RiskMetrics Group, in coordination with the Sustainable Investment Research Analyst Network (SIRAN) and Walden Asset Management, today released the results from a second survey of Equal Employment Opportunity (EEO) disclosure among S&P 100 firms. A follow-up on a benchmark study from 2005, the second EEO survey suggests the disclosure rate among S&P 100 companies has diminished over the past two to three years.

The report finds companies that confirmed a policy to provide investors with comprehensive EEO-1 data, either in public reports or on request, decreased from 54 percent in 2005 to 36 percent of responding companies in 2007-8. While partial EEO data providers increased from 13 to 21 percent, those confirming that they do not disclose such information increased from 33 to 43 percent over the same period.

However, even these low reporting rates are likely overstated, as those electing not to participate–approximately half of S&P 100 companies–are assumed to be much less likely to disclose EEO information. Also, the companies surveyed are among the largest in the United States and have likely been under more scrutiny for their employment practices and pressure to disclose EEO-1 data than smaller firms.

There are several possible explanations for the precipitous fall in reporting rates. Shareholder pressure on this issue, in the form of resolutions filed during proxy season, has declined in recent years, as calls for broader global sustainability reporting–not aligned with U.S. EEO-disclosure requirements–have increased.

In addition, as of September 2007, the revised EEO-1 Report requires, among other changes, companies to separate the "Officials and Managers" job classification into two levels based on responsibility and influence, "Executive/Senior Level Officials and Managers" and "First/Mid-Level Officials and Managers." Therefore, given that employment disparities by race and gender tend to increase at higher management levels, companies may be more reluctant to share the EEO-1 Report.

You can access the full report by clicking here.