Home Depot – EEO-1 Disclosure (2021)

Outcome: Successfullly withdrawn. The Home Depot will annually disclose its consolidated EEO-1 Report data beginning in 2021, and that the disclosure will be posted to the Company’s website by the later of July 31 or 60 days following the submission of its EEO-1 Report to the EEOC.

WHEREAS: We believe equal employment opportunity (EEO) is both a fair employment practice and an investment issue since diversity affects shareholder value. We believe companies with good EEO records have a competitive advantage in recruiting/retaining employees. The Home Depot customers are increasingly diverse; a diverse work force can anticipate and respond effectively to consumer demand.

The Home Depot annually files an EEO-1 report with the Equal Employment Opportunity Commission. Information could be made available to shareholders at minimal additional cost. In 2001, The Home Depot provided EEO information to investors upon request but, since then, reversed policy on its EEO disclosure.

Allegations of discrimination in the workplace burden shareholders with costly litigation/fines which can damage a company’s reputation. Over past years, The Home Depot has paid out millions of dollars to settle charges of class-wide gender, race and national origin discrimination.

At the 2020 shareholder meeting, 35.82% of Home Depot shares voted in favor of this proposal.

In July 2020, New York City Comptroller Scott M. Stringer, on behalf of three New York City Retirement Systems, sent a letter to 67 S&P 100 companies who issued supportive statements on racial quality, calling on companies to publicly disclose employee breakdowns by race, ethnicity and gender by position, including senior management, to facilitate evaluation of their diversity workforce practices by publicly disclosing their annual EEO-1 Report data. This included The Home Depot.

RESOLVED: Shareholders request The Home Depot prepare a diversity report, at reasonable cost and omitting confidential information, available to investors by September 2021, including:

1. A chart identifying employees according to gender and race in the nine major EEOC-defined job categories for the last three years, listing numbers or percentages in each category;
2. A summary description of any affirmative action policies and programs to improve performance, including in job categories where women and minorities are underutilized;
3. A description of policies/programs oriented toward increasing diversity in the workplace;
4. A description of challenges faced in meeting Home Depot’s diversity goals.

SUPPORTING STATEMENT: The Home Depot has demonstrated leadership on many corporate social responsibility issues. We are encouraged by the substantial and growing number of companies that are actively supporting diversity and inclusion. We believe that it is important to have hard data to be able to establish a baseline and review progress. Thus, we ask The Home Depot to demonstrate leadership on diversity by committing to EEO disclosure.