COMCAST CORPORATION | Racial Equity Audit at COMCAST CORPORATION

Status
10.84% votes in favour
AGM date
Previous AGM date
Proposal number
7
Resolution details
Company ticker
CMCSA
Lead filer
Service Employees International Union (SEIU)
Co-filers
Missionary Oblates of Mary Immaculate, Benedictine Sisters of Cullman, Benedictine Sisters of Virginia
Resolution ask
Conduct due diligence, audit or risk/impact assessment
ESG theme
  • Social
ESG sub-theme
  • Diversity, equity & inclusion (DEI)
Type of vote
Shareholder proposal
Filer type
Shareholder
Company sector
Consumer Discretionary
Company HQ country
United States
Resolved clause
RESOLVED that shareholders of Comcast Corporation (“Comcast”) urge the Board of Directors to oversee an independent racial equity audit analyzing Comcast’s adverse impacts on nonwhite stakeholders and communities of color and describing the steps, if any, Comcast plans to take to mitigate those impacts. Input from civil rights organizations, employees, and customers should be considered in determining the specific matters to be analyzed. A report on the audit, prepared at reasonable cost and omitting confidential and proprietary information, should be publicly disclosed on Comcast’s website.
Supporting statement
SUPPORTING STATEMENT
High-profile police killings of Black people have galvanized the movement for racial justice. That movement, together with the disproportionate impacts of the COVID-19 pandemic, have focused the attention of the media, the public and policy makers on systemic racism, racialized violence and other inequities.
Several aspects of Comcast’s business and operations suggest that a racial equity audit would be useful. Although Comcast touts the fact that its diversity programs have resulted in the “most inclusive employee representation” since Comcast began reporting diversity data,1 representation in senior management continues to lag. According to EEO-1 data for 2021, only 6.6% of Comcast’s executives/senior officers are Black, compared to 18.1% of the workforce generally.2
In October 2020, Comcast entered into a conciliation agreement with the U.S. Labor Department to resolve allegations of pay discrimination against Black and Latino employees. Comcast denied the allegations, but agreed to back pay and interest plus salary adjustments.3
Comcast has sponsored the Philadelphia Police Foundation’s annual gala,4 though donor information is no longer provided on the organization’s web site. Police foundations bypass normal procurement processes to buy equipment for police departments, including surveillance technology used to target communities of color and nonviolent protestors.5
Despite claiming that “[e]fforts to limit or impede access to this vital constitutional [voting] right for any citizen are not consistent with our values,” Comcast donated to several state lawmakers who sponsored legislation restricting access to voting. Among those recipients was Florida state senator Dennis Baxley, the only sponsor of a bill, later signed into law, that criminalized providing water to voters in line and limited availability of drop boxes, among other measures.6 Voting restrictions have already exacerbated racial turnout gaps, and two states that adopted them are being sued for intentionally discriminating against nonwhite voters.7

How other organisations have declared their voting intentions

Organisation name Declared voting intentions Rationale
Anima Sgr For While the company has taken steps to minimize disparities based on race and ethnicity in terms of its workforce,
customers, suppliers, and local communities, the adoption of this proposal should serve to further would
strengthen the company's existing diversity and inclusion initiatives. Furthermore, the company has recently faced
two high profile allegations of racial discrimination. In one, the company denied wrongdoing and in the second, the
Supreme Court found in the company s favor. As such, this proposal would allow shareholders to better assess the
effectiveness of the company's diversity initiatives and its management of related risks.
Kutxabank Gestion SGIIC SAU. For
Rothschild & co Asset Management For

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