In the context of recently publicized retractions by discrete companies from traditional demographic diversity director recruitment policies, PeopleReturn reported a sharp decline in “Rooney Rule” commitments, i.e., active language that explicitly prioritizes including women and people of color in candidate pools (see, e.g., Costco’s Corporate Governance Guidelines Section 3). As shown below, the prevalence of such policies declined by about one-half from 2024 to 2025 and proxies filed to date in 2026 portend a much further reduction:
|
|
2024
|
2025
|
2026
|
|
S&P 100
|
47.90%
|
24.90%
|
13.50%
|
|
S&P 500
|
40.60%
|
21.70%
|
12.10%
|
|
Russell 1000
|
37.00%
|
20.40%
|
14.00%
|
Data conveys a similar trend with regard to EEO-1 workforce disclosure, with significant increases in disclosure following post-2020 investor campaigns, shareholder proposals, and evolving expectations, followed by sharp reductions in 2025:
|
|
2019
|
2022
|
2024
|
2025
|
|
S&P 100
|
15%
|
95%
|
94%
|
62%
|
|
S&P 500
|
5%
|
66.2%
|
78.7%
|
57.2%
|
|
Russell 1000
|
2.8%
|
38.9%
|
48.8%
|
35.8%
|
The report notes that while some companies have continued to make annual EEO-1 disclosures, others have retained former year disclosures on their websites but have no plans (currently) to update them. At the same time, as noted in last week’s Society Alert and updated below, the New York City pension funds sued a company over its exclusion of an EEO-1 disclosure proposal, and such data is increasingly becoming public as a result of litigation and state laws.