The workforce data quest: Why we need it and why it helps companies as well

  • Workforce disclosure is essential for investors to better analyze companies’ social performance
  • Companies’ workforce disclosure is still limited, often referencing data gaps or lack of appropriate data gathering systems
  • BMO Global Asset Management encourages companies to respond to the Workforce Disclosure Initiative (WDI) annual survey to underline accountability to their social commitments
  • In 2019, we engaged 77 companies on workforce disclosure and their WDI submission; 17 of those have completed the survey

Why is better workforce data disclosure important?

For most companies, their workers are the biggest asset. Investors are keen to understand how companies treat their employees. Poor treatment can become a competitive disadvantage if workers underperform, leave for other employers, or file lawsuits. Conversely, good workforce management can support higher retention rates and enhanced customer satisfaction.

We at BMO Global Asset Management, alongside many other investors, are frustrated at the current stage of workforce data. A lack of detail and consistency makes it difficult and time-intensive to assess companies and compare them with their peers, leading to inconclusive assessments. At the same time, companies often tell us they are unclear what type of disclosures investors want, and have to spend time dealing with ad hoc queries.

This mismatch between the materiality of workforce issues and the ability of investors to assess them was the driver behind our commitment to a collaborative engagement with the Workforce Disclosure Initiative.

What is the WDI?

The Workforce Disclosure Initiative (WDI) is a project run by UK-based NGO ShareAction that aims at improving data from listed companies on how they manage workers in their direct operations and supply chains. Launched in 2017, the WDI brings together over 130 investors with around US $15 trillion AUM, to call on companies to complete an annual survey giving disclosure on their workforce practices.

The WDI is unique in its breadth and depth. It also aligns with many other reporting standards, including the Global Reporting Initiative, Ethical Trading Initiative and the Corporate Human Rights Benchmark.

The survey includes more than 200 questions on companies’ governance of workforce issues for their own operations and supply chain. Questions cover issues including human rights, diversity, pay ratios to overall wage levels, turnover rates, training, occupational health and safety, freedom of association, whistleblowing, structure of the company’s supply chain, as well as sourcing procedures.

While the survey appears daunting in length, mandatory public responses across all themes are limited to 28 questions: companies can choose to submit all other responses solely to investor signatories and the WDI team. Going through the process of completing the survey can also, investors hope, be beneficial for companies, as the gaps identified can be the first step towards more comprehensive future data collection and policies.

Response rates to the WDI are still comparably low in comparison to the investment universe or similar environmental initiatives, but numbers are increasing year after year.

Our WDI-related engagement

BMO Global Asset Management has been a signatory of the WDI since its inception around three years ago. We reinforced our commitment at the beginning of 2019, becoming a member of WDI’s Advocate Group. This group assembles a set of 20 investors that collaboratively engage a subset of companies for enhanced disclosure.

In 2019, BMO Global Asset Management’s Responsible Investment team reached out to 77 companies to encourage them to respond to the WDI, often in the context of wider engagement on other labour-related issues such as diversity and living wages. In some cases, this led to a dialogue on the reasons for our WDI support, as well as feedback from companies on the challenges they face in responding.

Among those challenges were:

  • a lack of data, meaning a company could only make a partial completion;
  • fear of being retaliated against for partial disclosure with a public low score;
  • an overall lack of resources, particularly given the length of the survey; and
  • other reports being higher on their priority list.


The challenges are real, though their weighting in deciding for or against a WDI submission needs to be evaluated.

While WDI scorecards show a percentage relating to the share of disclosed information, these scorecards are not made public. Our own interest in the scores is limited, and we would welcome even partial disclosure for our assessments.

Limited resources are of course an all-time challenge. As the survey builds on existing reporting standards, with the ‘social’ element of sustainability gaining more traction and with the level of investor support the WDI experiences, companies should consider re-prioritizing. In addition, in 2019 the WDI has also offered participating companies to pre-populate its survey based on publicly available data.

Of the 77 companies we engaged, 10 had replied to the WDI survey in 2018. In 2019, of the companies we reached out to, 17 have submitted their responses to the WDI.

The 2019 evaluation of the quality of responses is ongoing and will be published by the WDI in the first quarter of 2020.


Response rates to the WDI are still low in comparison to the investment universe or similar environmental initiatives, but numbers are increasing year after year.

However, despite widespread investor support for the WDI, social issues have yet to reach the prominence that environmental issues currently have, both with investors and companies. We believe this needs to change, for the sake of companies ensuring business continuity, for workers’ rights to be protected, for investors to see appropriate – and ultimately successful – human capital management approaches in the companies they invest in.

Corporates do acknowledge partial lack of data or internal data systems that can reflect their global operations and workforce. Nonetheless, for addressing workforce issues holistically and with a united investor response, as well as for the WDI to become “the CDP of social issues”, we need more companies to disclose. We will continue our engagement with those that have submitted and encourage their continuous commitment, as well as with those who haven’t yet, underlining the need for enhanced workforce disclosure.

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Views and opinions have been arrived at by BMO Global Asset Management and should not be considered to be a recommendation or solicitation to buy or sell any companies that may be mentioned. Past performance should not be seen as an indication of future performance. The value of investments and income derived from them can go down as well as up as a result of market or currency movements and investors may not get back the original amount invested. The information, opinions, estimates or forecasts contained in this document were obtained from sources reasonably believed to be reliable and are subject to change at any time.

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