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Changes in DEI Disclosure Practices: Form 10-Ks

By Randi Morrison posted 03-16-2025 07:24 PM

  

Impact of DEI-Related Executive Orders on Disclosures in Recent Public Company Annual Reports” from Mintz describes how companies are changing DEI-related disclosures in their Form 10-Ks based on the firm’s review of filings to date. Among the changes observed are:

  • Changes in terminology: avoidance of “diversity, equity, and inclusion”; “diversity”; and self-identification language
  • Removal of DEI program references, details, or actions undertaken
  • Removal of breakdown of workforce by race, ethnicity, gender, and/or identification of where such information may be found on the corporate website
  • Changes in characterization of DEI-related risks (e.g., perceptions of DEI initiatives being perceived as insufficient or extreme; elimination of DEI as a talent attraction/retention factor)

The firm notes that companies generally are balancing the risks of disclosure with stakeholder expectations and other relevant factors.
                                 This post first appeared in the weekly Society Alert!

                          

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