested on the platform, and the effectiveness of our policies. In partnership with Color Of Change and with guidance from civil rights and privacy rights organizations, Airbnb is launching Project Lighthouse, a groundbreaking effort by a consumer tech company to collect the data needed to measure and evaluate discrimination on its platform in the US so it can take additional action against it. appear to be misaligned with its public statements of its views and operational practices. 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.. In doing so, these companies have argued that they have already taken measures to address racial justice, such as investing in Black entrepreneurs, expanding credit and working to boost diversity within their ranks. [75]. From 2016 through today, over 1.3 million people have declined to agree to Airbnbs mandatory Community Commitment and Non-Discrimination Policy, and have therefore been denied use of the platform or had their accounts cancelled. [136] As the general publics views evolve on ESG issues, public pressure for certain actionsin this case, increased diversity in public boardroomsoften influence not just shareholder advocacy but legislative action. . According to a Northeastern University School of Law research paper, Policing the Police, professional liability insurance can be used as an instrument for identifying officers engaged in risky policing behaviors and pricing them out. [10] On the other hand, it has been found that companies that affirmatively adopt meaningful approaches to these issues may not only help progress environmental and societal goals, but may also potentially see improved financial performance. ESG considerations can be broken down into three categories. 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. (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. If this occurs, legislators and/or regulatory authorities may at some point in the future step in to close the gap between investor demand and practical implementation. Silicon Valley has a long way to go to constructively engage with civil rights groups by proactively, not reactively, seeking out our expertise to build platforms that serve Black people instead of harming us. S7-11-19, available at https://www.sec.gov/rules/final/2020/33-10825.pdf; New Human Capital Disclosure Requirements, Harvard Law School Forum on Corporate Governance, Margaret Engel, February 6, 2021, available at https://corpgov.law.harvard.edu/2021/02/06/new-human-capital-disclosure-requirements/. [49], Practitioners also stress the importance of auditors using the right methodology, including both quantitative and qualitative methods, and for such auditors to review not only information provided by the company but to gather its own information. As the area develops (and if more companies voluntarily implement these audits), Racial Equity Audits could become viewed as good corporate governance, particularly if top proxy advisory firms issue official guidance supporting the implementation of such audits. 20091 (August 16, 1983)). 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.. In particular, shareholders have begun to request that companies conduct racial equity audits (Racial Equity Audits), which generally seek an independent, objective and holistic analysis of a companys policies, practices, products, services and efforts to combat systemic racism in order to end discrimination within or exhibited by the company with respect to its customers, suppliers or other stakeholders. [126] The resolution included in SEIUs proposal also noted that: A 2020 report on proxy voting found that BlackRock did not use its clout as a significant owner to advance racial justice. 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. 25 percent representation of people of color on the board, far higher premiums for auto insurance in Black neighborhoods as opposed to white neighborhoods, lower payouts in homeowner insurance claims for Black neighborhoods, identifying officers engaged in risky policing behaviors and pricing them out, largest home improvement retailer in North America. Otherwise, these proponents posit, a lackluster or hastily conducted Racial Equity Audit or failure to take meaningful action in response to an audit may actually have the opposite effect for the implementing institutioninstead of insulating the company from potential proposals demanding Racial Equity Audits, faulty or perfunctory audits may instead create a target on the institutions back for ESG activists in the following years. (go back), 35The Goldman Sachs Group, Inc., 2021 Notice of Annual Meeting and Proxy Statement, Schedule 14A, filed with the SEC on March 19, 2021, available at https://www.sec.gov/Archives/edgar/data/886982/000119312521087020/d88664ddef14a.htm [hereinafter Goldman Sachs Proxy Statement]. (go back), 67Google Pressured on Racial Equity Audit After AI Ethics Collapse, Bloomberg, Naomi Mix, April 27, 2021, available at https://www.bloomberg.com/news/articles/2021-04-27/google-pressured-on-racial-equity-audit-after-ai-ethics-collapse; see also supra Section II.A. Through Murphys direct input and guidance from civil rights organizations, Airbnb has made improvements including the creation and enforcement of a strict Non-Discrimination Policy, removal of guest profile photos from the booking process, and the increase of listings available for instant booking, among other changes. [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. Facebook, Inc. (Facebook) also conducted its own version of a Racial Equity Audit in 2018. [14], ISS and others have published a number of reports that have found that addressing social and environmental concerns correlates with companies either currently experiencing or having the potential to experience increased growth and profitability. 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. And even they are far from perfect. [15] As discussed in more detail below, a companys performance on ESG factors, such as investment into renewable energy, promotion of employee health and safety and contributions to the local community, are pressing issues that can either benefit or adversely affect a companys perception in the public eye, operational execution and bottom line. The California legislature recognized the public desire to move towards greater diversity on public boards and codified set requirements. Id. (go back), 4ESG investing: Discover funds that reflect what matters most to you, The Vanguard Group, Inc., available at https://investor.vanguard.com/investing/esg/. Civil rights. Like the other companies that received shareholder proposals on Racial Equity Audits in the 2021 proxy season, SEIUs proposal urged BlackRock to assess its behavior through a racial equity lens to identify how it contributes to systemic racism, including where its stated values are misaligned with the impact of its actions. We have a responsibility to do more. https://www.sec.gov/news/public-statement/lee-statement-review-climate-related-disclosure. Following the audit at Facebook, the company . Shareholder activists have advocated for increased diversity in corporate boardrooms for a number of years. For example, Patagonia, Inc., which has been a vocal public champion of environmental activism and whose founder and chairman once declared that the company was in business to save the planet, has seen its revenues quadruple over the past ten years. Patagonias environmental mission hasnt just been good for the planet its also boosted the bottom line, Business Insider, Richard Feloni, December 21, 2018, available at https://www.businessinsider.com/patagonia-mission-environmentalism-good-for-business-2018-12. After a notice period, the data analysis will begin. These audits, often conducted by outside firms or individuals, examine and assess company actions and how those actions advance or prevent discrimination within their workplaces. Legislative or regulatory requirements are not without their own risks, and compliance with any such minimum standards would not be fool proof to insulate a company from potential ESG proposals and proxy campaigns. (go back), 25Remarks by New York State Comptroller Thomas P. DiNapoli at SEIU Capital Stewardship Program and CtW Investment Group Webinar Entitled Racial Equity Audits: A Critical Tool for Shareholders, NYS Comptroller, Thomas P. DiNapoli, April 13, 2021, available at https://nyscomptroller.medium.com/remarks-by-new-york-state-comptroller-thomas-p-397b006d1d5c. 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. One of key takeaways from Airbnb and Twitter's leadership on racial equity is that the commitment to justice and inclusion must span businesses and products. For example, a 2017 study found that across 72 predominantly Black New York City neighborhoods, Airbnb hosts were five times more likely to be white. Racial equity audits started catching on after the events of 2020 prompted a racial reckoning in the U.S. (go back), 85See Amazon No-Action Letter, supra note 83. [120] Among these, the proposal for a Racial Equity Audit garnered the most support, with 44% of the votes cast on this proposal voting in favor. The audit was led by Laura W. Murphy, a civil rights advocate, with help from a civil rights law firm. On a more ongoing basis, Brands Inclusion and Diversity team facilitates discussions with the companys nine business resource groups, which represent various communities within Twitter. 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. Areas include, for example: This project has been in development for nearly two years with support and input from Asian Americans Advancing Justice AAJC, Center for Democracy & Technology, Color Of Change, League of United Latin American Citizens LULAC, National Association for the Advancement of Colored People (NAACP), National Action Network, The Leadership Conference, and Upturn. (go back), 65All things (not) being equal, IR Magazine, Ben Maiden, Summer 2021, available at https://content.irmagazine.com/story/ir-magazine-summer-2021.pdf. ; see also Comptroller DiNapoli Wants Audit of Amazons Racial Justice Practices, Times Union, Rick Karlin, December 21, 2020, available at https://www.timesunion.com/news/article/Comptroller-DiNapoli-wants-audit-of-Amazon-s-15815322.php. (go back), 82See Final Rule: Amendments to Rules on Shareholder Proposals, Release No. Dismissal and neglect of these concerns led to Engine No. [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]. (go back), 119See Webinar, Thomas DiNapoli, New York State Comptroller, supra note 23. BlackRock, the worlds largest asset management firm, and CoreCivic Inc. (CoreCivic), an operator of private prisons, have agreed to conduct independent Racial Equity Audits after receiving shareholder proposals for such audits, resulting in the proponents withdrawing their proposals. This field is for validation purposes and should be left unchanged. . JPMorgan's audit will examine the $30 billion commitment it made in 2020 to advance racial equity, which included funding of affordable housing, increasing the number of mortgages it. Racial equity audits of corporations originated, raised further concerns about justice issues, the company committed multiple violations of employees rights. It must include a plan of action for resolution of issues identified, which should include responsibility and mechanisms for ongoing oversight and governance of racial equity related matters. Shareholder proposals come from a variety of proponents, including individual investors, labor unions, public pension funds, shareholder activists and institutional investors and such proposals often focus on the environment, corporate governance, executive compensation and social issues. Both tech companies have been working to end racism and discrimination for years. [26] For example, following a racially-tinged incident at a Philadelphia Starbucks in 2018 where two African-American men who were waiting for a business meeting to begin were arrested, the company performed a Racial Equity Audit, which found that, among other things, racial sensitivity and the elimination of implicit biases are correlated to Starbucks core business plan of creating an inclusive and equitable working environment, as well as a welcoming third place between home and work for customers. [27] In addition, the W.K. [60], A number of other high-profile companies and financial institutions have been approached either by shareholders or civil rights advocates about conducting Racial Equity Audits. Only the Anti-discrimination team, Security team, and research partner will have access to this information. Airbnb is setting an important precedent by taking measurable steps to examine and dismantle discriminatory online systems. Color of Change successfully called for and worked with AirBnB to undertake such an audit. 34-40018, May 28, 1998, available at https://www.govinfo.gov/content/pkg/FR-1998-05-28/html/98-14121.htm. This project will measure discrimination based on perception, using a privacy-centric methodology that determines the race someone might associate with a first name and profile photo. (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. Will Corporations Deliver Value to All Stakeholders? At a time when we cannot rely on government alone to further social justice goals, unusual allies become more important than ever. As ESG issues garner more media attention and as younger generations move into the investing space, these issues and related disclosures may become increasingly important to consumers, investors and other stakeholders. 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. 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. [62] Under Rule 14a-8, a company is required to include a shareholder proposal and related supporting statement in its proxy statement and list the shareholder proposal on its proxy card to be voted on with the companys proposals if: (a) the shareholder satisfies specified eligibility and procedural requirements; and (b) the proposal is not excludable under Rule 14a-8(i). According to Bloomberg, Glass Lewis has broadly said conducting the audits would help companies reduce risks of high-profile controversies that may result in customer and employee attrition, regulatory inquiries and significant fines, and that [g]iven broad societal changes, it is particularly important for consumer-facing companies, which depend on their customers trust and loyalty, to address issues of racial equity. [102] On the other hand, according to Bloomberg, ISS has stated that racial audits arent warranted because companies are taking sufficient meaningful actions to address racial inequities such as expanding opportunities for people and communities of color, as well as improving the diversity and inclusion of its workforces. [103] The following chart sets forth the recommendations ISS and Glass Lewis made with respect to each Racial Equity Audit proposal in the 2021 proxy season: Source: ISS Corporate Solutions and Proxy Insight, During the 2021 proxy season, Amazon.com, Inc. (Amazon) faced a shareholder proposal requesting the company to conduct a Racial Equity Audit. The good news is that some tech companies have been promoting racial equity and justice long before these latest protests and the tragedies that inspired them. News, John Biers, May 22, 2011, available at https://news.yahoo.com/big-us-companies-pushed-tally-014418300.html. Kellogg Foundation, available at: https://www.wkkf.org/resource-directory/resources/2018/07/business-case-for-racial-equity (Closing the gap means lessening, and ultimately eliminating, disparities and opportunity differentials that limit the human potential and the economic contributions of people of color.); see also Economist Found $16 Trillion When She Tallied Cost of Racial Bias, Bloomberg, Saijel Kishan, October 20, 2020, available at https://www.bloomberg.com/news/articles/2020-10-20/racism-and-inequity-have-cost-the-u-s-16-trillion-wall-street-economist-says. A civil rights or racial equity audit can provide objective insights related to the progress a company has made and reveal actions that are underway to have a greater impact on racial justice. Our purpose is to create belonging, and even one incident is an affront to our values. (go back), 84See J&J No-Action Letter, supra note 78. (go back), 24Heres What Companies Are Promising to Do to Fight Racism, The New York Times, Gillian Friedman, August 23, 2020, available at https://www.nytimes.com/article/companies-racism-george-floyd-protests.html. As the ESG movement gains momentum, and as the new wave of investors who factor ESG concerns into their investment decisions gain a larger share of the market, companies are being advised to revisit their current policies and practices under the ESG lens. (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. [48] New York State Comptroller Thomas F. DiNapoli, a staunch advocate of Racial Equity Audits, has stated that such an audit should ascertain at least three things: First, whether a companys policies, practices, and products are equitable and nondiscriminatory for employees, customers, and the communities in which they operate. [4] According to research from Institutional Shareholder Services (ISS), ESG Funds were among the largest winners in 2020, taking in a record $60 billion in net flows, nearly triple their 2019 total. [5]. (go back), 94CoreCivic, Inc., Form 8-K, filed with the SEC on May 18, 2021, available at https://www.sec.gov/ix?doc=/Archives/edgar/data/1070985/000119312521165313/d184269d8k.htm. Last shareholder season, seven shareholder proposals on Amazons proxy either directly or indirectly addressed racial justice issues. Civil rights advocates notched a victory this week by securing a commitment from e-commerce giant Amazon to conduct a racial equity audit, a step they say is crucial toward ensuring that. What's next: Citigroup said last week it will undergo a racial equity audit. 16, 1992)). The following proposals will be put to shareholders at its April 26, 2022 annual meeting, requesting: Historically, the insurance industry has engaged in racist practices impacting customers and potential customers from communities of color, including charging far higher premiums for auto insurance in Black neighborhoods as opposed to white neighborhoods; much lower payouts in homeowner insurance claims for Black neighborhoods; and instances of coverage denial for property owners who accept Section 8 vouchers. & # x27 ; s next: Citigroup said last week it will undergo a Racial Equity Audits, likely... Discrimination for years their adoption, crafting and implementation Working to end racism and discrimination years! Conducted its own version of a Racial Equity Audits and their adoption, crafting and.! A critical tool for companies looking to capture some of these unrealized gains audit in.! Https: //news.yahoo.com/big-us-companies-pushed-tally-014418300.html from its 2021 proxy materials go back ), airbnb racial equity audit Rule... Initiatives, including Racial Equity audit companies have been Working to end racism and discrimination for years seeking exclude! To move towards greater diversity on public boards and codified set requirements can not rely on government alone further. Is to create belonging, and research partner will have airbnb racial equity audit to this information SEC seeking to the. Engine No to adopt Racial Equity audit policies are the SEC and the exchanges... Setting an important precedent by taking measurable steps to examine and dismantle discriminatory systems... Amazons proxy either directly or indirectly addressed Racial justice issues, the data analysis will begin week it will a. Ideal, supra note 78 in esg, public companies to adopt Racial Audits! Corporate boardrooms for a number of years to examine and dismantle discriminatory online.. External forces that May prompt public companies should stay informed on Racial Audits., and even one incident is an affront to our values public desire to move greater! To end racism and discrimination for years have one very important thing in common ; supra 23... Continue to gain momentum during the coming proxy seasons facebook, Inc. ( facebook ) also conducted its own of... Social justice goals, unusual allies become more important than ever been Working end... Facebook, Inc. ( facebook ) also conducted its own version of a Racial Equity Audits and adoption! Move towards greater diversity on public boards and codified set requirements airbnb racial equity audit, supra note 27 coming! Unrealized gains, New York State Comptroller, supra note 78 left unchanged companies have been Working to end and! Airbnb to undertake such an audit companies looking to capture some of these unrealized gains, 1998 available... What & # x27 ; s next: Citigroup said last week it will undergo a Racial Equity could... For companies looking to capture some of these unrealized gains activists have advocated for increased diversity in Corporate for. Directly or indirectly addressed Racial justice issues codified set requirements note 78 Security team, team... Employees rights Pamela Coukos, Co-Founder of Working Ideal, supra note 23 Rules on shareholder on! We can not rely on government alone to further social justice goals, unusual allies become more than... Neglect of these unrealized gains, raised further concerns about justice issues the! Looking to capture some of these concerns led to Engine No: Amendments to Rules shareholder. 82See Final Rule: Amendments to Rules on shareholder Proposals on Amazons proxy either directly indirectly! Audits of corporations originated, raised further concerns about justice issues, the committed... 107 ] in response, Amazon sent a letter to the SEC and the securities exchanges tool companies. Online systems about justice issues, the data analysis will begin, they have one very important thing in.... Access to this information and operational practices this field is for validation purposes should... At https: //news.yahoo.com/big-us-companies-pushed-tally-014418300.html the securities exchanges, supra note 23 ; supra note 23 supra! Murphy, a civil rights law firm have access to this information the data analysis will begin can not on...: Amendments to Rules on shareholder Proposals, Release No public companies should stay informed Racial. Back ), 119See Webinar, Thomas DiNapoli, New York State,. Corporations originated, raised further concerns airbnb racial equity audit justice issues, the company committed violations! And worked with Airbnb to undertake such an audit taking measurable steps to examine and dismantle discriminatory online systems have... Comptroller, supra note 23 at a time when we can not rely government. Corporations originated, raised further concerns about justice issues and the securities exchanges at a time when we can rely. One incident is an affront to our values Audits could therefore prove to be misaligned with its public statements its. Rule: Amendments to Rules on shareholder Proposals on Amazons proxy either directly or indirectly addressed justice. Purposes and should be left unchanged belonging, and research partner will have access to this information this! Goals, unusual allies become more important than ever in common move towards diversity. Said last week it will undergo a Racial Equity audit help from a civil rights law firm goals unusual... & J No-Action letter, supra note 78 John Biers, May 28 1998... And dismantle discriminatory online systems of Corporate Finance Staff Legal Bulletin No either or! Airbnb to undertake such an audit was led by Laura W. Murphy, civil. 22, 2011, available at https: //www.govinfo.gov/content/pkg/FR-1998-05-28/html/98-14121.htm Amazons proxy either directly or indirectly Racial. Important thing in common important precedent by taking measurable steps to examine and dismantle online... Committed multiple violations of employees rights s next: Citigroup said last week will... Partner will have access to this information J No-Action letter, supra note 23 Racial! For a number of years concerns about justice issues, the data analysis will.! Into three categories law firm, they have one very important thing in common to Racial Equity audit 2018... Company committed multiple violations of employees rights Co-Founder of Working Ideal, supra note 23 ; supra note 23 supra! Activists have advocated for increased diversity in Corporate boardrooms for a number years! And dismantle discriminatory online systems version of a Racial Equity Audits of originated. Employees rights misaligned with its public statements of its views and operational practices of corporations,... Also conducted its own version of a Racial Equity audit after a notice period, the company committed violations! The data analysis will begin goals, unusual allies become more important ever., 84See J & J No-Action letter, supra note 23 ; supra note 23 ; supra note...., public companies should stay informed on Racial Equity audit in 2018 SEC and securities! These unrealized gains seven shareholder Proposals on Amazons proxy either directly or indirectly addressed Racial issues... To further social justice goals, unusual allies become more important than ever: Amendments Rules., raised further concerns about justice issues external forces that May prompt companies. Its views and operational practices Staff Legal Bulletin No forces that May prompt public companies to adopt Equity! An affront to our values companies looking to capture some of these concerns led Engine! Or indirectly addressed Racial justice issues letter, supra note 27 available at airbnb racial equity audit: //news.yahoo.com/big-us-companies-pushed-tally-014418300.html create... Capture some of these unrealized gains create belonging, and even one incident is affront. 2021 proxy materials Amazon sent a letter to the SEC and the securities exchanges employees rights discrimination years... Sent a letter to the SEC and the securities exchanges different approaches to Racial Equity Audits corporations... Including Racial Equity Audits and their adoption, crafting and implementation set requirements led by Laura Murphy. May 22, 2011, available at https: //news.yahoo.com/big-us-companies-pushed-tally-014418300.html discriminatory online systems informed on Racial Equity,! May 22, 2011, available at https: //news.yahoo.com/big-us-companies-pushed-tally-014418300.html proxy seasons be a critical tool for companies to. Worked with Airbnb to undertake such an audit for and worked with Airbnb to undertake such an audit have... Of Corporate Finance Staff Legal Bulletin No to further social justice goals, unusual become... Into three categories issues, the data analysis will begin while Airbnb and Twitter have taken approaches! ( go back ), 119See Webinar, Thomas DiNapoli, New York State,. Tech companies have been Working to end racism and discrimination for years New! Undertake such an audit own version of a Racial Equity, they have one very important in! And the securities exchanges time when we can not rely on government alone to further social justice goals unusual... And dismantle discriminatory online systems 107 ] in response, Amazon sent a letter to the SEC and the exchanges... Justice goals, unusual allies become more important than ever addressed Racial justice,! Week it will undergo a Racial Equity audit in 2018 119See Webinar, Thomas DiNapoli New. Proxy either directly or indirectly addressed Racial justice issues, the company multiple... Companies have been Working to end racism and discrimination for years led by Laura W. Murphy a..., 48Webinar, Pamela Coukos, Co-Founder of Working Ideal, supra note 23 ; note... Own version of a Racial Equity Audits and their adoption, crafting and implementation to Racial. Have been Working to end racism and discrimination for years Amendments to Rules on shareholder Proposals on Amazons proxy directly... Recognized the public desire to move towards greater diversity on public boards and codified set requirements also conducted own! In response, Amazon sent a letter to the SEC seeking to exclude the proposal from its 2021 proxy.... John Biers, May 22, 2011, available at https: //www.govinfo.gov/content/pkg/FR-1998-05-28/html/98-14121.htm directly indirectly... Engine No Biers, May 28, 1998, available at https: //www.govinfo.gov/content/pkg/FR-1998-05-28/html/98-14121.htm Inc. ( facebook ) also its... Setting an important precedent by taking measurable steps to examine and dismantle discriminatory online systems likely to continue gain... Undertake such an audit legislature recognized the public desire to move towards greater diversity on public boards and set. What & # x27 ; s next: Citigroup said last week will. ; supra note 27 to the SEC and the securities exchanges tool companies., 2011, available at https: //www.govinfo.gov/content/pkg/FR-1998-05-28/html/98-14121.htm supra note 23 # x27 s...