Equal Employment Opportunity

Confronting the Glass Ceiling

At the highest levels of business, there is indeed a barrier only rarely penetrated by women or persons of color. Consider: 97% of the senior managers of Fortune 1000 industrial and Fortune 500 companies are white; 95 to 97% are male….

The research also indicates that where there are women and minorities in high places, their compensation is lower.

The U.S. Glass Ceiling Commission, 1995

If the glass ceiling is to ever fade into history, it will require aggressive efforts by corporations to undermine old prejudices and residual institutional barriers to upward mobility faced by women and people of color. At Trillium Asset Management Corporation (“Trillium”), we seek to invest in companies that are striving hard to achieve diversity at all levels, from the clerical pool to the board room. Corporations of the 21st century will simply not be able to compete effectively in the global economy unless their employees are informed by diverse perspectives, backgrounds and experiences.

What We’re Doing About This Issue

How We Screen

When we consider investing in a company, Trillium considers its reputation regarding fair hiring and promotion practices. We will avoid investing in companies with egregious, pervasive or longstanding patterns of discriminatory behavior. If problems emerge at a company in which we are already invested, we will engage with management in dialogue to discern how well and how seriously the company is addressing its challenges. We generally view divestment on social grounds as a last resort, to be used only if dialogue and shareholder proposals fail to have a positive impact upon corporate behavior.

Recent Dialogue & Shareholder Proposals

Since 1997, Trillium has participated in dialogue with Home Depot to urge the company to disclose publicly its EEO-1 data. We were part of a shareholder coalition that has filed a shareholder proposal at the company for the last three years that formally requests this data, and were delighted to withdraw the proposal when Home Depot agreed to disclose EEO-1 data beginning this year.

This year, we joined a group of shareholders in filing a similar proposal at Bank of America, and filed another at Morgan Stanley Dean Witter. In both cases, the companies have agreed to release EEO-1 data and we withdrew our proposals. We applaud these three corporations for their responsiveness to shareholders’ desire for greater transparency and accountability.

Why Workforce Diversity Data?

Most of America’s leading corporations have programs in place to recruit and retain women and racial/ethnic minorities for managerial and leadership positions. But can outside stakeholders evaluate whether a corporation is doing enough to diversify its ranks?

Trillium tracks a number of qualitative indicators that provide insight into corporate culture (for example, the results of employee surveys; third-party rankings such as Working Woman magazine’ s annual “Best Companies For Working Mothers”; the strength of work-family benefits packages; mentoring initiatives; etc.). However, we also place great importance on companies’ workforce diversity statistics, and what they reveal about the long-term success or failure of corporate affirmative action initiatives.

We ask companies to provide us with copies of their most recent “EEO-1 consolidated data form.” This is a one-page worksheet that is submitted to the federal government by all private companies with 100 or more employees, and all companies that hold federal contracts. We look at the last several years’ worth of data to see if a company has made progress in meeting its goals over time, and we also compare it to workforce diversity statistics for the company/ s industry sector.

Corporations are required to submit the EEO-1 form on an annual basis to the federal government, but do not have to disclose it to the public at large (and are permitted, in fact, to block attempts to acquire the data through Freedom of Information Act requests). We believe, however, that transparency provides one of the most effective incentives to make progress in meeting equal employment goals. We therefore work with other concerned shareholders to press companies to voluntarily make this data available to the public for the asking.