October 16, 2000 This amicus brief was filed in the following legal cases:
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
________________________________ JENNIFER GRATZ, et al.,
Plaintiffs, v.
LEE BOLLINGER, et al.,
Defendants.
________________________________
)
)
) Civil Action No. 97-75231
)
) Hon. Patrick J. Duggan
) Hon. Thomas A. Carlson
)
)
)
)
)MOTION OF STEELCASE, INC., 3M, ABBOTT LABORATORIES, BANK ONE CORPORATION, E. I. DU PONT DE NEMOURS & CO., INC., THE DOW CHEMICAL COMPANY, EASTMAN KODAK COMPANY, ELI LILLY & COMPANY, GENERAL MILLS, INC., INTEL CORPORATION, JOHNSON & JOHNSON, KELLOGG COMPANY, KPMG INTERNATIONAL, LUCENT TECHNOLOGIES, INC., MICROSOFT CORPORATION, PPG INDUSTRIES, INC., THE PROCTER & GAMBLE COMPANY, SARA LEE CORPORATION, TEXACO INC., AND TRW INC. FOR LEAVE TO FILE BRIEF AS AMICI CURIAE IN SUPPORT OF DEFENDANTS AND FOR LEAVE TO FILE OUT OF TIME
Jon D. Botsford
Senior Vice President, Secretary and
Chief Legal Officer
Steelcase Inc.
CH-4E
901 44th Street SE
Grand Rapids, MI 49508
Dwight K. Hamilton
Corporate Counsel
Steelcase Inc.
CH-2E-06
901 44th Street SE
Grand Rapids, MI 49508
Attorneys for Amici CuriaeRandall E. Mehrberg
Jeffrey S. Silver
JENNER & BLOCK
One IBM Plaza
Chicago, IL 60611
(312) 222-9350
Deanne E. Maynard
Shilpa S. Satoskar
Daniel Mach
JENNER & BLOCK
601 Thirteenth Street, N.W.
Washington, D.C. 20005
(202) 639-6000Dated: October 16, 2000
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
________________________________ BARBARA GRUTTER, et al.,
Plaintiffs, v.
LEE BOLLINGER, et al.,
Defendants.
________________________________
)
)
) Civil Action No. 97-75928
)
) Hon. Bernard Friedman
) Hon. Virginia Morgan
)
)
)
)
)BRIEF OF STEELCASE, INC., 3M, BANK ONE CORPORATION, ABBOTT LABORATORIES, E. I. DU PONT DE NEMOURS & CO., INC., THE DOW CHEMICAL COMPANY, EASTMAN KODAK COMPANY, ELI LILLY & COMPANY, GENERAL MILLS, INC., INTEL CORPORATION, JOHNSON & JOHNSON, KELLOGG COMPANY, KPMG INTERNATIONAL, LUCENT TECHNOLOGIES, INC., MICROSOFT CORPORATION, PPG INDUSTRIES, INC., THE PROCTER & GAMBLE COMPANY, SARA LEE CORPORATION, TEXACO INC., AND TRW INC. AS AMICI CURIAE IN SUPPORT OF DEFENDANTS
Jon D. Botsford
Senior Vice President, Secretary and
Chief Legal Officer
Steelcase Inc.
CH-4E
901 44th Street SE
Grand Rapids, MI 49508
Dwight K. Hamilton
Corporate Counsel
Steelcase Inc.
CH-2E-06
901 44th Street SE
Grand Rapids, MI 49508
Attorneys for Amici CuriaeRandall E. Mehrberg
Jeffrey S. Silver
JENNER & BLOCK
One IBM Plaza
Chicago, IL 60611
(312) 222-9350
Deanne E. Maynard
Shilpa S. Satoskar
Daniel Mach
JENNER & BLOCK
601 Thirteenth Street, N.W.
Washington, D.C. 20005
(202) 639-6000Dated: October 16, 2000
Steelcase, Inc., 3M, Abbott Laboratories, Bank One Corporation, E. I. du Pont de Nemours & Co., Inc., The Dow Chemical Company, Eastman Kodak Company, Eli Lilly & Company, General Mills, Inc., Intel Corporation, Johnson & Johnson, Kellogg Company, KPMG International on behalf of its United States member firm, KPMG LLP, Lucent Technologies, Inc., Microsoft Corporation, PPG Industries, Inc., The Procter & Gamble Company, Sara Lee Corporation, Texaco Inc., and TRW Inc. hereby move for leave to file a brief as amici curiae in the above-captioned case, and for leave to file the brief out of time. A copy of the brief accompanies this motion. As grounds for this motion, amici state as follows:
1. Amici are global corporations that recruit at the University of Michigan or similar leading institutions of higher education. Many of the amici have a substantial business presence in the state of Michigan, some are headquartered in Michigan, and all have ties to Michigan corporations and customers. Racial and ethnic diversity in institutions of higher education is vital to amici's efforts to hire and maintain a diverse workforce, and to employ individuals of all backgrounds who have been educated in a diverse environment. Such a talented workforce is important to amici's continued success in the global marketplace.
2. Amici corporations have devoted substantial financial and human resources to create and maintain such a workforce. These extensive efforts are part of the very fabric of amici's corporate cultures, are implemented and overseen by senior managers, and are supported at the highest levels. As a group, amici corporations pursue a variety of endeavors, including participating in numerous joint initiatives with the University of Michigan and other leading universities with strong academic programs and diverse student bodies, providing underrepresented minority students with substantial financial assistance and summer internship opportunities, recruiting and mentoring, extending financial grants, and partnering with university staff and chapters of national minority professional organizations.
3. If the University of Michigan is not able to consider all qualities of each applicant to the University, including his or her racial or ethnic background, the University will be hampered in its search for students with the most promise, and its graduates will be less likely to receive an education that gives them "wide exposure to the ideas and mores of students as diverse as this Nation of many peoples." Regents of the University of California v. Bakke, 438 U.S. 265, 313 (1978) (opinion of Powell, J.). The University's graduates will therefore be less likely to possess the skills, experience, and wisdom necessary to work with and serve the diverse populations of the United States and the global community. Graduates with such an education are important to the community as a whole, as well as to the amici corporations. Accordingly, amici seek to add their collective voices to that of General Motors Corporation in support of the University of Michigan.
4. In an effort to avoid burdening the Court with numerous individual briefs, amici worked together to file a joint brief. Substantial time was required to obtain and coordinate the input of all amici.
For the foregoing reasons, the motion for leave to file the accompanying brief as amici curiae and for leave to file out of time should be granted.
Jon D. Botsford
Senior Vice President, Secretary and
Chief Legal Officer
Steelcase Inc.
CH-4E
901 44th Street SE
Grand Rapids, MI 49508Dwight K. Hamilton
Corporate Counsel
Steelcase Inc.
CH-2E-06
901 44th Street SE
Grand Rapids, MI 49508Respectfully submitted,
__________________________
Randall E. Mehrberg
Jeffrey S. Silver
JENNER & BLOCK
One IBM Plaza
Chicago, IL 60611
(312) 222-9350Deanne E. Maynard
Shilpa S. Satoskar
Daniel Mach
JENNER & BLOCK
601 Thirteenth Street, N.W.
Washington, D.C. 20005
(202) 639-6000
Attorneys for Amici Curiae
Dated: October 16, 2000
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
________________________________ JENNIFER GRATZ, et al.,
Plaintiffs, v.
LEE BOLLINGER, et al.,
Defendants.
________________________________
)
)
) Civil Action No. 97-75231
)
) Hon. Patrick J. Duggan
) Hon. Thomas A. Carlson
)
)
)
)
)MOTION OF STEELCASE, INC., 3M, ABBOTT LABORATORIES, BANK ONE CORPORATION, E. I. DU PONT DE NEMOURS & CO., INC., THE DOW CHEMICAL COMPANY, EASTMAN KODAK COMPANY, ELI LILLY & COMPANY, GENERAL MILLS, INC., INTEL CORPORATION, JOHNSON & JOHNSON, KELLOGG COMPANY, KPMG INTERNATIONAL, LUCENT TECHNOLOGIES, INC., MICROSOFT CORPORATION, PPG INDUSTRIES, INC., THE PROCTER & GAMBLE COMPANY, SARA LEE CORPORATION, TEXACO INC., AND TRW INC. FOR LEAVE TO FILE BRIEF AS AMICI CURIAE IN SUPPORT OF DEFENDANTS AND FOR LEAVE TO FILE OUT OF TIME
Jon D. Botsford
Senior Vice President, Secretary and
Chief Legal Officer
Steelcase Inc.
CH-4E
901 44th Street SE
Grand Rapids, MI 49508
Dwight K. Hamilton
Corporate Counsel
Steelcase Inc.
CH-2E-06
901 44th Street SE
Grand Rapids, MI 49508
Attorneys for Amici CuriaeRandall E. Mehrberg
Jeffrey S. Silver
JENNER & BLOCK
One IBM Plaza
Chicago, IL 60611
(312) 222-9350
Deanne E. Maynard
Shilpa S. Satoskar
Daniel Mach
JENNER & BLOCK
601 Thirteenth Street, N.W.
Washington, D.C. 20005
(202) 639-6000Dated: October 16, 2000
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
________________________________ BARBARA GRUTTER, et al.,
Plaintiffs, v.
LEE BOLLINGER, et al.,
Defendants.
________________________________
)
)
) Civil Action No. 97-75928
)
) Hon. Bernard Friedman
) Hon. Virginia Morgan
)
)
)
)
)BRIEF OF STEELCASE, INC., 3M, BANK ONE CORPORATION, ABBOTT LABORATORIES, E. I. DU PONT DE NEMOURS & CO., INC., THE DOW CHEMICAL COMPANY, EASTMAN KODAK COMPANY, ELI LILLY & COMPANY, GENERAL MILLS, INC., INTEL CORPORATION, JOHNSON & JOHNSON, KELLOGG COMPANY, KPMG INTERNATIONAL, LUCENT TECHNOLOGIES, INC., MICROSOFT CORPORATION, PPG INDUSTRIES, INC., THE PROCTER & GAMBLE COMPANY, SARA LEE CORPORATION, TEXACO INC., AND TRW INC. AS AMICI CURIAE IN SUPPORT OF DEFENDANTS
Jon D. Botsford
Senior Vice President, Secretary and
Chief Legal Officer
Steelcase Inc.
CH-4E
901 44th Street SE
Grand Rapids, MI 49508
Dwight K. Hamilton
Corporate Counsel
Steelcase Inc.
CH-2E-06
901 44th Street SE
Grand Rapids, MI 49508
Attorneys for Amici CuriaeRandall E. Mehrberg
Jeffrey S. Silver
JENNER & BLOCK
One IBM Plaza
Chicago, IL 60611
(312) 222-9350
Deanne E. Maynard
Shilpa S. Satoskar
Daniel Mach
JENNER & BLOCK
601 Thirteenth Street, N.W.
Washington, D.C. 20005
(202) 639-6000Dated: October 16, 2000
INTEREST OF AMICI CURIAE
Amici Steelcase, Inc., 3M, Abbott Laboratories, Bank One Corporation, E. I. du Pont de Nemours & Co., Inc., The Dow Chemical Company, Eastman Kodak Company, Eli Lilly & Company, General Mills, Inc., Intel Corporation, Johnson & Johnson, Kellogg Company, KPMG International on behalf of its United States member firm, KPMG LLP, Lucent Technologies, Inc., Microsoft Corporation, PPG Industries, Inc., The Procter & Gamble Company, Sara Lee Corporation, Texaco Inc., and TRW Inc. are global corporations that recruit at the University of Michigan or similar leading institutions of higher education. Many of the amici have a substantial business presence in the state of Michigan, some are headquartered in Michigan, and all have ties to Michigan corporations and customers. Racial and ethnic diversity in institutions of higher education is vital to amici's efforts to hire and maintain a diverse workforce, and to employ individuals of all backgrounds who have been educated in a diverse environment. Such a talented workforce is important to amici's continued success in the global marketplace.
Amici corporations have devoted substantial financial and human resources to create and maintain such a workforce. These extensive efforts are part of the very fabric of amici's corporate cultures, are implemented and overseen by senior managers, and are supported at the highest levels. As a group, amici corporations pursue a variety of endeavors, including participating in numerous joint initiatives with the University of Michigan and other leading universities with strong academic programs and diverse student bodies, providing underrepresented minority students with substantial financial assistance and summer internship opportunities, recruiting and mentoring, extending financial grants, and partnering with university staff and chapters of national minority professional organizations. See Appendix (describing more fully the specific initiatives of some of the amici).
If the University of Michigan is not able to consider all qualities of each applicant to the University, including his or her racial or ethnic background, the University will be hampered in its search for students with the most promise, and its graduates will be less likely to receive an education that gives them "'wide exposure' to the ideas and mores of students as diverse as this Nation of many peoples." Regents of the University of California v. Bakke, 438 U.S. 265, 313 (1978) (opinion of Powell, J.). The University's graduates will therefore be less likely to possess the skills, experience, and wisdom necessary to work with and serve the diverse populations of the United States and the global community. Graduates with such an education are important to the community as a whole, as well as to the amici corporations. Accordingly, amici seek to add their collective voices to that of General Motors Corporation in support of the University of Michigan.
INTRODUCTION
Now more than ever, the ability of universities, such as the University of Michigan, to consider all of an applicant's attributes is essential to create the educational environment necessary to best train all their students to succeed. The students of today are this country's corporate and community leaders of the next half century. For these students to realize their potential as leaders, it is essential that they be educated in an environment where they are exposed to diverse ideas, perspectives, and interactions. In the experience of the amici corporations, today's global marketplace and the increasing diversity in the American population demand the cross-cultural experience and understanding gained from such an education. Diversity in higher education is therefore a compelling government interest not only because of its positive effects on the educational environment itself, but also because of the crucial role diversity in higher education plays in preparing students to be the community leaders this country needs in business, law, and all other pursuits that affect the public interest.1
1 Amici address here only the compelling nature of the University's interest and leave to the parties the discussion of the narrowly-tailored nature of the University's program.
ARGUMENT
THE PURSUIT OF DIVERSITY IN HIGHER EDUCATION IS A COMPELLING STATE INTEREST BECAUSE IT PREPARES ALL STUDENTS TO SUCCEED IN AND ENHANCE THE GLOBAL COMMUNITY.
"[T]he attainment of a diverse student body . . . clearly is a constitutionally permissible goal of an institution of higher education." Regents of the University of California v. Bakke, 438 U.S. 265, 311-12 (1978) (opinion of Powell, J.). As Justice Powell recognized in his controlling opinion in Bakke, a diverse student body promotes an atmosphere of "'speculation, experiment and creation'" that is "essential to the quality of higher education." Id. at 312 (quoting Sweezy v. New Hampshire, 354 U.S. 234, 263 (1957)). Moreover, by enriching students' education with a variety of perspectives, experiences, and ideas, a university with a diverse student body equips all of its students with the skills and understanding necessary to succeed in any profession. Id. at 314. Those skills include the ability to understand, learn from, and work and build consensus with individuals from different backgrounds and cultures. Statement on the Importance of Diversity in University Admissions, Association of American Universities (April 14, 1997) (Exhibit E to Memo. in Supp. of Defs.' Renewed Mot. for S.J. as to Pls.' Claim for Injunctive and Declaratory Relief (filed July 15, 2000)).
Diversity in higher education is therefore critical not only within the confines of the university itself, but also in preparing students to excel once they graduate. It is even more clear now than when Justice Powell wrote his opinion in Bakke that "the 'nation's future depends upon leaders trained through wide exposure' to the ideas and mores of students as diverse as this Nation of many peoples." Bakke, 438 U.S. at 313 (quoting Keyishian v. Board of Regents, 385 U.S. 589, 603 (1967)). The population of the United States is increasingly defined by its diversity. In 1999, African Americans, Native Americans, Asian Americans, and Hispanics made up 28 percent of the population of the United States. See Population Estimates Program, Population Div., U.S. Census Bureau, Population Estimates for States by Race and Hispanic Origin: July 1, 1999 (rel. Aug. 30, 2000), available at http://www.census.gov/population/ estimates/state/srh/srh99.txt.2 By one estimate, these groups will constitute almost half � 47 percent � of the United States' population by the year 2050. Jon Meacham, The New Face of Race, Newsweek, Sept. 18, 2000, at 40. The rich variety of ideas, perspectives, and experiences to which both non-minority and minority students are exposed, and the cross-cultural interactions they experience in a diverse university setting, are essential to the students' ability to function in and contribute to this increasingly diverse community.
2 In contrast, two years after the Bakke opinion was issued, the 1980 census showed that African Americans, Native Americans, Asian Americans and Hispanics constituted 20 per cent of the nation's population. See Population Estimates Program, Population Division, U.S. Census Bureau, U.S. Population Estimates by Age, Sex, Race, and Hispanic Origin: 1980 t0 1999, (rel. April 11, 2000), available at http://www.census.gov/population/estimates/nation/natdoc.txt.
The experiences of the amici corporations demonstrate the need for the cross-cultural education that a diverse educational institution provides, as well as the talented diverse graduates it produces. The changing face of America is reflected in the marketplace, as both the workplace and the purchasers of products and services become increasingly diverse. For example, the combined spending power of racial minorities in the United States is $600 billion annually. (Expert Report of William G. Bowen at 14 (Dec. 9, 1998)). The individuals who run and staff the amici corporations must be able to understand, learn from, collaborate with, and design products and services for clientele and associates from diverse racial, ethnic, and cultural backgrounds. American multinational corporations, including amici, are especially attuned to this concern because they serve not only the increasingly diverse population of the United States, but racially and ethnically diverse populations around the world.
In the opinion of amici, individuals who have been educated in a diverse setting are more likely to succeed, because they can make valuable contributions to the workforce in several important ways. First, a diverse group of individuals educated in a cross-cultural environment has the ability to facilitate unique and creative approaches to problem-solving arising from the integration of different perspectives. Second, such individuals are better able to develop products and services that appeal to a variety of consumers and to market offerings in ways that appeal to these consumers. Third, a racially diverse group of managers with cross-cultural experience is better able to work with business partners, employees, and clientele in the United States and around the world. Fourth, individuals that have been educated in a diverse setting are likely to contribute to a positive work environment, by decreasing incidents of discrimination and stereotyping. Finally, an educational environment created by consideration of the potential promise of each applicant in light of his or her experiences and background is likely to produce the most talented possible workforce.
Accordingly, if the University of Michigan and other top institutions are not permitted to pursue excellence in education by creating a diverse educational environment, their graduates also will likely be constrained in their pursuit of excellence. The experiences of amici, the demographic changes in the United States, and the increasing globalization that has occurred in the twenty-two years since Justice Powell wrote his controlling opinion in Bakke confirm his binding holding that the pursuit of diversity in higher education is a compelling state interest. The reasons given by Justice Powell are just as valid today, if not more so. Institutions of higher learning must be allowed to prepare students to thrive in an increasingly diverse environment. The best way to do this is to ensure that students learn in an environment of diversity, including racial and cultural diversity. Students from diverse backgrounds bring to school "experiences, outlooks, and ideas that enrich the training of the student body and better equip its graduates to render with understanding their vital service to humanity." Bakke, 438 U.S. at 314. Accordingly, institutions of higher learning should be able to use "competitive consideration of race and ethnic origin" in pursuit of a diverse student body. Id. at 320 (opinion of Powell, J., joined by Brennan, White, Marshall, and Blackmun, JJ.).
CONCLUSION
For the foregoing reasons, this Court should find that the pursuit of diversity in higher education is a compelling state interest.
Jon D. Botsford
Senior Vice President, Secretary and
Chief Legal Officer
Steelcase Inc.
CH-4E
901 44th Street SE
Grand Rapids, MI 49508Dwight K. Hamilton
Corporate Counsel
Steelcase Inc.
CH-2E-06
901 44th Street SE
Grand Rapids, MI 49508Respectfully submitted,
__________________________
Randall E. Mehrberg
Jeffrey S. Silver
JENNER & BLOCK
One IBM Plaza
Chicago, IL 60611
(312) 222-9350Deanne E. Maynard
Shilpa S. Satoskar
Daniel Mach
JENNER & BLOCK
601 Thirteenth Street, N.W.
Washington, D.C. 20005
(202) 639-6000
Attorneys for Amici Curiae
Dated: October 16, 2000
APPENDIX: INDIVIDUAL STATEMENTS OF INTEREST OF AMICI 3M, STEELCASE, INC., KELLOGG COMPANY, THE PROCTER & GAMBLE COMPANY, TEXACO, INC., AND TRW INC.
3M
3M is a $16 billion diversified manufacturing and technology company with operations in more than 60 countries and customers in nearly 200 countries. Headquartered in St. Paul, Minnesota, 3M makes a wide variety of products serving customers in dozens of markets, including industrial, electronic, automotive, telecommunications, health care, transportation safety, consumer and office. 3M maintains manufacturing and sales facilities in Michigan, and has extensive ties with Michigan's auto industry. 3M is a truly global corporation, with more than 50 percent of its revenues coming from outside the United States.
Because it serves and works with an increasingly diverse group of communities in both the United States and around the world, 3M's future hinges upon its ability to attract, deploy, and maintain a diverse workforce capable of understanding, relating to, and satisfying the needs of its broad customer base. 3M invests heavily in research and development and is known widely as one of America's most innovative companies. As such, 3M has found that bringing together the collective talents and experiences of a diverse group of employees is necessary to develop creative approaches to problem_solving, and to successfully market and sell its products to a wide range of communities. Time after time, 3M has found that input from employees who are members of the communities to which 3M markets and sells its products is crucial to ensuring that it can reach those communities in the most effective way.
3M dedicates extraordinary amounts of time and resources to increasing its diversity. The company has long relied on a highly structured program to recruit, hire and train engineers from underrepresented racial groups, and employs a Staffing Manager who oversees the various efforts the company makes to attain a diverse workforce.
3M works with universities across the country to recruit African American, Hispanic and Native American engineering students for summer internships and regular employment with the company. It targets certain "key schools," including the University of Michigan, because of those schools' strong engineering programs and their diverse student bodies. Each of these schools is partnered with a College Relations Team from 3M. The College Relations Team works closely with the university staff and the university chapters of national minority engineer organizations, such as the National Society of Black Engineers, the Society of Hispanic Professional Engineers, and the American Indian Science and Engineering Society, to identify qualified students from underrepresented minority groups. The College Relations Teams also present workshops, attend career fairs, and interview on campus in an effort to attract qualified minority candidates for full time positions and summer internships.
3M bolsters its commitment to diversity with considerable financial support. Through its Minority Engineering Scholarship Program, 3M funds scholarships at nine top universities, including the University of Michigan, for promising engineering students from underrepresented minority groups. The program provides funding for both undergraduate and graduate programs, and also offers students the opportunity to work for 3M the summers after their freshman, sophomore and junior years in college. Once a student makes it through the coursework and internships in good standing, he or she is offered regular employment with the company. Since the Minority Engineering Scholarship Program started in fall of 1986, 3M has provided University of Michigan minority students with $375,000 in scholarship money, in addition to wages for summer employment. In a similar vein, 3M has made significant grant contributions to the University of Michigan in recognition of the University's commitment to diversity.
3M's efforts are a central component of its corporate mission and its vision for the future. Since 1986, 3M has provided summer internships for 33 minority students in the Minority Engineering Scholarship Program from the University of Michigan alone. As of August 31, 2000, the company had hired over 30 African American, Hispanic, or Native American engineers for regular positions this year. In addition, approximately 25-30 percent of 3M's interns each year are African American, Hispanic, or Native American students.
STEELCASE INC.
Steelcase Inc., which is headquartered in Grand Rapids, Michigan, is the world's preeminent designer and manufacturer of products used to create high-performance work environments. Steelcase's products include office furniture, systems furniture, computer support furniture, office and lounge seating, desks, filing and storage cabinets, and task lighting and accessories. Its fiscal 1999 worldwide consolidated sales were in excess of $3 billion. Steelcase is a global corporation that serves every country in the world through independently-owned dealers and with more than twenty-six manufacturing facilities in foreign countries. The company, its subsidiaries and joint ventures employ over 20,000 people worldwide.
Steelcase places a high value on attracting and maintaining a diverse workforce, which it believes is critical to maintain its competitive position in the global marketplace. Because Steelcase markets and sells its products to an increasingly diverse set of communities in the United States and around the world, it recognizes that it must have a diverse group of employees with backgrounds reflecting a variety of demographic groups and with experience interacting with individuals from cultures other than their own. Steelcase also believes that having a diverse group of employees who bring to the table different perspectives, ideas and approaches to problem-solving is the best way to increase creativity and productivity within the company.
For these reasons, Steelcase, through its Diversity Work Team, is dedicated to increasing and maintaining diversity at the company. Steelcase recruits talented minority candidates from top universities including the University of Michigan, which is one of Steelcase's primary schools for recruiting undergraduate business students, engineering students and MBA candidates. In order to reach out to minority students at the University, Steelcase attends career fairs on campus and works directly with the University to identify strong minority candidates.
Steelcase utilizes two specific programs to provide employment experience for minority college students. First, more than ten years ago, Steelcase developed the Cooperative Education Program, which provides engineering students the opportunity to augment their education by working at Steelcase. The Cooperative Education Program targets educational institutions, such as the University of Michigan, with a diverse population of engineering students. This year, 37 percent of the program's participants were from minority groups.
Second, Steelcase provided startup funding to bring to Grand Rapids, Michigan the national INROADS program, which is dedicated to increasing employment opportunities for minorities. Steelcase avidly supports the INROADS program and its senior management is represented on the INROADS Board of Directors. This year, Steelcase offered nineteen summer internships to minority college students through the INROADS program.
Steelcase also targets younger students in its efforts to increase diversity at the company. For example, through the Grand Rapids Area Pre-College Engineering Program, Steelcase focuses on identifying, supporting and educating economically disadvantaged minority and majority elementary and high school children through in-school and worksite programs designed to encourage them to explore the field of engineering.
Steelcase's commitment to diversity is evident at the highest levels of the corporation. The senior management meets quarterly to discuss and review the status of the company's various diversity initiatives, and the individual with primary oversight of those initiatives reports on his efforts directly to the CEO. The quest to attain and celebrate diversity within the company has long been part of the corporate culture at Steelcase.
KELLOGG COMPANY
For nearly 95 years, Kellogg Company has been a major employer in western Michigan and other communities throughout the world. With sales of nearly $7 billion, Kellogg Company is the world's leading producer of ready-to-eat cereal and a leading producer of convenience foods, including toaster pastries, cereal bars, frozen waffles, and meat alternatives. The Company's brands include Kellogg's�, Special K�, Rice Krispies�, Eggo�, Pop-Tarts�, Nutri-Grain�, and Morningstar Farms� and Kashi�. Kellogg icons such as Tony the Tiger� and Snap!� Crackle!� Pop!� are among the most recognized characters in advertising. Kellogg products are manufactured in 20 countries and marketed in more than 160 countries around the world.
We have great brands, a proud history, and an exceptional line-up of products. And all have been made possible by Kellogg people. Indeed, the strength of our organization is the people who plan, research, market, invent, produce, and perform here each day. Tapping the unique skills, ideas, and perspectives of those people � relying on that diversity to inspire the innovations that drive our business � will continue to be our source of competitive advantage.
Kellogg Company believes diversity is a rich, vital ingredient in our formula for success. Our diversity has a significant, positive impact on the lives of our employees, customers, and bottom line. Several national organizations have recognized the company's commitment to diversity.
Kellogg is keenly interested in diversity opportunities in the global marketplace. At all levels of the organization, we actively recruit and develop diverse candidates from around the world, including but not limited to women, people of color, and people from different geographic regions, to ensure that all consumers have a voice in product development, marketing, and business strategies. We look to our local educational institutions as a pipeline for diverse talent in our recruiting efforts.
Kellogg Company actively recruits talented University of Michigan students, including minority undergraduate and graduate candidates specifically in the areas of finance and marketing. Senior Kellogg management maintains a presence and connection to the University and regularly participates in speaking engagements and visits college classrooms. Carlos Gutierrez, Chairman, President and CEO, is a member of the Visiting Executive Committee at The University of Michigan Business School. Kellogg Company is also a significant contributor and program participant of the University's Consortium for the Graduate Study in Management, which provides graduate fellowships for talented minorities and assists Kellogg Company in identifying minority candidates. Additionally, Kellogg Company has board member presence on and is a sponsor of the INROADS/Southwest Michigan Program, which gives students summer employment opportunities leading to permanent full-time employment upon graduation. Last summer, Kellogg Company placed six interns in the areas of human resources, global procurement, IT, sales, marketing, and finance.
At Kellogg, we keep diversity top-of-mind throughout the year. We do so by building a culture in which each person, in each Kellogg facility, takes personal ownership of diversity. Individually and collectively, our employees are seizing the opportunities our differences represent. We have assembled Diversity Leadership Teams (DLTs) at the corporate level as well as at our plants and within our sales team. These DLTs lead the charge by developing strategies, tearing down barriers, and crossing organizational boundaries to ensure positive changes. We continually invest in our people, providing them with mentoring opportunities, an ongoing feedback mechanism, and personal development programs through our on-site Learning Center. At Kellogg Company, we see diversity as a valuable fact of life. We embrace, encourage, and nurture it, not because it looks good to do so, but because it is good. It is good for every one of us. To drive our business success, we rely upon the continued availability of talented students with diverse backgrounds at our local educational institutions.
THE PROCTER & GAMBLE COMPANY
From its global headquarters in Cincinnati, Ohio, Procter & Gamble ("P & G") enjoys unrivaled access to and understanding of the world's consumers: their needs and wants, their attitudes and behaviors, their habits and practices. This year, 2.5 billion people will purchase a branded P&G product somewhere in the world, yielding more than $40 billion in sales.1 To accomplish this, P&G employs approximately 40,000 people in the U.S. and a global total exceeding 100,000 individuals in 75 countries whose singular focus is to provide products of superior quality and value that improve the lives of the world's consumers.
There is no question in the minds of Procter & Gamble's leadership that its diverse workforce has been key to the achievements of this Fortune 25 company. "Our success as a global company is a direct result of our diverse and talented work force. Our ability to develop new consumer insights and ideas and to execute in a superior way across the world is the best possible testimony to the power of diversity any organization could ever have," P&G's Chairman of the Board John E. Pepper asserted years ago.
On October 11, 2000, A. G. Lafley, CEO of Procter & Gamble, wrote to the Company's global workforce, "Diversity is also a fundamental business strategy. � [O]ur success depends entirely on our ability to understand these diverse consumers' needs and to work effectively with customers and suppliers around the world. All the data I've seen in 30 years of being in business - and all of my personal experience at P&G over the last 23 years - convince me that a diverse organization will out-think, out-innovate, and out-perform a homogenous organization every single time."
A promote-from-within employer, Procter & Gamble invests heavily in recruiting new employees into all areas of the Company's complex businesses each year to sustain its talent pipeline. Last year in the U.S., P&G hired approximately 3275 individuals, of whom 36.5 percent are minorities, which is fairly typical of the diversity of its recruiting for many years. As a result of its efforts to recruit and develop a diverse workforce, Procter & Gamble has been recognized for its achievements by the U.S. Secretary of Labor's Opportunity 2000 Award in 1994, the Martin Luther King, Jr. Foundation's Salute to Greatness Award in 1995, the NAACP Legal Defense and Educational Fund's Corporate Affirmative Action Award in 1996, the National Urban League's Donald H. McGannon Award in 1998, and numerous other awards and statements of recognition by other organizations and publications.
Because P&G is a major employer in the Midwest with seven research and development centers, four manufacturing plants, and its global headquarters all in Ohio, the Company has historically relied upon nearby universities of superior academic training, such as the University of Michigan, as a key source of new employees. The University of Michigan consistently ranks among P&G's top 20 schools for the number of recruits the Company annually hires from college campuses, and for the last four years, Michigan has been among the top five schools for African-American new hires. Currently, nearly 300 U of M alumni work at Procter & Gamble.
Procter & Gamble continues to invest heavily in the University of Michigan as a valued and ongoing source of new talent needed by the Company to further grow its global business. The Company has been donating more than $200,000.00 annually to the University of Michigan to support its academic programs, and each year sends numerous P&G managers to Ann Arbor to help educate students about marketing, technical and related careers. As customers of the students which the University of Michigan educates, Procter & Gamble strongly encourages the University of Michigan to continue to recruit and educate a diverse student body.
TEXACO INC.
Texaco Inc., a Delaware Corporation, which is headquartered in White Plains, New York, is a major international integrated energy company. Texaco is principally engaged in the worldwide exploration for and production, transportation, refining and marketing of crude oil, natural gas liquids, natural gas and petroleum, power generation and gasification. Through its owned and affiliated companies, the company conducts business in some 150 countries and territories and employs over 18,000 employees worldwide.
In view of the increasingly diverse base of operations, employees, and customers in both the United States and globally, Texaco holds respect for the individual as one of its fundamental values. A key corporate strategy is to develop a world-class workforce. Texaco continually strives to: attract the best and brightest; create an environment where change is embraced and challenge accepted; inspire all employees to recognize their worth and the worth of others; and develop a highly competent, deep, and diverse leadership talent pool.
Texaco is committed to developing a diverse workforce and has dedicated significant time and resources to creating an environment that fosters diversity. In the ever-increasing global economy it is vital to recognize that people are our most valuable resource. Our hiring and promotion activities continue to yield a rich and diverse talent pool.
Texaco recruits at universities across the country to hire top quality students for internships and regular employment upon graduation. The company has adopted a "dynamic" college recruiting program that targets a number of colleges and universities as "core" schools. These schools provide talented, diverse groups of highly qualified students from which to recruit. The University of Michigan is one of these "core" schools.
TRW Inc.
TRW is a global technology, manufacturing, and service company serving the automotive, aerospace, defense, and information systems markets. It has sales of $18 billion, with 110,000 employees in over 30 countries. Headquartered in Cleveland, Ohio, TRW was founded in 1901 and will be celebrating its 100th anniversary in 2001.
Diversity has been a key strategic priority at TRW for many years. TRW's businesses, markets, customers, competitors, employees, and potential employees are becoming increasingly global and diverse. Global demographics suggest that the war for talent will continue to make competition for the best people a major issue for years to come. TRW, therefore, believes it makes good business sense for its people and business practices to reflect diversity as well. TRW has a number of practices in place to foster a more diverse world-class workforce and a more inclusive work environment. Our approach on diversity is rather focused � to make TRW "where the best people want to work."
Over the years, TRW has used Diversity Advisory Committees to provide insight and guidance regarding diversity-related issues. TRW uses a variety of training and communications tools to equip managers and employees to deal with diversity. It also uses employee opinion surveys, skip-level sensing sessions, and other "listening devices" to ensure employee voices � and diverse points of view � are heard.
TRW has been a leader in implementation of progressive Human Resources practices to promote diversity in the workplace. Examples include flexible work hours, flexible time off, child care facilities, and telecommuting to accommodate the need for balance between work and personal lives. TRW has been recognized externally for such efforts, including being named by Working Mothers magazine as one of the 100 best companies for working mothers, five of the last seven years. TRW also participates in a number of highly effective external and community outreach programs such as INROADS for development of high potential minorities, and many others.
In the area of university relations and recruiting, TRW has a long-standing commitment to hiring a diverse population of students. Through its Management Associates Program (MAP), TRW hires 10-15 graduate students per year in disciplines including Manufacturing, Finance, and Human Resources. The MAP is a highly selective, two-year rotational development program designed to develop participants to achieve senior level executive positions in TRW. Because the MAP serves as one important pipeline for senior level talent, TRW pays significant attention to the attraction of qualified female and minority applicants for the MAP. Universities, including the University of Michigan, represent a critical source of high quality, diverse talent for high potential programs such as MAP.
Likewise, at the undergraduate level, TRW has relationships with schools like the University of Michigan, Southern University, and over 100 other universities worldwide, for critical skills in engineering, manufacturing, sales and marketing, purchasing, finance, human resources, and many other disciplines. TRW hires hundreds of undergraduates each year, including many women, minorities, and representatives of diverse countries and cultures.
The admissions practices, which ensure a diverse population of students at the University of Michigan and other schools, therefore, serve as a critical link in the diversity value chain. TRW depends on a steady flow of highly qualified, diverse talent from universities to fuel its growth, performance, and global competitiveness.
MICROSOFT CORPORATION
Microsoft Corporation, a Washington corporation with its headquarters in Redmond, Washington, is one of the world's leading computer software companies. Like other technology companies, Microsoft Corporation overall is experiencing a shortage of available workers and expends substantial resources in its efforts to recruit qualified employees. Attracting minorities and women is even more challenging due to the relatively small number of women and people of color who are choosing to enroll in scientific and technical academic programs. Microsoft Corporation is committed to increasing the number of minorities in its workforce. To accomplish that objective, it is critical to Microsoft's interests that the number of minorities in technical degree programs be expanded rather than reduced.
Legal Documents Table of Contents