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Mentions of diversity are featuring prominently in companies’ human capital disclosures this proxy season; however, most companies are staying mum on the numbers. An analysis of 10-Ks led by big companies by mid-April shows that only about a third disclosed any workplace demographic data on race and ethnicity. Fewer still broke the data out into specific demographic groups.

The new human capital management disclosure requirement was introduced by the Securities and Exchange Commission for the 2021 proxy season and requires companies to disclose material factors related to the management of the workforce. However, the SEC provided little guidance on what exactly companies should disclose, leaving it up to them to determine what would be material to investors.

The type of information disclosed so far varies widely. Publishing demographic data in SEC filings is different than publishing the same data via other avenues, says Deb Lifshey, managing director at Pearl Meyer.

“Some companies could be worried that the figures may change next year,” says Lifshey. “If you put it in [a filing] one year and take it out the next year, people notice,” she says, which could put pressure on companies to explain why figures went down, for example.

Similarly, many companies are hesitant to make aspirational statements about their diversity goals, says Lifshey. This is because, despite efforts to recruit and hire more diverse candidates, hiring pools vary from year to year, she says.

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