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Private Equity & Ventures
Q2 2025 Engagement Case Study: DEI
Topic: Diversity, Equity & Inclusion
WHEB’s Objective: Supporting high quality management extends the company’s overall positive impact and long-term success.
Company Objective: To understand decision to remove gender diversity target for North American business segment.
Desired Outcome: We believe that better DEI practices can lead to higher quality management and therefore better decision-making.
Background: Diversity, Equity, and Inclusion (“DEI”), has become a politicised symbol of partisan battles, overshadowing its core purpose of strengthening both organisations and broader society. In the US especially, actions taken by President Trump1 are forcing companies to retreat on DEI commitments. For example, Novo Nordisk is amongst 2002 of the largest corporates to have recently dropped senior management gender diversity targets in the US3.
Activity: We contacted Novo Nordisk’s Investor Relations team to better understand the decision to drop gender targets in the US, particularly as this would contradict the core values of the Novo Foundation.
Outcome: Milestone 2 – Company shares or agrees to disclose on the issue
Novo Nordisk explained that its decision to remove gender diversity targets for its North American business was driven by evolving legal risks. Specifically, recent U.S. government investigations into DEI practices, initially focused on federal agencies and now extending to the private sector, have raised concerns about compliance with federal regulations. These investigations could potentially jeopardize the company’s eligibility to participate in Medicare and Medicaid programs, which account for over 20% of its U.S. business.
Despite this change, Novo Nordisk remains majority-owned by the Novo Foundation, which maintains strong ESG commitments. The company continues to uphold its DEI initiatives outside the U.S., aligning with the Foundation’s values.
As shareholders, we recognise the importance of protecting the company’s operational resilience and access to critical markets. While the rollback of DEI targets in the U.S. is concerning, we acknowledge the complex regulatory environment and the potential financial risks involved. We will continue to engage with Novo Nordisk to encourage alignment with long-term sustainability goals while navigating these challenges.
1 https://www.whitehouse.gov/presidential-actions/2025/01/ending-illegal-discrimination-and-restoring-merit-based-opportunity/
2 https://www.reuters.com/sustainability/society-equity/drugmaker-novo-nordisk-drops-gender-representation-requirements-us-2025-05-07/
3 https://www.ft.com/content/c2320415-dcf6-4b69-acd4-3187507d762c