Disclosure Is Collapsing, Synchrony Is Winning Without RTO, and the EEOC Changes the Rules Again

Proxy Season Is Mostly Over. Meeting Season Isn’t.

We’re effectively at the end of proxy reporting season. PeopleReturn has now processed nearly 2,400 Russell 3000 proxy statements filed in 2026, and the filing rush is largely behind us.

But the actual shareholder meetings are still ahead. Roughly 72% of Russell 3000 annual meetings for companies that filed proxies have yet to occur, and more than 1,000 meetings are concentrated on just ten dates over the next several weeks:

  • May 21 โ€” 151 meetings
  • May 20 โ€” 130
  • May 14 โ€” 120
  • June 10 โ€” 110
  • June 4 โ€” 95
  • May 7 โ€” 94
  • June 3 โ€” 84
  • May 13 โ€” 82
  • June 11 โ€” 82
  • May 19 โ€” 81

In case you missed it last week, weโ€™ve again attached our workbook covering board disclosure, composition, refreshment, and governance policy trends from 2019โ€“2026 across indices, exchanges, and sectors.

Now attention turns to sustainability and broader human capital reporting season.

So far, 21.8% of the S&P 500 has completed sustainability and HCM-related reporting for 2026, and roughly another 30% are expected to report between now and the end of June.

Last year marked the beginning of a pullback in human capital disclosure and transparency. That trend has continued this year.

Our transparency score measures the share of quantitative disclosures companies provide across four categories:

  • Board of Directors (20%)
  • Workforce Representation (50%)
  • Employee Development (22%)
  • Pay Equity (8%)

The average S&P 500 transparency score now stands at 32.0 โ€” down from 41.2 last year and 45.9 two years ago.

Weโ€™ve already written extensively about the collapse in board diversity disclosure following the rollback of the Nasdaq Board Diversity Rule and broader changes in investor and regulatory expectations. But the decline is no longer isolated to boards.

Workforce representation disclosures โ€” which had remained relatively resilient through last year โ€” are now falling meaningfully as well.

The pullback is happening across every sector.

Communication Services and Information Technologyโ€”sectors that were previously among the most aggressive reportersโ€”have seen some of the steepest declines, while Real Estate and Utilities remain the most transparent overall.

Despite the broader decline, a handful of companies continue to provide unusually comprehensive disclosure across board, workforce, development, and pay metrics.

Sector leaders include:

At the other end of the spectrum, several large-cap companies have sharply reduced disclosure over the last two years:

The direction of travel is becoming clearer: companies are still talking about human capital, but they are increasingly providing fewer standardized, quantitative disclosures that allow investors to benchmark performance over time and across peers.

As sustainability reporting season ramps up through June, we’ll continue tracking where disclosure is holding up, where it’s disappearing, and which companies remain committed to transparency despite the broader pullback.

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The Financial Sector Is Moving One Direction. Synchrony Went the Other Way.

Most large financial services firms spent the last two years pushing employees back into the office, cutting costs, outsourcing work, and reducing headcount.

Synchrony chose a different path.

This week, Fortune highlighted the company after it became the first financial services firm in 23 years to rank #1 on the annual Fortune 100 Best Companies to Work For list. The company has now made the list for nine consecutive years and has ranked in the top 10 for the last three.

The article focused heavily on Synchrony’s approach to flexibility and trust-based management at a time when much of corporate America, especially banking and finance, has moved in the opposite direction.

As Synchrony CHRO DJ Casto put it:

“Five days in the office, and then Iโ€™m going to check the hours and what you’re working on. But you want people motivated and engaged?”

Unlike peers implementing strict return-to-office mandates, Synchrony operates what it calls a “flex model”:

  • no mandated office days
  • no badge swipe tracking
  • no surveillance or time monitoring

And notably, that flexibility extends beyond corporate employees to contact center workers as wellโ€”something still relatively uncommon in financial services.

The backdrop here matters.

Over the past 18 months, many of the largest financial institutions have moved aggressively toward stricter in-office requirements:

  • JPMorgan Chase and Goldman Sachs implemented five-day office mandates
  • Companies across banking and payments have simultaneously emphasized expense reduction, restructuring, and offshoring
  • A recent KPMG survey found 83% of CEOs expect a full return to office within three years

Synchrony’s leadership argues the industry may be optimizing for control instead of outcomes.

And at least so far, the numbers suggest their model is working.

Our employee review data places Synchrony near the top of its peer group, andโ€”importantlyโ€”its scores have held up far better than many competitors over the last several years.

Synchrony’s employee sentiment has softened somewhat since 2023โ€”like nearly every major employerโ€”but the decline has been relatively modest compared to several peers that experienced sharp deterioration following layoffs, restructurings, or return-to-office pushes.

At the same time, Synchrony has significantly outperformed many competitors from a shareholder return perspective.

The company’s leadership explicitly links those outcomes to culture and trust.

CEO Brian Doubles framed flexibility as a management philosophy rather than a perk:

“We measure our employees based on results and impact and outcomes โ€ฆ But we don’t measure time in office.”

One of the more interesting aspects of the story is that Synchrony is not positioning itself as “remote-first” or anti-office.

Leadership repeatedly emphasized that in-person collaboration, mentorship, and relationship building still matterโ€”but that forcing attendance is not the same thing as building culture. The company has reportedly reduced its real estate footprint by roughly 50% while redesigning offices around collaboration rather than individual desk work.

The timing is also notable given the broader AI discussion happening across corporate America.

While many firms are discussing AI primarily through the lens of productivity and labor reduction, Synchrony has leaned heavily into workforce trust and AI enablement simultaneously. Nearly 80% of employees reportedly believe AI will improve their careers, and nearly 90% say they trust the company to use AI responsibly and ethically.

That may ultimately be the more important signal here.

The companies that navigate the next phase of AI and workforce transformation most successfully may not be the ones with the strictest office policies or the lowest labor costsโ€”but the ones whose employees actually trust leadership enough to adapt alongside them.

Stranger Than Fiction

A few years ago, major investors, proxy advisors, regulators, and stock exchanges were all pressuring companies to disclose more information about workforce diversity and representation.

This week, the EEOC sued The New York Times, alleging the company discriminated against a white male employee in promotion decisions tied to diversity goals.

At nearly the same time, the agencyย published a press releaseย titled: โ€œEEOC Delivers on Administration Priorities and President Trumpโ€™s Executive Orders.โ€

The release highlights:

  • investigations into “DEI-related discrimination”
  • scrutiny of law firm diversity programs
  • enforcement tied to executive orders targeting “illegal DEI”
  • efforts to “root out unlawful DEI-motivated race and sex discrimination”

Regardless of where companies, investors, or employees stand politically, the direction of travel is becoming difficult to ignore.

Just a few years ago:

  • Nasdaq adopted a board diversity rule
  • BlackRock, State Street, and proxy advisors expanded disclosure expectations
  • companies raced to publish EEO-1 reports, diversity goals, and representation metrics

Now many of those same disclosures are disappearing, references to DEI are being rewritten or removed entirely, and federal enforcement priorities have reversed direction almost overnight.

The result is a corporate environment where many companies increasingly appear to believe that saying less is safer.


What we’re reading:

  • โ€˜Did we learn nothing?โ€™ Synchrony is hybrid, the Best Company to Work For, and puzzled by the return-to-office pushย Synchrony is the countryโ€™s largest provider of store credit cards, and a stalwart member of Fortuneโ€™s Best Companies to Work For list. The company just claimed the No. 1 spot, rising from No. 37 just five years ago, and marking its ninth consecutive year on the list. It is the first financial services firm to top the list in 23 years. Synchrony doesnโ€™t check the hours. The company, which employs roughly 20,000 people across hubs including Stamford, Conn., New York City, Chicago, Orlando and Costa Mesa, Calif., operates what Casto and CEO Brian Doubles call a โ€œflex modelโ€ โ€” no mandated days, no tracking of badge swipes, no surveillance. And yet the companyโ€™s New York City hub at Bryant Park is so packed that employees sometimes struggle to find a seat. (Fortune)
  • AI Is Forcing CEOs to Make a Stark Choice: Lay Off Workers or Make Them Do Moreย Company bosses are splitting into two camps over what the technologyโ€™s best, immediate benefits are. Neither calls for more hiring anytime soon. (Wall Street Journal) andย Corporate Layoffs Are Down 10% This Year, but the AI Reckoning Has Come for Techย 
  • Human Capital as an Investment Factor: Using H-1B Visa Data as a Proxy for Firm Innovation and Performanceย The US H-1B visa program for highly skilled foreign labor represents a unique proxy for firm investment into human capital. We find that the level of H-1B intensity within a firm is positively correlated with firm innovation, as measured by R&D intensity. We show that there is significant correlation between firm investment into human capital as proxied by the H-1B program and defined as H-1B intensity to firm financial performance including 1-, 3-, and 5-year revenue growth. Last, we demonstrate that the US market does, in fact, reward innovation-driven firms and sectors that invest in the H-1B application process with higher market returns. (The Journal of Impact and ESG Investing)
  • What 8,000 Annual Reports Reveal About Corporate “People Are Our Greatest Asset” Talkย In November 2020, the SEC quietly amended Regulation S-K to require public companies to disclose โ€œhuman capital resourcesโ€ in their annual 10-K filings. The hope was that companies with thoughtful human capital practices would now have a venue to describe them, and that the resulting disclosure would create a meaningful signal โ€” separating the firms that actually managed their workforce from the ones that just talked about it. Five years later, we have enough post-rule filings to test whether that hope was warranted.ย (Crabcake & Commerce)
  • Trump Administration Targets Dismantling of Already-Weakened DEIย After a remarkably successful effort to extinguish diversity, equity and inclusion programs at US employers, federal officials are stepping up their push against corporate Americaโ€™s remaining DEI initiatives. (Bloomberg)
  • Age fades as barrier to winning the CEO seatย For most older U.S. workers, ageism persists across the U.S. workplace, according to AARP. Yet in the highest echelons of leadership at U.S. companies, age is less of an impediment to advancement, according to the NBER research. The average age of CEOs at their appointment date jumped from about 47 in 2000 to 55 in 2023, the researchers said, citing data from LinkedIn and BoardEx. (ESG Dive)
  • What Companies Can Learn from Their Biggest Fansย Despite decades of effort by companies to boost engagement and loyalty, employee trust and customer commitment continue to decline. Most organizations try to fix deficiencies or incrementally raise satisfaction levels. But human behavior does not change in response to mildly positive experiences. The author argues that behavior shifts only when experiences are extremely positiveโ€”when people say they โ€œloveโ€ them.ย (Harvard Business Review)
  • DEI Goes Quiet, But The Returns Are Speaking Volumesย In the year or so since Donald Trump first signed a series of executive orders aimed at curbing diversity, equity and inclusion initiativesโ€”particularly among federal contractorsโ€”corporate America has moved quickly to scrub the language. Mentions of โ€œdiversityโ€ in filings and earnings calls have dropped sharply, and formal targets have quietly disappeared from disclosures. But beneath that retreat in rhetoric, the underlying economics appear far more durable. (Financial Advisor)

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