WHEREAS: Consistent, comparable, and comprehensive disclosure of workforce demographic data enables investors to more accurately evaluate the effectiveness of corporate diversity, equity, and inclusion (DEI) policies and practices.
The business case for advancing DEI is clear. Recent research has confirmed a positive association between diverse representation in management and positive financial performance.1 Diverse and inclusive workplaces encourage varied perspectives, which enables companies to better anticipate shifts in consumer preferences, reduce costly turnover, and increase productivity and morale.23 Such companies are better positioned to recruit the most talented employees from the broadest possible labor pool. Conversely, charges of discrimination can result in costly litigation and reputational damage.
Major institutional investors share our belief that transparency and public accountability are essential components of diversity, equity, and inclusion leadership. For example, on behalf of the New York City Employee Retirement Systems, New York City’s Comptroller has moved 90 companies to make public their EEO-1 reports.4
Despite recent progress, women and people of color remain significantly underrepresented in management positions at US companies. Women hold 41% of officials and managers positions compared to 48% of private industry jobs reported to the EEOC. The numbers are proportionately worse for Black and Hispanic employees, who comprise 7% and 8% of officials and managers, respectively, though each group accounts for 15% of total employment.5 Quantitative data is sought so investors can assess and compare the effectiveness of companies’ diversity, equity, and inclusion programs and foster progress.
Valmont Industries, Inc. (“Valmont”) lags industry peers in disclosing comprehensive workforce composition data, diminishing shareholder’s ability to evaluate the effectiveness of its DEI policies and practices. Companies that report currently or have committed to disclose EEO-1 data include First Solar, Inc.,6 Hubbell Incorporated,7 and Harsco Corp.8
Valmont already submits the data—disclosing its EEO-1 report is a cost-effective means to demonstrate DEI leadership while providing investors with credible, decision-useful data. Although Valmont established a goal to increase the racial/ethnic representation of its workforce, its limited disclosure of high-level workforce demographic data does not provide shareholders the disaggregated workforce data needed to appropriately analyze and assess the company’s progress against its representation goal nor the overall effectiveness of its DEI efforts.