SEC Rule for Public Companies to Disclose DEI Expenses in Quarterly & Annual Reports

All public companies should be made to reveal to shareholders in their quarterly and annual reports exactly how much is being spent internally and externally on DEI training efforts and conformity. This should include (at least): 1. Costs associated with internal training of employees (including training time opportunity costs of labor, training materials development, scoring, consultant expenses, conformity efforts, etc.); 2. Salary/hourly expenses of managers and employees in the departments responsible for internal training efforts in this regard; 3. Expenses associated with external interactions with state, local, or federal government, as well as private associations regarding DEI training; 4. Aggregate costs related to litigation in regards to DEI.

The SEC should also provide the relative ranking for the company compared to industry peers and all public companies, normalized by the percent of total expenses used for aggregate DEI efforts of the rated company. This information should be updated regularly and made available on the SEC website for investors.

This required information by public companies would allow all investors, whether favorably or unfavorably disposed to DEI efforts and expenses, to be more informed in making investment decisions. Transparency is essential in this regard, and this policy would enable such transparency.

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