(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. [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. New York State Common Retirement Fund et al. (go back), 85See Amazon No-Action Letter, supra note 83. Companies that dismiss these concerns or lag behind their peers in addressing ESG matters may find themselves in the crosshairs of investors and proxy advisory firms, or even state legislatures and federal agencies. The racial equity audit proposal at Citigroup Inc. garnered 39% of shareholders' support, while the one at Amazon.com Inc. secured 44% of investors' backing, according to Bloomberg Intelligence data. Airbnb is setting an important precedent by taking measurable steps to examine and dismantle discriminatory online systems. (go back), 106Other shareholders joining the proposal were: (1) the Praxis Growth Index Fund; (2) CommonSpirit Health; (3) the Adrian Dominican Sisters; (4) Catherine Donnelly Foundation; (5) Monasterio Pan de Vida; (6) Reynders, McVeigh Capital Management, LLC; (7) the Congregation of the Sisters of St. Joseph of Peace; (8) the Sisters of the Holy Names of Jesus and Mary U.S.-Ontario Province Corporation; and (9) Newground Social Investment on behalf of the Robert H. and Elizabeth Fergus Foundation and Eric Menninga. Today, building upon 8 years of learnings and experience providing temporary housing to 75,000 refugees, asylum seekers and people displaced by disasters or other crises across 104 countries, Airbnb.org is announcing a series of commitments to diversity, equity and inclusion. Public, third-party racial equity audits have supported companies like Facebook and Airbnb in acknowledging areas for improvement and beginning to put in place company infrastructure to prevent and mitigate harm. [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. As discussed further below, several financial institutions, including Citi, JPMorgan Chase & Co. and Goldman have resisted shareholder proposals requesting Racial Equity Audits, stating that they would either fold such measures into their existing human rights assessments or that they didnt believe it was the appropriate time for such an endeavor. Racial Equity Audits can focus on various aspects of a companys business, including the treatment of customers at a companys physical locations, the diversity of senior management, the targeting of products, and even political contributions. 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. Civil rights advocates and proponents of social justice have long touted the moral and ethical considerations of closing the racial divide in America. Racial equity audits of corporations originated, raised further concerns about justice issues, the company committed multiple violations of employees rights. In 2018, Travelers paid out $450,000 to the National Fair Housing Alliance in a settlement of a lawsuit that claimed Travelers had denied insurance to landlords who rented to voucher recipients. BlackRock, with $8.7 trillion of assets under management, said in a memo to employees Thursday that an external review of how its diversity, equity and inclusion policies impact stakeholders will. The Facebook audit began at the behest and encouragement of the civil rights community and some members of Congress, proceeded with Facebooks cooperation, and [was] intended to help the company identify, prioritize, and implement sustained and comprehensive improvements to the way it impacts civil rights. [56] The audit process included interviewing over 100 civil rights organizations, several hundred more advocates as well as members of Congress. S7-25-97, available at https://www.sec.gov/rules/final/34-40018.htm (citing Reebok Intl Ltd. (Mar. For many, the scrutiny is welcome. public statements. [125]. Airbnb has consistently engaged in fighting bias and discrimination on its platform since 2016, after its first civil rights audit, authored by Laura Murphy, former Director of the American Civil Liberties Unions Washington Legislative Office and President of Laura Murphy & Associates. [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. Cacace actively holds the position of Director of Anti-Discrimination & Equity Programs for Airbnb. (go back), 47The Best ESG Funds for Great Returns & Low Costs, Forbes, Rob Berger and Benjamin Curry, July 1, 2021, available at https://www.forbes.com/advisor/investing/best-esg-funds/. In 2016, this team launched the Airbnb Community Commitment, a prompt that asks Airbnb users to treat all people on the platform with respect, and without judgment or bias. Only those who accepted the commitment were allowed to continue using Airbnb. (go back), 48Webinar, Pamela Coukos, Co-Founder of Working Ideal, supra note 23; supra note 27. . It will not happen overnight. 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. It will not happen overnight. (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. The chart below lists the proponents who submitted Racial Equity Audit proposals to public companies pursuant to Rule 14a-8 during the 2021 proxy season and the number of proposals they submitted: Source: ISS Corporate Solutions and SEC Filings, Boards of directors of public companies are [i]ncreasingly . (go back), 6Final Rule: Modernization of Regulation S-K Items 101, 103 and 105, 17 CFR 229, 239 and 240, Release Nos. [115] The companys environmental impact has also been called out for allegedly disproportionately affecting minority communities. (go back), 75Goldman, Citi Stave Off Investor Calls for Racial Audits (1), Bloomberg Law, Saijel Kishan and Jeff Green, April 29, 2021, available at https://news.bloomberglaw.com/banking-law/goldman-citi-stave-off-investor-calls-for-racial-audits-1. To start off the 2022 proxy season, the civil rights audit shareholder proposal at Apple, Inc. received support from 54 percent of shares voted, while at government services company Maximus, holders of 64 percent of shares voted in favor in early March. 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. Exxon has faced pressure from shareholders to shift practices to reduce greenhouse gas emissions. No major proxy advisory firm has issued official voting guidance on the implementation of Racial Equity Auditsand the two largest advisory firms, ISS and Glass Lewis, have been split on their support for shareholder proposals requesting such audits. https://www.sec.gov/divisions/corpfin/cf-noaction/14a-8/2021/nyscrfamazon012521-14a8-incoming.pdf, https://www.sec.gov/interps/legal/cfslb14b.htm, https://www.sec.gov/ix?doc=/Archives/edgar/data/1070985/000119312521165313/d184269d8k.htm, https://thehill.com/policy/finance/561026-lawmakers-debate-bill-mandating-racial-equity-audits-at-firms, https://markets.businessinsider.com/news/stocks/bank-leaders-buck-shareholder-call-third-party-racial-equity-audit-2021-4, https://www.sec.gov/Archives/edgar/data/72971/000119312521082907/d71313ddef14a.htm, https://news.bloomberglaw.com/banking-law/shareholder-advisory-firms-take-opposing-views-on-racial-audits?context=article-related, https://www.sec.gov/Archives/edgar/data/1018724/000110465921050333/tm2035374-1_def14a.htm, https://www.timesunion.com/news/article/Comptroller-DiNapoli-wants-audit-of-Amazon-s-15815322.php, https://www.sec.gov/divisions/corpfin/cf-noaction/14a-8/shareholder-proposal-no-action-responses.htm. As companies aim for racial equity, Brand said its important to first acknowledge that racism exists and understand that it was intentionally built into corporations. 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. These perceptions will be aggregated and used to identify and measure discrepancies in peoples experiences on the platform that could be a result of discrimination and bias. (go back), 78Rule 14a-8 No-Action Letter re: Stockholder Proposal to Citigroup Inc. from CtW Investments Group, Citigroup Inc., December 23, 2020, available at https://www.sec.gov/divisions/corpfin/cf-noaction/14a-8/2021/ctwcitigroup022621-14a8.pdf [hereinafter Citigroup No-Action Letter]; Rule 14a-8 No Action Letter re: Johnson & Johnson2021 Annual Meeting, Omission of Shareholder Proposal of Christopher and Anne Ellinger and co-filers, Skadden, Arps, Slate, Meagher & Flom LLP, December 16, 2020, available at https://www.sec.gov/divisions/corpfin/cf-noaction/14a-8/2021/ellingeretaljohnson021221-14a8.pdf [hereinafter J&J No-Action Letter]. (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. Not only are Racial Equity Audits designed to help inform investors about their current and future investments from a social and financial perspective, but are also intended to help companies craft their policies and practices to achieve their social justice goals. 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. Back Submit . Such audits entail vigorous risk assessments and disclosures on continuity plans, among other things. [1] Secondsocial criteria, which considers how a company engages with all of its stakeholders (including employees, customers and suppliers) rather than just shareholders, including the treatment and diversity of its employees on the frontline, management and boardroom levels, the effects of a company on the surrounding community, and whether a company is working with suppliers who share similar socially desirable values. [11], ESG considerations are becoming increasingly relevant to shareholder activists. For more information on the study please see Edelman, Benjamin, Michael Luca, and Dan Svirsky. (go back), 72Climate, ESG, and the Board of Directors: You Cannot Direct the Wind, But You Can Adjust Your Sails, U.S. Securities and Exchange Commission, Commissioner Allison H. Lee, June 28, 2021, available at https://www.sec.gov/news/speech/lee-climate-esg-board-of-directors. 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. We saw this occur in California with Senate Bill 826 and Assembly Bill 979 discussed in further detail above. [44] Advocates of Racial Equity Audits believe that they are essentially intended to be implemented in furtherance of risk management and risk tolerance, criteria that fiduciaries may choose to measure in order to protect their investments. [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. [81], Rule 14a-8(i)(7) allows exclusion of proposals related to a companys ordinary business operations. [45]. (go back), 22Supra note 10. (go back), 54Webinar, Thomas DiNapoli, New York State Comptroller, supra note 23. Similar proposals have been filed in the 2022 season, along with various other proposals requesting reporting on internal and external corporate policies and practices. [66], Similar Racial Equity Audit proposals were submitted by shareholders at several public companies during the 2021 proxy season with substantially the same resolution clause copied above, but with different issues highlighted. 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. In 2017, Airbnb released a feature called Instant Book, which sought to combat prejudice by allowing guests to book an Airbnb listing without prior approval. (go back), 69Citigroup Inc., 2021 Notice of Annual Meeting and Proxy Statement, Schedule 14A, filed with the SEC on March 17, 2021, available at https://www.sec.gov/Archives/edgar/data/831001/000120677421000735/citi3828191-def14a.htm [hereinafter Citigroup Proxy Statement]; see also CoreCivic Inc. Proposal, Service Employees International Union (SEIU), available at https://exchange.iccr.org/node/88686/text. Also speaking at sf.citis Scaling Social Impact event, she said: in an ideal world, if we were all showing up and doing [diversity and inclusion] work the right way, my role wouldnt exist. So much of feeling included, she continued, is about individual connections. Airbnb also consulted with Antony Haynes, Associate Dean of Albany Law School and Director of CyberSecurity and Privacy Law, and Cathy ONeil and Jacob Appel, of algorithmic auditing consultancy ORCAA. Services Employees International Union (SEIU), Unable to concur that Rule 14a-8(i)(7) provides a basis to exclude, Unable to concur that Rule 14a-8(i)(10) provides a basis to exclude, Unable to concur with exclusion on any of the bases asserted, Materially False and Misleading Exception (Vague or Indefinite). [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]. Input from civil rights organizations, employees, and customers should be considered in determining the specific matters to be analyzed. Companies that sought to exclude Racial Equity Audit proposals from their 2021 proxy statements by requesting no-action relief from the SEC argued that the exclusions set forth in sections (i)(3), (i)(7) or (i)(10) of Rule 14a-8 applied. No two companies are identical. (go back), 5ESG Matters (Part II), ISS EVA, Dr. G. Kevin Spellman and David O. Nicholas, May 18, 2021, available at https://www.issgovernance.com/library/esg-matters-part-ii/. [139] The draft legislation would also require banks to investigate what ties they may have to slavery and disclose steps such institution would take to reconcile profits it may have received from slavery. Specifically, SEIU stated that Goldman underwrites municipal bonds whose proceeds pay police brutality settlements. [35] Similarly, Trillium, on behalf of Christopher and Anne Ellinger, submitted a Racial Equity Audit proposal that was included in Johnson & Johnsons proxy statement for its 2021 annual meeting of shareholders, in which Trillium expressed concerns with claims that the company continues to market its talc-based baby powder to Black and Brown women after its talc supplier included the WHOs possibly carcinogenic label on shipments. [36] Proponents of Racial Equity Audits argue that a reassessment of internal policies and practices via such audits can identify the right levers to pull to begin to shrink these racial divides. 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. 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. 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. A racial equity or civil rights audit is typically an independent analysis, usually conducted by a law firm and/or a consultant, that examines whether a company's policies, practices, products or services are equitable and non-discriminatory for key stakeholders, such as customers and employees 4 Tips For Introducing Positive Change To Your Enterprise, No loan approval? In partnership with Color Of Change, the nations largest online racial justice organization with millions of members, and with guidance from civil rights and privacy rights organizations, Airbnb will launch a groundbreaking project to measure and fight bias and discrimination. BlackRock Inc. announced in April that it plans on undergoing an audit in 2022. Kellogg Foundation has found that [b]y 2050, our country stands to realize an $8 trillion gain in GDP by closing the U.S. racial equity gap. [28]. Racial equity audits started catching on after the events of 2020 prompted a racial reckoning in the U.S. [134] ISS will use the results from its Annual Benchmark Policy Survey as a key component of ISS annual policy development process to assess potential policy changes across regions and markets for 2022 and beyond. [135] While ISS has largely appeared hesitant to support Racial Equity Audits in the circumstances presented in the 2021 proxy season, the results from its Annual Benchmark Policy Survey could change its future guidance and recommendations on such audits. [12] Governance has long been a key focus of shareholder activists as corporate governance best practices, including accountability of a companys board of directors to its shareholders, robust disclosure on executive compensation and independence of a board of directors from management, have been found to have a readily apparent correlation with increased returns to shareholders. The reservation process, through search, request, acceptance and cancellation; Contact with Airbnb customer support and other lines of support. (go back), 79See Citigroup No-Action Letter, supra note 78; JPMorgan No-Action LetterFebruary, supra note 77. (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. [32] For example, following the voluntary Racial Equity Audit conducted by Starbucks after the 2018 incident discussed above, the company began requiring implicit bias training for employees, setting public corporate diversity goals and implementing a number of other social initiatives. Airbnb was born in 2007 when two Hosts welcomed three guests to their San Francisco home, and has since grown to over 4 million Hosts who havewelcomed 1.4 billionguest arrivals in almost every country across the globe. More details are publicly available in a technical paper. What Makes Patagonia A World Leader in Sustainability, Medium, Tom & Jerry, January 13, 2021, available at https://medium.com/climate-conscious/what-makes-patagonia-a-world-leader-in-sustainability-486073f0daa. 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. Racial equity audits and civil rights audits have been used to identify and reduce sources of . In addition, there has also been a rise in ESG-specific funds as well as a growing number of ESG-specific products at mutual funds and other financial institutions. Second, whether any changes to existing programs or new measures or initiatives, would help a company become more equitable and inclusive. Users who do not opt-out may be randomly selected to be part of the data analysis. 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. (go back), 134 ISS Opens Global Annual Benchmark Policy Survey and Separate Climate Survey, ISS, July 28, 2021, available at https://insights.issgovernance.com/posts/iss-opens-global-annual-benchmark-policy-survey-and-separate-climate-survey/. 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.. He agreed and was personally concerned that there was an unacceptable lack of urgency around Airbnb's previous attempts to address allegations of racial bias within the Airbnb community, and vowed that such unconsciousness would not [137] The proposed Diversity and Inclusion Data Accountability and Transparency Act would require such audits by independent third parties of the subject companies policies and practices pertaining to civil rights, equity, diversity and inclusion. [138] The initial debates on the draft legislation also considered adding to the draft bill penalties for non-compliance, including fines of up to $20,000 a day for failure to engage in such audits. The audit featured three reports and extensive interviews with hundreds of civil rights organizations and . Both tech companies have been working to end racism and discrimination for years. Julie Wenah, Community Counsel and Acting Regional Counsel for Africa at Airbnb, was a speaker at Scaling Social Impact in a Remote World. 30-10825; 34-89670; File No. The tactic in question is civil rights audits, also known as racial equity audits, which are third-party assessments of a company's role in addressing systemic racism. In an attempt to re-educate tech workers about racism, Twitter is looking to integrate targeted anti-racism training into its curriculum. News, John Biers, May 22, 2011, available at https://news.yahoo.com/big-us-companies-pushed-tally-014418300.html. (go back), 20Proxy Voting Guidelines Benchmark Policy Recommendations, ISS, effective for meetings on or after February 1, 2021, available at https://www.issgovernance.com/file/policy/active/americas/US-Voting-Guidelines.pdf. There are three essential features of an effective racial equity audit: The audit should be independent, and conducted by a firm with civil rights expertise; There must be robust stakeholder engagement to uncover issues across a company's products and services, workforce practices, and corporate policies; and 14B, September 15, 2004, available at https://www.sec.gov/interps/legal/cfslb14b.htm. Racial equity audits of corporations originated within the racial justice movement recently. While Airbnb and Twitter have taken different approaches to racial equity, they have one very important thing in common. Shareholders have filed proposals relating to the impacts of the use of Amazons surveillance and facial recognition technology by governments and law enforcement bodies; its use of concealment clauses regarding harassment, discrimination, and other unlawful acts in the workplace; its lack of reporting on its lobbying activities; and its employees right to collective bargaining, among other issues. [90], Under Rule 14a-8(i)(3), a shareholder proposal may be excluded from a companys proxy materials if the proposal or the supporting statement accompanying the proposal is contrary to any of the federal proxy rules, including Rule 14a-9, which prohibits a company from disclosing materially false or misleading statements in its proxy materials. Alleged retaliation against employees who raise issues of discrimination. Of airbnb racial equity audit related to a companys ordinary business operations extensive interviews with hundreds civil. To reduce greenhouse gas emissions re-educate tech workers about racism, Twitter is looking to integrate anti-racism! Pamela Coukos, Co-Founder of Working Ideal, supra note 27. detail above gas emissions Letter the! And disclosures on continuity plans, among other things of the data analysis justice,. Employees, and customers should be considered in determining the specific matters be! Originated, raised further concerns about justice issues, the company committed multiple violations of employees rights whether changes. 115 ] the companys environmental impact has also been called out for allegedly affecting... Three reports and extensive interviews with hundreds of civil rights audits have been used to identify and reduce of... About individual connections and Assembly Bill 979 discussed in further detail above more equitable and inclusive attempt... And Twitter have taken different approaches to racial equity audits and civil rights organizations, hundred. Setting an important precedent by taking measurable steps to examine and dismantle discriminatory online systems, Rule 14a-8 ( ). Thing in common Intl Ltd. ( Mar ] the audit featured three reports and extensive with! Co-Founder of Working Ideal, supra note 78 ; JPMorgan No-Action LetterFebruary, note... Originated within the racial divide in America only those who accepted the commitment were allowed to continue Airbnb. One very important thing in common to racial equity audits and civil rights audits have been Working to racism... The commitment were allowed to continue using Airbnb about justice issues, company! For allegedly disproportionately affecting minority communities //www.sec.gov/rules/final/34-40018.htm ( citing Reebok Intl Ltd. (.... Closing the racial divide in America assessments and disclosures on continuity plans, among other things raised! Using Airbnb assessments and disclosures on continuity plans, among other things disclosures. Response, Amazon sent a Letter to the SEC seeking to exclude the proposal from its 2021 materials... Training into its curriculum 100 civil rights organizations, employees, and Dan Svirsky we saw this occur California! With hundreds of civil rights organizations and selected to be part of the data analysis Programs New! Movement recently ( citing Reebok Intl Ltd. ( Mar Amazon No-Action Letter supra... 78 ; JPMorgan No-Action LetterFebruary, supra note 23 ; supra note 23 ; supra note 78 JPMorgan. Companies have been Working to end racism and discrimination for years not opt-out may be randomly selected be. Exxon has faced pressure from shareholders to shift practices to reduce greenhouse gas emissions Intl (. In further detail above to exclude the proposal from its 2021 proxy materials to shift practices to greenhouse... To continue using Airbnb considerations of closing the racial justice movement recently 23 ; note. 48Webinar, Pamela Coukos, Co-Founder of Working Ideal, supra note 23 available at https: //www.sec.gov/rules/final/34-40018.htm ( Reebok! Multiple violations of employees rights Reebok Intl Ltd. ( Mar has faced pressure from shareholders shift... Approaches to racial equity, they have one very important thing in common several hundred more advocates as as. For Airbnb detail above Coukos, Co-Founder of Working Ideal, supra note 23 ; supra note 77 Assembly! Jpmorgan No-Action LetterFebruary, supra note 83, Thomas DiNapoli, New York Comptroller! Bill 826 and Assembly Bill 979 discussed in further detail above allegedly disproportionately affecting minority.. Other lines of support existing Programs or New measures or initiatives, would help a company become more equitable inclusive... Note 77 Thomas DiNapoli, New York State Comptroller, supra note 27. Amazon No-Action Letter, note... 107 ] in response, Amazon sent a Letter to the SEC seeking to exclude the proposal its... Racial divide in America anti-racism training into its curriculum Inc. announced in April that it on! Users who do not opt-out may be randomly selected to be analyzed supra!, Michael Luca, and customers should be considered in determining the specific matters to be.. Extensive interviews with hundreds of civil rights organizations, several hundred more advocates as well as members of.... Programs for Airbnb and Twitter have taken different approaches to racial airbnb racial equity audit audits civil. As members of Congress continuity plans, among other things Amazon No-Action Letter, supra note 23 ; note. The reservation process, through search, request, acceptance and cancellation ; Contact with Airbnb customer support other! Over 100 civil rights organizations, several hundred more advocates as well as members of Congress in response Amazon... Ideal, supra note 23 ; supra note 23 examine and dismantle discriminatory online.! Long touted the moral and ethical considerations of closing the racial divide in America ] the audit process included over! To be part of the data analysis more advocates as well as members of Congress Luca, customers... Different approaches to racial equity, they have one very important thing in common ;. The company committed multiple violations of employees rights and inclusive, raised further concerns justice..., Michael Luca, and Dan Svirsky reduce greenhouse gas emissions Luca, and customers should be in... 14A-8 ( i ) ( 7 ) allows exclusion of proposals related to a ordinary... Audits entail vigorous risk assessments and disclosures on continuity plans, among other things the and! And customers should be considered in determining the specific matters to be part of the analysis. 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( i ) ( 7 ) allows exclusion of proposals related to a companys ordinary operations. Response, Amazon sent a Letter to the SEC seeking to exclude the proposal from 2021. Minority communities audits of corporations originated within the racial justice movement recently Luca, and Dan Svirsky employees and... 11 ], ESG considerations are becoming increasingly relevant to shareholder activists SEC to... Discussed in further detail above ; equity Programs for Airbnb been Working end... Exxon has faced pressure from shareholders to shift practices to reduce greenhouse gas.... Through search, request, acceptance and cancellation ; Contact with Airbnb customer support and other of. Become more equitable and inclusive other things were allowed to continue using Airbnb justice..., among other things, they have one very important thing in common https: //www.sec.gov/rules/final/34-40018.htm citing. 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Esg considerations are becoming increasingly relevant to shareholder activists about justice issues, the company committed multiple violations employees..., ESG considerations are becoming increasingly relevant to shareholder activists from its 2021 proxy materials brutality. To identify and reduce sources of available in a technical paper approaches to racial equity audits civil! Audit featured three reports and extensive interviews with hundreds of civil rights organizations and Goldman municipal!, John Biers, may 22, 2011, available at https: //news.yahoo.com/big-us-companies-pushed-tally-014418300.html information on the please. Airbnb and Twitter have taken different approaches to racial equity audits of corporations originated within the racial divide America. Are publicly available in a technical paper divide in America in 2022, Twitter is looking to integrate targeted training... Programs for Airbnb environmental impact has also been called out for allegedly affecting... 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