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TheCorporateCounsel

TheCorporateCounsel.net

A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.

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DealLawyers.com

An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.

CompensationStandards

CompensationStandards.com

The “one stop” resource for information about responsible executive compensation practices & disclosure.

Section16.net

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Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.

PracticalESG

PracticalESG.com

Keeping you in-the-know on environmental, social and governance developments

While anti-ESG may be struggling in the courtroom, anti-DEI is thriving. The DOJ is racking up DEI-related settlements using the False Claims Act (FCA). The FCA requires federal contractors to warrant that they abide by civil rights laws. The EEOC is arguing that DEI programs discriminate based on protected characteristics, thus violating equal protection. So far, Deloitte faced a $20 million settlement, along with IBM, which paid out $18 million. Now Accenture joins their ranks, settling the government’s claim with a $25 million FCA settlement. A DOJ press release sums up some of the government’s allegations:

“The United States alleged that AFS took race or sex into account when making hiring decisions to achieve progress toward non-public workforce composition goals. Business unit leaders within AFS received monthly summaries of the specific percentage of each race and sex within the unit, with the figures highlighted green, yellow, or red to indicate whether representation was at or exceeded AFS’ goal, was within 5 percent of AFS’ goal, or was below 5 percent of AFS’ goal, respectively. These demographic goals were designed to, and did, drive changes in hiring practices based on race and sex. For example, at the end of 2020 and beginning of 2021, AFS engaged in a round of entry level employee hiring to make further progress towards the company’s racial representation goals.”

This $25 million FCA settlement further cements the DOJ’s strategy, and we’ll likely see more cases of this type over the next two years. It’s worth pointing out that the government is targeting companies with quotas. This was also the case in the Deloitte settlement as well. DEI programs are still valuable, but must be crafted with compliance at the top of mind. Diversity is a valuable asset, but in the current environment, targets cannot be set in clear-cut quota fashions. Instead, companies should work to foster inclusive cultures and bring about workforce diversity organically.

Our members can learn more about ESG litigation developments here.

If you’re not already a member, sign up now and take advantage of our no-risk “100-Day Promise” – during the first 100 days as an activated member, you may cancel for any reason and receive a full refund. But it will probably pay for itself before then. Members also save hours of research and reading time each week by using our filtered and curated library of ESG/sustainability resources covering over 100 sustainability subject areas – updated daily with practical and credible information.

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The Editor

Zachary Barlow is a licensed attorney. He earned his JD from the University of Mississippi and has a bachelor’s in Public Policy Leadership. He practiced law at a mid-size firm and handled a wide variety of cases. During this time he assisted in overseeing compliance of a public entity and litigated contract disputes, gaining experience both in and outside of the courtroom. Zachary currently assists the PracticalESG.com editorial team by providing research and creating content on a spectrum of ESG… View Profile