Which S&P 500 Companies Disclose Gender Pay Equity Data?

In the 50-plus years since the enactment of the Equal Pay Act of 1963, the U.S. has yet to achieve gender pay equity. That’s confirmed by a 2020 U.S. Census study which has full time working women earning 82% of their male peers, and a similar global study by the World Economic Forum, which puts the U.S. gender pay gap at 76.9%. In either case, that’s less than the world leader in gender pay equity, Iceland, where women make 90 cents on the dollar, but considerably more than Afghanistan, where women earn a paltry 43% of what men do. 

Which pay equity and transparency disclosure regulations are on the table, and on the horizon?

Pay data disclosure regulations are an important step toward closing this gap. The UK and France currently mandate this, as does the EU’s Sustainable Finance Disclosure Regulation (SFDR). Back home, states such as California and Illinois already require pay data reporting, and several states and cities also mandate, or are about to mandate, various forms of pay transparency during the hiring process – as eloquently outlined by Syndio’s Christine Hendrickson.

Is EEO-1 component 2 coming back?

Nationally, the Biden Administration supports the collection of gender pay data, and the EEOC is again trying to collect EEO-1 Component 2 pay data, which was collected in 2017 and 2018, but later suspended by the Trump Administration. Only two companies we know of, Intel and Micron, wound up publicly releasing this expanded pay data. In our opinion, the Biden Administration’s move to resume this reporting is laudable, but it could be rescinded by future administrations. With that in mind, many are looking to the SEC to include some form of pay equity transparency in its upcoming human capital proposal.  

With that in mind, we analyzed which S&P 500 companies are currently disclosing gender pay data, outside of any U.S. mandate: 

  • Only 25 companies meet our criteria for fully transparent gender pay equity disclosures. We consider a company fully transparent if they disclose raw, unadjusted pay data for their entire global workforce. In our opinion, this method, which is used by companies like BNY Mellon and American Express, gives the public the bare minimum it needs to benchmark companies and track progress over time.
  • Microsoft also reported unadjusted pay data for the first time today, bringing the total number of fully disclosed companies to 26.  
  • Another four companies (Albemarle, DuPont, Iron Mountain, and Kellogg) only meet our criteria for partial disclosure. In three cases, this is because the company did not report data for their entire global workforce, and in one case – Kellogg – it’s because they did not break down how many employees they’re counting at each level. 
  • There are other companies who don’t meet our requirements for either full or partial disclosure, that are nonetheless analyzing and acting on the gender pay equity issue. For example, for many years Salesforce has published an equal pay assessment which details the percentage of their workforce that needs gender and race-based pay adjustments, and the cost of those adjustments. 
  • Another 97 companies fully disclose adjusted gender pay equity data. Instead of disclosing raw data, this group chooses to adjust pay by certain variables, such as job title or occupation, work experience, geography, or education level.

Finally, for a deep dive on how certain companies are performing, we recommend taking a look at Arunja Capital and Proxy Impact’s latest Racial and Gender Pay Scorecard. That study looked at 57 major U.S. companies, only seven of which received an “A” grade.

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