STERICYCLE, INC. | Civil Rights Audit at STERICYCLE, INC.
Conduct due diligence, risk or impact assessment
- Human rights & inequality
Company HQ country
That shareholders of Stericycle, Inc., urge the Board of Directors to oversee a third-party audit analyzing the adverse impact of Stericycle’s policies and practices on the civil rights of company stakeholders, above and beyond legal and regulatory matters, and to provide recommendations for improving the Company’s civil rights impact. Input from civil rights organizations, employees, customers, and other stakeholders should be considered in determining the specific matters to be analyzed. A report on the audit, prepared at reasonable cost and omitting confidential or proprietary information, should be publicly disclosed on Stericycle’s website.
Racial justice concerns together with the disproportionate impacts of COVID-19 have focused public and policy maker attention on civil rights, gender and racial equity issues. Stericycle’s 2021 Corporate Social Responsibility report details an Equity Task Force and the creation of employee resource groups supporting women, Black or African Americans, LatinX, Veterans, and the LGBTQ+ community. CEO Cindy Miller also signed the CEO Action for Diversity & Inclusion Pledge. The civil rights impact of Stericycle’s facilities also warrants further disclosure, given the history of environmental racism in the waste industry.1 Stericycle operates ten incinerators for Hospital, Medical, and Infectious Waste (HMIW) – a source of potential air pollution. In January 2021, for example, Stericycle announced a $2.6 million settlement with the Environmental Protection Agency and Department of Justice over allegations of nitrogen oxide pollution at its HMIW incinerator in North Salt Lake, Utah. The facility is the subject of a long-running environmental controversy, even attracting the attention of famed activist, Erin Brockovich. From a recent study, we know 79% of the country’s municipal solid waste incinerators are located in low-income communities and/ or communities of color;2 however, Stericycle investors lack disclosure concerning the sociodemographic composition of communities surrounding Stericycle’s HMIW incinerators, or how, if at all, Stericycle is considering civil rights in locating and operating facilities. We urge Stericycle to assess its behavior through a civil rights lens to obtain a complete picture of how it contributes to social and economic inequality and avoid adverse impacts on its stakeholders. Noteworthy, however it remains unclear how effective these practices are based on Stericycle’s reporting. For example, Stericycle discloses 53% of its U.S. workforce is non-white and provides the racial and ethnic composition of recent hiring and promotion, but does not report its EEO-1 data, detailing positions held by these groups (despite providing a snapshot of gender diversity in management ranks). This is particularly significant given the inherent dangers for operation-level employees in the handling, transporting and treatment of regulated waste, such as, hazardous medical materials. Without greater disclosure it is difficult for investors to gauge Stericycle’s stated commitment to the advancement of historically marginalized groups.