Deere states a commitment to diversity, equity, and inclusion (“DEI”). It created a DEI Global Advisory Board “to provide strategic oversight and leadership-driven progress on inclusion,” as well as partnerships with local business units and employee resource groups. On July 16, 2024, however, Deere announced that it would end or curtail some of its DEI commitments. For example, Deere announced that it would “no longer participate in or support external social or cultural awareness parades, festivals, or events,” and that it would audit “all company-mandated training materials and policies to ensure the absence of socially motivated messages, while being in compliance with federal, state, and local laws.”
Earlier this year, Deere agreed to pay $1.1 million in back pay and interest to nearly 300 Black and Hispanic job applicants and provide job offers to eligible class members as part of a settlement with the U.S. Department of Labor, which alleged systemic hiring discrimination. The Human Rights Campaign, the sponsor of the Corporate Equality Index, a tool measuring corporate policies affecting lesbian, gay, bisexual, transgender, and queer employees, expressed its disappointment with the company’s decision to curtail DEI commitments. The National Black Farmers Association responded by calling for a boycott of Deere.

Given the impact the company’s decision has already had with important constituencies, shareholders need to understand the full impact of these rollbacks, including the company’s ability to build a talented workforce and grow its customer base and revenue. A civil rights audit is a tool to help companies and key stakeholders, including shareholders, identify and understand the bias and discrimination risks of a company’s policies, practices, products, and services. A civil rights audit also provides recommendations for addressing the adverse impacts of a company’s actions. The Civil Rights Audit Standards, published by PolicyLink, were developed by an independent committee, including business executives, union and worker group representatives, investors, and civil rights experts. These Standards provide a roadmap for how a company should conduct a civil rights audit. The Standards include requiring that the auditor be independent and have a commitment to civil rights and racial justice; the auditor meaningfully engage key stakeholders such as employees, customers, and civil rights groups; and the company publicly share the final audit report on the company’s website in an easily accessible location. We urge Deere to conduct a civil rights audit consistent with the Civil Rights Audit Standards. A civil rights audit will provide Deere management and its shareholders the information and analysis they need to evaluate the company’s recent actions and their impact on legal and business risks, as well as the company’s progress in meeting its DEI and other business objectives.