Resolved clauseResolved: James McRitchie, of CorpGov.net, and other shareholders, request Kellogg Company (Kellogg) report annually on unadjusted median pay gaps across race and gender globally and/or by country, where appropriate, including associated policy, reputational, competitive, and operational risks, and risks related to recruiting and retaining diverse talent.
Pay includes base, bonus, and equity compensation either aggregated or, preferably, disaggregated. The reports should be prepared annually at reasonable cost, omitting proprietary information, litigation strategy, and legal compliance information.
Racial/gender pay gaps are defined as the difference between non-minority and minority/male and female median earnings expressed as a percentage of non-minority/male and female earnings.
Supporting statementSupporting Statement: Pay inequities persist across race and gender and pose substantial risks to companies and society. Black workers’ hourly median earnings represent 64% of white wages. The median income for women working full time is 83% of that of men.[1] Intersecting race, Black women earn 63%, Native women 60%, and Latina women 55%.[2] At the current rate, women will not reach pay equity until 2059, Black women in 2130, and Latina women in 2224.[3]
Citigroup estimates closing minority and gender wage gaps 20 years ago could have generated 12 trillion dollars in additional national income.[4] PwC estimates closing the gender pay gap could boost Organization for Economic Cooperation and Development (OECD) countries’ economies by $2 trillion annually.[5]
Minorities represent 37.1% of Kellogg’s North American workforce and 20.5% of senior management. Women represent 35.8% percent of the workforce and 38.4% of senior management.[6] Actively managing pay equity is associated with improved representation and diversity is linked to superior stock performance and return on equity.[7]
Best practice pay equity reporting consists of two parts:
unadjusted median pay gaps for similar, assessing equal opportunity to high paying roles,statistically adjusted gaps for similar roles, assessing whether minorities and non-minorities, men and women, are paid the same for similar roles.Kellogg committed to reporting statistically adjusted pay equity but ignores unadjusted pay, which addresses the structural bias women and minorities face regarding job opportunities and pay.
Racial and gender unadjusted median pay gaps are accepted as the valid way of measuring pay inequity by the United States Census Bureau, Department of Labor, OECD, and International Labor Organization.[8], The United Kingdom and Ireland mandate disclosure of median pay gaps, and the United Kingdom is considering racial pay reporting.[9]
Kellogg does report diversity data. However, unadjusted median pay gaps would show, quite literally, how Kellogg assigns value to its employees through the roles they inhabit and pay they receive. Pay gap reporting provides digestible, comparable data to determine progress over time.[10]
[1] https://www.nationalpartnership.org/our-work/resources/economic-justice/fair-pay/americas-women-and-the-wage-gap.pdf
[2] https://www.aauw.org/app/uploads/2021/09/AAUW_SimpleTruth_2021_-fall_update.pdf
[3] https://iwpr.org/iwpr-publications/quick-figure/the-gender-pay-gap-1985-to-2020-with-forecast-for-achieving-pay-equity-by-race-and-ethnicity/
[4] https://ir.citi.com/NvIUklHPilz14Hwd3oxqZBLMn1_XPqo5FrxsZD0x6hhil84ZxaxEuJUWmak51UHvYk75VKeHCMI%3D
[5] https://www.pwc.com/hu/en/kiadvanyok/assets/pdf/women-in-work-2021-executive-summary.pdf
[6] https://www.kelloggcompany.com/content/dam/NorthAmerica/kelloggs-diversity-and-inclusion/images/2022/homepage/Features2021%20_%20FINAL_J22.pdf
[7]https://www.mckinsey.com/capabilities/people-and-organizational-performance/our-insights/promoting-gender-parity-in-the-global-workplace
[8]https://blog.dol.gov/2022/03/15/connecting-the-dots-womens-work-and-the-wage-gap https://www.census.gov/library/stories/2022/03/what-is-the-gender-wage-gap-in-your-state.html
[9] https://www.gov.uk/government/collections/gender-pay-gap-reportinghttps://www.gov.ie/en/campaigns/0cb29-gender-pay-gap-information-act-2021/
[10] https://static1.squarespace.com/static/5bc65db67d0c9102cca54b74/t/622f4567fae4ea772ae60492/1647265128087/Racial+Gender+Pay+Scorecard+2022+-+Arjuna+Capital.pdf