CRE Alliance - 2022 Public Comment Record

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1	Corporate Racial Equity Alliance: 2022 Public Comment Record
2	Feedback category	Topic	2022 public comment

3	Development process and principles	Development process	Collective action amplifies impact. Organizations uniting to challenge each other learn from one another, change outdated rules, and mend broken systems. Organizations can create feedback loops that promote change and reinforce action at the individual, market, and societal levels.
4	Development process and principles	Development process	Maybe trying to use social media to see more answers and doing more surveys to see more options and outcomes.
5	Development process and principles	Development process	I think creating more awareness.
6	Development process and principles	Development process	I think this is a great start and maybe we need others to hear about these great ideas and changes.
7	Development process and principles	Development process	Maybe do more to bring more people to speak about this idea and show that these issues matter.
8	Development process and principles	Development process	Maybe trying to speak the information even more.
9	Development process and principles	Development process	I would say create [a] creative and dynamic way of ensuring accountability with your standards.
10	Development process and principles	Development process	I think figuring out when or how you are going to check in with people/companies.
11	Development process and principles	Development process	Dealing with a lack of data, risk of moving to superficial assessments at the policy [level] rather than the performance level.
12	Development process and principles	Development process	Ensure accountability. Successful coalitions have systems in place to collect, analyze, and share data on the outputs and outcomes of their initiatives. These systems are based on an agreed upon set of principles on how impact will be measured and reported, and on how credit for accomplishments will be shared. Racial equity stakeholders are already taking steps to develop and strengthen such systems.
13	Development process and principles	Development process	I think this is good but take it a step further [by asking] how rather than just why.
14	Development process and principles	Development process	Develop structures to examine, identify, and address systemic biases and deficiencies in its policies, practices, and programs.
15	Development process and principles	Development process	Emphasize equity, diversity, and inclusion in program design, implementation, goals, objectives, and outcomes.
16	Development process and principles	Development process	We understand that the process of developing corporate standards is a complicated process. Still we would have hoped for a bit more detail about the framework in this iteration. It would be helpful to better understand how and why these levers were selected and what the journey from the blueprint to the framework has been.
17	Development process and principles	Development process	Know yourself and your organization. Systemic change requires a recognition and acceptance on the part of everyone in public service that they too must be willing to change. Individual reflection and evolution must be an explicit part of any systemic change.
18	Development process and principles	Development process	Have workshop whereby people can be taught on developing performance standards.
19	Development process and principles	Development process	Develop a framework. As you review your policies and procedures, creating a framework can help you ensure you produce durable and meaningful initiatives. This involves developing guidelines that align with your business strategy, mission, values, and philosophy. Experts recommend reviewing policies and practices from the perspective of impact on employees, customers, and the larger society, and using this data to inform your framework. These guidelines will help ensure processes, tools, and experiences around the employee journey, vendor selection, and corporate philanthropic efforts are consistent with your equity goals.
20	Development process and principles	Development process	Focus more on concrete ideas as these six steps seem to be very abstract, like it's the outline of the steps and not [the] actual steps. I'm sure once the plans begins being implemented it will have actual substance, so maybe since this is still in research phases, it will turn out better in the future.
21	Development process and principles	Development process	As the report mentions, it is very difficult to create a one-size-fits-all plan for racial equity in a company, as every company is different. Having a constantly evolving or more personalised plan for specific companies through consultation or another method of monitoring the progress and resources of said company, would be an invaluable addition, if possible.
22	Development process and principles	Development process	According to the reading, the work of standard-setting is meant as complimentary. They are not meant to eliminate or not take into account the other pertinent interventions that must be incorporated to have a successful outcome. I would suggest that there be strict monitoring on a continuous short time frame basis for the upholding of the standards once firmly structured and set as practice.
23	Development process and principles	Development process	Your approach to standards development does highlight the need for a diverse team, stakeholder engagement that prioritizes people of color and low-income people, and a ground-up approach that uses informed expertise and wisdom from underserved communities. With this being said, I think your standards development could be strengthened by providing more detail on how these actions are being implemented. How is a diverse team chosen? How are the experiences and wisdom of people of color and low-income communities being included in the process?
24	Development process and principles	Development process	The process you engaged in to develop the standards seemed quite comprehensive. The resources that you looked for how standards had been developed by other groups, speak more to process than content that is relatable to racial equity.
25	Development process and principles	Development process	Successful coalitions are committed to and united around a clear mission. [equal rights campaign], a campaign that was active in the United States between 2001 and 2016, rallied its supporters around a clear goal: winning marriage for same-sex couples. As early as 2001, fourteen years before marriage equality was achieved in the United States, founder [name] urged movement leaders, supporters, and allies to focus on that goal [saying,] "We may leave the room not getting everything we want, but don't go in bargaining against yourself."
26	Development process and principles	Development process	I would have liked to see how the approach to standards development took into account the feasibility of these standards being adopted on an impactful scale. Although I think it's great to set the bar high, I think many young people, such as myself, are disillusioned with corporate America and would like to see standards that we believe companies might actually adopt.
27	Development process and principles	Development process	The webinars are a good start. How will you ensure businesses will want to attend? What's in it for them? What is so special about the certification they will be awarded for making these changes?
28	Development process and principles	Development process	I have the impression at this point that this effort is driven by a naïve view of companies, i.e., the assumption that they are willing to entertain prioritizing social justice, especially when it competes with short-term profits.
29	Development process and principles	Development process	The power to spend is the power to change. Government organizations have the power to drive equity through all the ways they spend money-for example, directing funds in pursuit of equitable outcomes through everyday business operations.
30	Development process and principles	Development process	Identifying what is at stake and how to accomplish a well rounded program.
31	Development process and principles	Development process	Beliefs drive behavior and behavior changes beliefs. To achieve equitable outcomes, organizations must overturn common beliefs and behaviors that get in the way. New behaviors shape new values, while those values can reinforce new behavior.
32	Development process and principles	Development process	Be sure you create something that’s new (i.e., drawing on existing standards makes sense but creates the risk of reiterating existing assessments).
33	Development process and principles	Development process	I believe an exceptionally strong approach to development of standards has been laid out.
34	Development process and principles	Development process	I like the current steps as they are.
35	Development process and principles	Development process	I think you guys have a great way of approaching it. I just hope that this works and allows for changes to be made.
36	Development process and principles	Development process	Currently, I do not see any need for additional steps. What I see is very thorough and well planned.
37	Development process and principles	Development process	I believe this is a great start and from this we can grow and see what more we must do to bring changes within our community.
38	Development process and principles	Development process	I feel like from what I have read, this seems to be the best way to start the change and see what happens from here. A lot of the changes, I believe, I can resonate with as well.
39	Development process and principles	Development process	I undoubtedly believe that these guiding principles create a solid foundation for the development and application of the standards. I wish I had meaningful feedback; like I said prior, however, y'all truly hit the nail on the head point after point (and goal after goal).
40	Development process and principles	Development process	The steps are flawless in my opinion.
41	Development process and principles	Development process	Overall I am very impressed with your approach and your willingness to share and ask for feedback from those most affected by equitable racial and economic transformation. I appreciate that you recognize that this is a first step, and I'm grateful that you're working so thoughtfully on developing and sharing the standards.
42	Development process and principles	Development process	I can't think of anything at this time. I truly appreciate the thoughtful creation process of the standards that have been developed.
43	Development process and principles	Development process	I feel like the approach used in this report touches on standards development in an appropriate manner. Even when it came to things that I, as a person of color, haven't thought about.
44	Development process and principles	Development process	Equity takes race, gender, ethnicity and other identifying factors into consideration when developing processes and presenting opportunities.
45	Development process and principles	Development process	More people of color in the development [process].
46	Development process and principles	Development process	Where to draw the boundaries of the framework? Doesn’t everything a company does relate to racial justice?
47	Development process and principles	Development process	Would it be possible for this goal to spread further than just corporate businesses? If so, then we could look into ways to engage with the community.
48	Development process and principles	Development process	Since many nonprofits operate under what is essentially a corporate structure, I would suggest including a nonprofit cohort in the pilot.
49	Development process and principles	Development process	I think conducting additional surveys and having more statistics would help.
50	Development process and principles	Development process	Yes, look for ways to merge cultures and people of different academic levels.
51	Development process and principles	Development process	Exactly what you're doing right now: Establish the framework, receive any feedback and seriously consider adopting those changes, compensate participants for their time and expertise.
52	Development process and principles	Development process	Maybe try to survey how people would want to implement this change and see if people are even okay with changing. Many people don't want changes to occur but we need this to happen for the greater good.
53	Development process and principles	Development process	Conducting surveys would strength the approach to standard development.
54	Development process and principles	Development process	Maybe try to survey people in seeing how to approach the development.
55	Development process and principles	Development process	Working with people of all disciplines always helps shape policy development. In my field of health, one of the main flaws is that too many people in health are speaking, while we need people outside of health to help us enact change.
56	Development process and principles	Development process	Include people from the community in the planning process, not just in a roundtable.
57	Development process and principles	Development process	In the accountability section, I think it is imperative to implement community members of multifarious organizations as part of this process. In doing so, their role should not be performative, but genuinely impactful. If one or more members voices their concerns, then these should be addressed and not by removing them from their position, but by taking their concerns seriously. One thing to note about community work; it goes slow. Everybody wants changes to happen fast, but change is slow. Always has been. Always will be. With this approach, change will be slow, deliberation will occur, pushback is inevitable but the reward is often times a better, safer place for everyone. Thus, employ and empower community members to help make a difference in their community and hold your organization accountable in the process.
58	Development process and principles	Development process	Based on what I've read and observed from the meeting today, I think you guys have a great team. If I were to add anything I would say maybe include persons who sit on boards that deals with policy changes, etc.
59	Development process and principles	Development process	Having teamwork with the shareholders and implementing what has been proposed.
60	Development process and principles	Development process	Add a step where you get the thoughts and words from people that may not have access to the internet (for example, homeless people or low-income individuals who have no access to the internet).
61	Development process and principles	Development process	Consider implementing your approaches with groups across age demographics. Gen Z and young Millennials have much to offer to these conversations and policies.
62	Development process and principles	Development process	It can be advertised to the youth that it is also a necessity to lobby for the implementation of those standards into the law.
63	Development process and principles	Development process	For the Scope of the CEO Blueprint for Racial Equity within the Company, the Worker Power and Voice should [be] as diverse as possible. The people in charge of this should come from many different backgrounds and experiences.
64	Development process and principles	Development process	Based on the graphic at page 32, it seems that it is already at the last stage of the development process. I guess at this stage, it would be most important to have companies adopt the standards, and report, to see what works well and if there are any tweaks that can enhance corporate adoption. I also think that is very important to develop ESG standards to assess racial equity and mandate disclosure. For instance, it is more common for companies to share data on the gender pay gap, but less common (or almost non-existing) to report on the racial pay gap.
65	Development process and principles	Principles	The Guiding Principles for Developing the Standards are good, I feel as though the third founding principle “lifting up what works” could use more details. The principle in itself is good but it feels as though there should be more to it, than just using what works. Possibility includes what this might look like, such as being involved in community events to be open to dialogue with community members. For example, in my hometown, Des Moines we have nearby companies host booths at festivals and events for representation within the community.
66	Development process and principles	Principles	Maybe go into a bit more detail on number three, "Lifting Up What Works."
67	Development process and principles	Principles	Overall we find the approach to developing standards robust. On Guiding Principle three, however, we recommend adding more clarity on what is meant by “what works.” Through our work to identify and share “what works” to improve financial health, we have learned that there are both challenges and opportunities in how you define this.
68	Development process and principles	Principles	These steps are great. It is very important to be sure to include the diverse team so that there is true understanding of the importance and struggle people are going through. It is good to have this mission be transparent and open to all but I feel it needs to be even more than this. As stated in previous sections, this fight will need everyone to play a role to make a change. There should be more outreach to communities and companies. These steps are not very specific and should explain more action that needs to be taken.
69	Development process and principles	Principles	Along with the six guiding principles already in place to developing standards for racial equity initiatives, there should be a guideline regarding the deprogramming of current company beliefs and employee biases to ensure that all new goals and initiatives are met with nothing but enthusiasm and commitment.
70	Development process and principles	Principles	For principle five, building a big tent and robust standards that stand the test of time. I am unaware of the [meaning of the] statement “building a big tent”, is it referring to building a solid foundation?
71	Development process and principles	Principles	I believe that the current plan is already set up for future success, as the guiding principles are clear, and the phasing of the development will allow for a smoother implementation.
72	Development process and principles	Principles	The ones in the blueprint are enough.
73	Development process and principles	Principles	It looks great and understandable! It's easily comprehensive.
74	Development process and principles	Principles	For example, through our [program name], we take a rigorous approach, working with companies to A/B test specific tactics, isolate their impact, and identify causal relationships between tactics and impact. This method provides strong evidence for “what works”; however, it is time- and resource-consuming to execute. An alternate approach is to identify leading practices in the market. This was the basis for our [program name] and the creation of the assessment tool used by J.D. [program name] program (our team at [organization] collaborated with J.D. Power to develop the evaluation framework, based on the [program name]). While this does not provide the proof of causal impact, it is less time- and resource-intensive. However, we do find that this assessment needs regular review and updating to ensure it remains a set of leading standards based on the state of the industry and the needs of consumers. In this way, we do agree that standards setting can often be more art than science.
75	Governance		[It's] unclear if there will be a bipartisan board of volunteers to review these standards periodically or if internal audits will be conducted.
76	Governance		I feel the governance approach should be strengthened and I would refer to Elinor Ostrom's Nobel lecture, pg. 13 on her 8 principles of governance for guidance.
77	Standard Structure	Assurance / Accountability	On assurance, I think third party review is great. Disclosure is great, but can also have its own third party review as well. Are you presenting two mechanisms that both rely on third party, or is one purely self-reporting?
78	Standard Structure	Assurance / Accountability	Re. disclosure; this can be done by a company alone (self-reporting) or with third–party assurance/audit (e.g., like greenhouse gas emissions). [It] would be good to highlight which you mean so that the distinction with the second option is also more clear.
79	Standard Structure	Assurance / Accountability	Audit firm selection will be critical to ensuring the reported metrics are legitimate.
80	Standard Structure	Assurance / Accountability	Making sure companies don't self report because then they will just report what is better for them, rather than reality.
81	Standard Structure	Assurance / Accountability	Ensure a third party is involved to monitor the progress.
82	Standard Structure	Assurance / Accountability	The more public we can make participation in these standards and progress towards achieving them, the better! It would be powerful if corporate bond rating organizations included at least a reference to an organizations' participation and achievement related to these standards.
83	Standard Structure	Assurance / Accountability	Granularity and transparency of results is key. Especially feedback from at least a random sample of ultimate beneficiaries will be key, to show actual use and change of living standards, equity, etc. Verified data is the best answer to "woke capitalism."
84	Standard Structure	Assurance / Accountability	I like the approaches listed so far. When it comes to the self-assessment tool, I really like that idea a lot. If it is implemented, I think it needs to be thorough and not just some sort of checklist item. I think making sure discussion workshops and questions go in-depth, in said assessment tool, is a must.
85	Standard Structure	Assurance / Accountability	When it comes to standard setting, efficiency checks should be put in to make sure these standards are actually being followed in a professional setting.
86	Standard Structure	Assurance / Accountability	In terms of accountability, how will we know those companies are truly committed to the journey?
87	Standard Structure	Assurance / Accountability	How will you collect the data to make sure companies are not reneging on their commitment?
88	Standard Structure	Assurance / Accountability	I would potentially expand upon the disclosure portion. Many ESG frameworks have struggled in how they gain information from companies. Often, if it it company based it is biased. How will you ensure that all data is disclosed?
89	Standard Structure	Assurance / Accountability	Assurance needs also to be added to ensure we can believe what is being reported. In addition, a stakeholder engagement platform identifying which stakeholders are included and how, their material interests, what initiatives are being implemented, and their impact need to be reported.
90	Standard Structure	Assurance / Accountability	Accountability needs to be transparent.
91	Standard Structure	Assurance / Accountability	I particularly like the assurance part of the framework.
92	Standard Structure	Assurance / Accountability	Could some kind of penalty be added for those that fail to comply with equality?
93	Standard Structure	Assurance / Accountability	https://www.prlog.org/12871675-petition-to-the-sec-for-rulemaking-on-black-lives-matter-pledges.html Request the SEC develop mandatory rules for public companies to disclose high-quality, comparable, decision-useful information concerning BLM Pledge fulfillment. https://www.sec.gov/comments/4-774/4-774.htm
94	Standard Structure	Assurance / Accountability	Similar to what someone suggested in the meeting--potentially define an ESG report for those who aren't entirely familiar!
95	Standard Structure	Assurance / Accountability	How do we help design accountability measures, that if [racial equity] is not happening how do we help people recognize that it's not happening and actually shift the norm? I think it's great that we're talking about shifting culture and really talking about norms. That's why I’m also thinking about the individual.
96	Standard Structure	Assurance / Accountability	Overall good but as always, the devil is in the details and vital to reward those best complying [organizations]. And what happens if they don’t [comply]?
97	Standard Structure	Assurance / Accountability	Sharing racial and ethnic representation levels transparency--companies have started to collect demographic data of their workforce and publish annual diversity reports about racial and ethnic representation across their business. When collecting such data, companies need to ensure that employees are protected from negative, unintended consequences of such data disclosure.
98	Standard Structure	Assurance / Accountability	Another idea would be to create a team that audits the businesses which partner with the CRE Alliance, interviewing employees, and working with the created diversity committee.
99	Standard Structure	Assurance / Accountability	In the "how to use" guidance for this, what guidance will be included on who within a corporation or community leads/does the audit/assessments or measures progress, both initially and ongoing?
100	Standard Structure	Duty owed	The one place I’m having a sticking point is around the notion of duty owed. Says who? We might want to spell out where you are making an ethical or legal argument or the various places where that could come from. It’s signaling a duty, but something else could bolster that.