Corporate Racial Equity Tracker

Kavya Vaghul is Senior Director of Research and Ashley Marchand Orme is Director of Corporate Equity at JUST Capital. This post is based on a JUST Capital memorandum by Ms. Vaghul, Ms. Orme, Aleksandra Radeva, Daniel Krasner, Kim Ira, and Molly Stutzman. Related research from the Program on Corporate Governance includes Politics and Gender in the Executive Suite by Alma Cohen, Moshe Hazan, and David Weiss (discussed on the Forum here); Will Nasdaq’s Diversity Rules Harm Investors? by Jesse M. Fried (discussed on the Forum here); and Duty and Diversity by Chris Brummer and Leo E. Strine, Jr. (discussed on the Forum here).

In the two years since the killing of George Floyd and other Black Americans ignited a national reckoning with racial injustice, dozens of America’s largest companies have made unprecedented commitments to advancing racial equity in their workplaces and communities. Last year, we began tracking these commitments—as well as the concrete actions corporate America was beginning to take—as part of our 2021 Corporate Racial Equity Tracker. Below, we’ve updated our Tracker with the latest corporate performance data on these issues, tracking whether companies are making progress toward their goals, two years on.

With our recent survey research showing that 92% of Americans overall (up from 79% last year) and 95% of Black Americans believe it is important for companies to promote racial diversity and equity in the workplace, the demand for action on corporate commitments has only increased—especially considering that 68% of Americans, and 87% of Black Americans, agree companies have more work to do.

The 2022 Corporate Racial Equity Tracker offers an in-depth accounting of the commitments and actions announced by the 100 largest U.S. employers, through 23 metrics across six specific dimensions of racial equity:

  • Anti-Discrimination Policies
  • Pay Equity
  • Racial/Ethnic Diversity Data
  • Education and Training Programs
  • Response to Mass Incarceration
  • Community Investments

Key Findings

Across the 85 companies that we tracked in both 2021 and 2022, we saw the greatest increases in disclosure on workforce and board diversity data, as well as pay equity—areas where we’ve also seen rising pressure from investors:

  • Workforce diversity data disclosure increased by 6% from 86% to 91%.
  • Board diversity data disclosure increased by 13% from 84% to 95%.
  • Racial/ethnic pay equity analysis disclosure increased by 33% from 34% to 45%.
  • Disclosure of pay ratios by race/ethnicity increased by 71% from 14% to 24%.

But corporate America continues to lag behind on many issues. Across the 100 companies we tracked in 2022, we found that only:

  • 7% disclose their internal hire (or promotion) rate by race/ethnicity.
  • 9% disclose a local supplier/small business spend amount.
  • 11% report re-entry or second chance policies.
  • 14% report funding local public schools.
  • 21% report providing anti-harassment training, compared to 98% of companies that disclose an anti-harassment policy.
  • 22% disclose the actual results of the pay equity analysis, i.e. pay ratios by race/ethnicity.
  • 23% disclose diversity targets for hiring, workforce composition, promotion, or retention by race/ethnicity.
  • 36% disclose anti-prison labor policies for their suppliers, while only 14% disclose anti-prison labor policies in their own operations.
  • 42% disclose a supplier diversity spend amount.

Over time, the Tracker will continue to evolve, growing to feature more Russell 1000 companies as well as additional actions related to racial equity. We will also continue to build on our broader racial equity initiative, providing updated guidance to corporate leaders—like our 2021 CEO Blueprint for Racial Equity—as well as additional issue analyses and insights on leading practices related to our findings.

The Corporate Racial Equity Tracker

Delve into the Corporate Racial Equity Tracker below:

  • Explore corporate commitments/actions via blue “tags.” Sort by company, industry, and the # of employees. Click on commitment/action (blue box) to link to the original data source.
  • “Drill down” to explore details on specific commitments/actions within a given dimension. Click on a column header to sort.
  • Click on or search for a company to see a comprehensive list of its responses and descriptions of all the commitments and actions.


This Tracker uses information primarily found on company websites, corporate press releases, sustainability reports, diversity, equity, and inclusion reports, and company SEC filings to evaluate what steps America’s largest public employers—the 100 largest companies by U.S. employment size in the Russell 1000 Index—have taken to promote racial equity. The Tracker currently looks at six dimensions, or “tags,” of company commitments or actions related to racial equity, ranging from community investments to pay equity.

When a company meets the criteria for a particular response (listed below), it receives a “tag” in the Tracker above, indicating that it has disclosed that commitment or action. Each tag links to the original data source. By using the “Drill Down” feature, you can explore more detailed information about a company’s response: for example, by filtering by the tag “Response to Mass Incarceration,” you can find out if a company discloses multiple policies, including a Re-Entry Policy, a Company Anti-Prison Labor Policy, or a Supplier Anti-Prison Labor Policy. The six dimensions—and their underlying metrics—include:

Anti-Discrimination Policies: Company discloses an anti-harassment policy, racial and ethnic diversity targets, and/or implements anti-harassment training, a discrimination grievance mechanism, or a harassment grievance mechanism. A harassment grievance mechanism is what a company implements for employees to submit harassment or sexual harassment concerns whereas a discrimination grievance mechanism is for employees to safely report concerns or issues relating to discrimination more broadly.

Community Investments: Company discloses the dollar amount spent on diverse suppliers and local suppliers, and/or the company provides funding for local schools. Funding for local education measures whether the company donates to educational programs for primary or secondary school, excluding employee donation-matching programs to schools and scholarships.

Education and Training Programs: Company provides tuition assistance, an apprenticeship program, and/or company discloses its internal hiring rate by race or ethnicity or the average hours of training or career development per employee. Internal hiring rate by race or ethnicity measures whether a company publicly discloses the proportion of vacancies that have been filled from current employees disaggregated by race and ethnicity.

Pay Equity: Company conducts a pay equity analysis to examine pay discrepancies between white and racially or ethnically diverse employees. Drill down to explore details about the frequency of analysis, whether or not a company discloses the results of its pay equity analysis, as well as its adjusted People of Color-to-White pay ratio. For example, if a company reports that employees who identify as racially and ethnically diverse make $0.94 for every dollar employees who identify as white make, the People of Color-to-White pay ratio disclosed would be $0.94.

Racial/Ethnic Diversity Data: Company discloses workforce and/or board demographic data. Board demographic data is measured as disclosure of board racial or ethnic diversity as well as the disclosed percent of racially or ethnically diverse directors on a company’s board. Company workforce demographic data is measured by three different levels of detail: Overall People of Color Data, Detailed Race/Ethnicity Data, and EEO-1 Report or Intersectional Data by Gender and Race/Ethnicity. Overall People of Color Data indicates that the company has disclosed information about the overall number or share of racially or ethnically diverse workers without disaggregating the data by race/ethnicity groups; Detailed Race/Ethnicity Data indicates that a company has disclosed the number or share of workers for at least one racially or ethnically diverse group such as Asian, Black, or Latinx, among others; and EEO-1 Report or Intersectional Data by Gender and Race/Ethnicity indicates that a company has disclosed the number or share of workers by gender, as well as by race or ethnicity, or information that would typically be found in an EEO-1 Report.

Response to Mass Incarceration: Company discloses a re-entry policy, anti-prison labor policy, and/or supplier anti-prison labor policy. A re-entry or fair chance policy is defined as a policy that removes employment barriers for people with criminal records. Anti-prison labor and supplier anti-prison labor policies are counted when a company explicitly bans voluntary or involuntary prison labor in its operations and in its supply chain, respectively.

Each corporation’s number of U.S. employees is based on the company’s total employment count in 2020 if business in the U.S. accounted for more than 95% of revenues or long-term assets. These headcounts are further adjusted for all additions of employees through acquired businesses or subtractions of employees through divested businesses. In cases where the U.S. headcount is not disclosed in company filings or publicly available material, we estimate the total U.S. employment size by multiplying the global employment size by the ratio of U.S. sales and long-term assets to global sales and long-term assets.

Tracker Updates

The Corporate Racial Equity Tracker was originally released in April 2021. We have continued to track the same six dimensions in 2022 but expanded or refined the underlying metrics within three of the six dimensions to better capture corporate transparency and actions supporting racial equity. Within the Anti-Discrimination Policies dimension, we substituted the general quantitative diversity targets metric with a more granular race and ethnicity diversity targets metric to shine a light on corporate commitments as they relate to race and ethnicity specifically. Additionally, we removed the EEO Policy metric in favor of more performance-oriented metrics. Within the Education and Training Programs dimension, we removed the career development program metric and added two metrics that capture corporate transparency on equitable outcomes of a career development program: average hours of training or career development per employee and disclosure on internal hiring or promotions by race or ethnicity. Similarly, within the Community Investments dimension, we replaced supplier diversity policy and local sourcing policy metrics with diverse supplier and local supplier spend disclosure metrics to measure if companies are sharing the extent to which they support diverse and local suppliers. We also updated the stringency of our funding for local education metric to only capture companies that donate funds or infrastructural materials to primary or secondary schools, excluding providing ad-hoc educational materials and other non-infrastructural forms of assistance. Instead of analyzing disclosure on general policies, we have included metrics that assess if companies are transparent about how and to what degree their policies support employees and communities of color.

In addition, the Tracker universe has changed over time because of differences between the 2020 and, previously, 2019 U.S. employment count used to identify the 100 largest U.S. employers. As a result, the 2022 Tracker has 85 overlapping companies with the 2021 Tracker, with 15 new companies not included in last year’s Tracker.

All data supporting this Tracker has been updated as recently as May 2022. The Tracker was last updated on May 31, 2022 at 6AM ET.

The Tracker can be viewed on the JUST Capital site here.

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