November 23, 2020
Via Electronic Filing (www.beta.regulations.gov)
Re: Executive Order 13950 Combating Race and Sex Stereotyping
Dear President Trump, Secretary Scalia and Director Vought,
We are White Men as Full Diversity Partners (WMFDP), the firm whose documents and programs were misrepresented, maligned and released on Twitter by Christopher F. Rufo, a Director at the Discovery Institute, whose factually incorrect reporting led to Executive Order 13950.
For more than 25 years, we have worked with Fortune 1000 companies and government agencies to create inclusive cultures where everyone, regardless of skin color, gender, sexual orientation or any other dimension of difference, feels like they belong. This is our mission—to help leaders create inclusive cultures at work which help to improve competitiveness and profitability and also help to create a better world for everyone.
We have led thousands of people, leaders, white men and women, and people of color (and all of the other dimensions of difference people can see and feel) through sometimes difficult conversations which have resulted in profound and lasting change for them individually, as well as collectively, for their organizations.
Executive Order 13950 alludes to the foundations of our democracy, as captured in these words, “We hold these truths to be self-evident, that all men are created equal,” and “in the inherent equality of every individual…” This too is our goal—to have everyone feel they have equal rights and opportunities in this country for education, work, housing and a myriad of other basic human needs.
It is why we must respond strongly to Executive Order 13950. This Executive Order, based on Christopher F. Rufo’s recounting, is misinformed, based on factual misrepresentations and a fundamental misunderstanding of the nature of diversity, equity and inclusion work—the work we and fellow practitioners do with our clients.
Quite simply, the Executive Orders’ interpretation of our work and of diversity, equity and inclusion (DEI) efforts generally is misguided.
It is far from who we are and what we do. We and fellow DEI practitioners strive for the opposite of what the Executive Order states we do: We aim to create an inclusive world for all, including those who disagree. Tactics like shame and blame are precisely what we don’t do because they don’t work to build inclusivity—they only create further division and upset.
The Executive Order promotes colorblindness under the guise of inclusivity. In doing so, it negates the very differences we attempt to overcome as practitioners and supporters of equal opportunity for all—the very real and different lived experiences people in the United States are having based solely on the darkness or lightness of their skin or on their gender.
The Executive Order perpetuates a myth that people of color and women currently have equal access to opportunity in the United States. Worse, it reinforces structural racism and sexism and supports ongoing discrimination based on race, gender, and sexual orientation, which significantly affects our quality of life and work, costing our economy trillions.
We recognize that this Executive Order will most likely be overturned by the incoming Biden-Harris Administration. In the meantime, we request you do not enforce this order. It is poorly constructed, ambiguous, violates freedom of speech, and is a stain on our country.
We submit our formal commentary on behalf of our firm to demonstrate the impact this Executive Order has had on our employees, our company, our profession, our clients and our country.
- Who we are and why we do what we do
To begin, our firm’s name is our mission: We are White Men as Full Diversity Partners (WMFDP). Yes, we know our name is provocative. That’s the point.
White people are essential agents of change towards greater inclusion, equity and justice because in the US, white people, especially men, hold the majority of our leadership positions in business and politics. White people, and white men in particular, have pivotal roles to play in creating and sustaining work cultures and communities where everyone is valued, heard and respected. Overwhelmingly represented in leadership positions, white men control resources and set the tone of our cultural values.
Consider that currently, just 1% of the Fortune 500 CEOs are African-Americans despite comprising 13.4% of the U.S. population. Since 1999, there have only been 18 black CEOs of Fortune 500 companies. There are only three minority NFL coaches. Notably, the Trump administration’s cabinet is 86% white despite whites making up only 65% of the US population. Only 18.4% of the Trump administration’s cabinet are women. Positions of power in the USA are overwhelmingly white—and male.
If whites, particularly men, who control most of the resources in this country do not participate in the conversation on creating inclusive cultures, inclusivity and equality will not happen.
Additionally, there is a huge and unjust burden placed on women and people of color to drive diversity and inclusion. Traditionally, when white male business leaders endeavor to create more diverse and inclusive cultures in their organizations, they look to women and people of color. Chief Diversity Officers at Fortune 500 companies are almost always people of color and often women; rarely are they white men. In executive offices, when the issue of diversity and inclusion comes up, the people of color in the room are often asked to explain what needs to be done to fix the problem.
While women and people of color need to have a voice at the table, they are not the source of the problem. Simply put, it is unfair to continue to ask women and people of color to shoulder the brunt of the DEI work as individuals and for organizations. We invite white people in positions of leadership to not just be at the table, but to lead the discussion.
It’s important to note this discrepancy: Business leaders are routinely able to strategize and solve complex problems and steer massive, multinational corporations. We need to shift mindsets and expect that we as business leaders can apply our business skills and acumen to view the lack of diversity, inclusion and equity as a business imperative, as well.
- What we do
For us at WMFDP, our work is first and foremost about leadership development. It is grounded in deep partnership and views DEI as the lens through which we lead and do business—what we call inclusive leadership. It is quite literally the opposite of the “shame and blame” practices that the Executive Order alleges.
In fact, in our 25 years of work, our reputation for excellence has preceded us and has afforded us a robust referral network working with the US’s leading companies and organizations. For the many leaders who’ve attended our sessions, their experience with us is life-changing, deepening partnerships and relationships at work and at home.
We support and challenge white men to see their roles in co-creating inclusion while also offering sessions that help white women and people of color see their work to strengthen partnerships at work. During our programs, we encourage participants to choose their own level of participation and disclosure. We do not force, require, or intimidate anyone. We do not employ trainers—we facilitate conversations and have a team of process professionals skilled in courageous conversation and leadership development.
We underscore the importance of building awareness and seeing the often invisible characteristics of our culture so that we understand its strengths and weaknesses at the individual, partnership and organizational levels.
Our work acknowledges that, in the US and around the globe, we have different lived experiences because of our race, gender, class, background and more. We explore systemic advantages and disadvantages and how that presents in our workplaces. We talk of our layers of identity and what it’s like to navigate them for ourselves and for others. Much of our work is about providing a supportive learning journey as participants become more aware of parts of our story, history and cultural framework that are unexamined or unrecognized. Learning about new and difficult parts of our past and present lived experiences can be uncomfortable—but that doesn’t mean it should be avoided or denigrated.
We help participants learn the skills of partnership across difference, however it presents itself, because in an increasingly more diverse world and workforce, it is vital that we be able to work together effectively and that we be able to bring our full gifts and talents to the workplace to drive innovation and business. We inspire each and every one of our participants to identify why DEI uniquely matters to and for them, regardless of their race, gender or other dimension of difference.
As a firm who intentionally seeks out a group historically not involved in DEI efforts—white men—we are also no strangers to resistance. We are well versed in working with who we call, “willing skeptics,” those who doubt they are personally connected to DEI because they’ve often viewed themselves as outside of these efforts.
Our premise is that diversity, inclusion and equity work matters to and for each and every one of us personally and that what benefits all, benefits the individual, too. For many of the white men we work with, that often means exploring the ways in which they’ve been personally impacted by our cultural prescriptions of whiteness and maleness—both positively and negatively.
Overwhelmingly, white men find tremendous benefit in our programs. In the decades we’ve been doing this, we often hear how white men never dreamed of how much the learning would benefit them. They discover ways to be better leaders, stronger fathers, better partners in their significant relationships, and have deeper friendships of support in their lives. We don’t tell them how to think or what to believe. We invite reflection and dialogue amongst peers on these very complex topics.
In short, this work empowers and liberates white men. The breakthroughs white men experience with us are routinely described as life-changing, capstone moments propelling them to more inclusive and courageous leadership and partnership at work and at home. For many white men, their time with us are highlights in their professional development. They are genuinely grateful and appreciative.
Fundamentally, we cannot do the meaningful work we do, of building inclusive leadership, if we blame, shame or discount peoples’ experiences. Instead, we build the skills and frameworks necessary to acknowledge our personal lived experiences and how they can be the same—or very different—from others’ lived experiences. From there, we build inclusivity and partnership across difference through curiosity, inquiry, heartfelt dialogue, and courageous explorations into our mindsets and assumptions.
We are, quite literally, the opposite of what the Executive Order purports.
- Misinformed foundations
The Executive Order is based on faulty information, stemming from mischaracterizations and misrepresentation of our work as reported by Christopher F. Rufo late in the summer of 2020. Rufo leaked documents from one of our sessions with a government client to support his claims, mischaracterizing our materials and discharging a series of harmful behavior and events in the process, the greatest of which is the writing of this Executive Order.
That the foundations and premise of the Executive Order rest on misinformation is of great concern and importance given the Executive Order’s expedient and wide-ranging ramifications. Add to it that this Executive Order circumvented processes intended to substantiate its contents, and we now have in effect an Order that dangerously misconstrues an entire profession and practice, and with it, the lived experience of millions of our fellow citizens and residents.
As it stands, the Executive Order has a tremendous number of problems, many of which are outlined here below, in injunctions like the one filed by the NAACP Legal Defense Fund and in open letters from captains of industry around the country.
- The Executive Order intentionally mischaracterizes and misrepresents DEI programs and professionals.
As detailed above, the foundations of the Executive Order are factually inaccurate and intentionally misrepresentative of our work at WMFDP and that of DEI as a profession. The Executive Order’s misrepresentation of our work oversimplifies DEI, the nature of which is complex, layered and dynamic.
The impact on our firm and on our industry is that it has decreased our revenue, and for some practitioners, it has jeopardized their ability to work. It also sows doubt and distrust of practices, practitioners and programs that we know benefit our workplaces, our economy and our workers.
The business community understands that a more diverse and inclusive workplace is a more successful workplace, which is why organizations actively seek DEI programs and why so many companies have decried the Executive Order. A few statistics:
- According to a May 2020 McKinsey Consulting study, ethnically diverse companies are 36% more likely to financially outperform their peers.
- Companies that have more diverse management teams have 19% higher revenue due to innovation.
- Businesses with greater racial and gender diversity bring in higher sales revenue, more customers and greater profits.
In short, the Executive Order puts a chilling effect on a practice that improves our public entities and private businesses alike. We know DEI works for the benefit of businesses, individuals and our communities across the country.
- The Executive Order ignores the desires of our employees, partners and clients, who all call for more DEI programs and greater change towards more inclusion, equity and justice.
As the data above reveals, the business community actively seeks DEI programs, emanating from internal requests from their employees, from efforts to better understand their clients, and from wanting to be better allies.
Denying companies and organizations the ability to participate in practices and programs that they seek undermines their ability to be more innovative, more competitive, and more desirable places to work.
Additionally, the Executive Order keeps organizations and companies from responding to current social and political movements, such as support for Black Lives Matter, in ways that could more profoundly and actively support the challenges facing their employees and businesses. It constricts organizations’ ability to respond in real time to current events and experiences of racism, sexism and other forms of discrimination.
The Executive Order puts our economic vitality in question by exposing our workplaces to more discrimination and forbidding them from engaging in the DEI programs and practices that improve their products, revenue and workplace cultures, benefitting our economy and our people.
- The Executive Order is unclear, subjective and ambiguous, creating confusion and significant burden.
The Executive Order is so unclear and vague on what constitutes divisiveness that companies have paused trainings, resulting in exactly the opposite of what the Order purports to support.
As a DEI firm, it is virtually impossible to understand the directives of the Executive Order and to concretely understand how to amend our curriculum accordingly: It is unclear on what will be seen as divisive in training materials, approach and impact. It gives little guidance on how multinational organizations should consider their overseas operations.
Relatedly, the Executive Order’s subjective investigative process gives little direction as to what constitutes a complaint or violation of the Order. It indicates that feelings of discomfort are sufficient for submitting a complaint, ignoring the idea that meaningful learning can be inherently challenging. The nature of DEI programs is to challenge us to see and behave inclusively. As with every new skill and learning journey, it can be uncomfortable to learn something anew.
The Executive Order’s subjectivity and ambiguity create confusion and significant burden for practitioners and companies alike who must interpret, possibly incorrectly, the meaning of the Executive Order and attempt to align their programs. The confusion exposes companies to greater risk, destabilizing efforts to foster more inclusive workplaces.
- The Executive Order encroaches on freedom of speech and is a form of censorship.
The Executive Order curtails industries’ abilities to present and consider multiple perspectives, from important scientific research that considers race and gender as variables in health to how we tell and remember our collective history.
Its labeling of difficult conversations as divisive sets a dangerous precedent.
Of greatest impact to WMFDP, the Executive Order’s review of internal training materials and dictates of which terminology to use in DEI programs is unprecedented, expansive and intrusive. It stifles our industry’s ability to use terminology that would help further clarify our current lived experiences, resulting in more confusion and obfuscation.
Forbidding terms like “privilege,” “unconscious bias,” and “intersectionality” aims to further stoke confusion and thwart deep and meaningful conversations on differences and on our different lived experiences.
Doing the above hampers our protected and essential right to exercise our freedom of speech and to contribute to the breadth of human knowledge.
- The Executive Order impedes positive momentum, denies our country’s history, and ignores our core values.
The Executive Order rejects important research, scholarship, and corporate-led efforts intended to promote racial and gender equity. It reverses important civil rights law and curtails racial reconciliation in an effort to address racism, further delaying our ability to create cultures of inclusion.
At its core, the Executive Order undermines our ability to execute on the American ideals of equality and justice for all.
- The Executive Order perpetuates systemic racism and sexism by denying our history as a country and privileging the comfort of certain groups but not others.
The Executive Order interrupts our collective ability to advance racial and gender equity today, further drawing out discomfort and tension. It attempts to silence and simplify our country’s detailed and documented experiences of racism and sexism, declaring these experiences of systemic injustice and inequity as either vanquished or imagined.
The Executive Order centers the white male experience and denies the different lived experiences of men and women of color and of white women. It is white male privilege and fragility realized, using the power and position of the role of President of the United States to chill and silence meaningful discourse on racism, sexism and discrimnation in our workplaces and federal institutions.
By attempting to control and legislate how we discuss issues of DEI, the Executive Order further compounds centuries of oppressive and divisive policies that keep us from creating truly inclusive, equitable and just cultures. It is exactly what it claims to refute: Systemic racism and sexism in action.
Our appeal to you is that you rescind the Executive Order.
It is critical and vital for the functioning of our democracy and for the vitality of our economy and people that we are able to engage in deep, meaningful dialogue and learning of racism, sexism and other forms of discrmination and how to create true cultures of inclusion, equity and justice.
DEI support our American ideals and the plurality of our country. We must support the practice, practitioners and programs.