Wells Fargo's DEI Employment Practices: What the Company's Own Documents Show — and What They Mean for Employees

Published August 22, 2026 · Last updated August 22, 2026 · By Fett Law — Michigan Employment Discrimination Attorneys

Wells Fargo & Company documented demographic employment practices in its own annual Diversity, Equity, and Inclusion Reports, proxy statements, and a commissioned racial equity assessment between 2019 and 2024 — including executive compensation tied to progress on racial, ethnic, and gender representation, a stated expectation of a 50% diverse candidate slate and a diverse interviewer on first-round interview panels, representation goals set for Operating Committee members and other leaders, and development programs built around race or sex. Wells Fargo eliminated the diverse-slate policy in February 2025 and deleted its DEI web pages and reports in May 2025. Similar practices were the basis of IBM's $17 million False Claims Act settlement with the U.S. Department of Justice in April 2026.

Key facts

Did Wells Fargo tie executive pay to diversity targets?

The clearest statement came from Wells Fargo itself in September 2020:

"Operating Committee members will be evaluated based upon their progress in improving diverse representation and inclusion in their area of responsibility. These evaluations will have a direct impact on year-end compensation decisions."Wells Fargo & Company, "CEO Charlie Scharf Reinforces Commitment to Diversity and Inclusion," September 23, 2020 (source)

Wells Fargo then disclosed the linkage to the Securities and Exchange Commission. Its 2021 proxy statement told shareholders that the executive performance framework, "[b]eginning for 2020, takes into account progress against diversity initiatives," and that "[p]rogress in these areas was evaluated and taken into consideration by the Board and the Human Resources Committee as part of year-end compensation decisions." The 2022 proxy went further, reporting that Wells Fargo had "[i]ncorporated the consideration of progress relating to DE&I initiatives into performance goals for our executives that are taken into consideration in connection with year-end compensation decisions." In a spring 2022 investor presentation filed with the SEC, the company stated plainly that it had "linked DE&I outcomes to compensation."

The most operationally specific description appears in Wells Fargo's own second annual DE&I Report, published in June 2023:

"We developed DE&I goals, which are informed by affirmative action and equal employment opportunity principles, for our Operating Committee members and other leaders to measure our progress in increasing gender, racial, and ethnic representation in our areas of business. Performance against these goals is factored into their performance evaluation and compensation."Wells Fargo & Company, 2023 Diversity, Equity, and Inclusion Report, June 2023, p. 10, "Improving diverse leadership" (report deleted from wellsfargo.com in May 2025)

The final edition, published August 15, 2024, repeated the same mechanism in shorter form:

"We want our employees and leadership to reflect the communities where we live and work. Our Operating Committee and other senior leaders support this goal through coaching, mentoring, and embedding DE&I into our business practices and work in the community, and their performance against this is factored into their performance evaluation and compensation."Wells Fargo & Company, 2024 Diversity, Equity, and Inclusion Report, published August 2024, p. 11, "Creating opportunities for leaders" (report deleted from wellsfargo.com in May 2025)

In plain terms: for roughly five years, the executives who oversaw hiring, promotion, and staffing decisions at Wells Fargo had part of their own pay outcome tied to whether the racial, ethnic, and gender composition of their business unit moved in a particular direction. When a leader's compensation depends on a demographic number, employees and applicants have a direct interest in how that pressure reached individual decisions.

Did Wells Fargo require diverse slates in hiring and promotion?

Wells Fargo announced the requirement in September 2020, describing it as "requiring diverse candidate slates for key roles with compensation of more than $100,000." The public formulation the company used — and the one later placed at the center of shareholder litigation — was that "[i]n the U.S., we are requiring a diverse slate of candidates – and a diverse interview team – for most roles with total direct compensation of more than $100,000 per year."

Wells Fargo's own DE&I Report restated the operative rule after the 2022 revision:

"For most senior posted U.S.-based professional and manager job levels, Wells Fargo expects a 50% diverse candidate slate and diverse interviewer on interview panels in first-round interviews."Wells Fargo & Company, 2023 Diversity, Equity, and Inclusion Report, June 2023, p. 13, "Diverse candidate slate and interview teams" (report deleted from wellsfargo.com in May 2025)

The independent racial equity assessment Wells Fargo commissioned from Covington & Burling LLP, published in December 2023, described the mechanics in more detail. A "diverse pool" required at least half of first-round candidates to self-identify as underrepresented on any of six characteristics — race or ethnicity, gender, disability status, veteran status, sexual orientation, or gender identity — and a "diverse interview team" required at least one underrepresented interviewer. A hiring manager who did not produce a diverse slate had to document a rationale, which the recruiter and the next-level manager reviewed, and compliance was reported quarterly by line of business. Training on the guidelines was mandatory for all hiring managers beginning in August 2022.

The assessment also recorded a finding Wells Fargo's own assessor thought worth flagging: because the definition spanned six characteristics, a slate could satisfy the guidelines even if no candidate on it was racially or ethnically diverse — a slate composed entirely of white women, or of white male veterans, would qualify.

Alongside the slate policy, Wells Fargo described a parallel internal process for advancement: "In 2021, we developed an internal process for identifying and elevating our talent from underrepresented backgrounds to proactively build a diverse workforce" (2023 DE&I Report, p. 13, "Diversity-focused talent review"). The 2022 edition described that review as a twice-yearly, cross-business review of the diverse pipeline for U.S. roles paying $100,000 or more.

The policy did not survive intact. In June 2022, after The New York Times reported that Wells Fargo had conducted interviews with minority and female candidates for jobs that were already filled, Wells Fargo announced it had "temporarily paused the use of its diverse slate guidelines" pending a review. It restarted the guidelines on August 1, 2022, saying it would "[c]ontinue to expect a 50% diverse candidate slate and a diverse interviewer panel" but would "[r]edefine roles that are in-scope for the guidelines based on job level, not compensation." On February 26, 2025, Bloomberg Law reported that Wells Fargo had discontinued the policy entirely and removed diverse-slate training from its hiring process. The August 2024 DE&I Report — the last edition Wells Fargo published — contains no description of the slate guidelines at all.

What a slate rule means for an individual is concrete: a hiring manager who wants to move a requisition forward must first assemble a first-round panel with the right demographic mix, or write a justification that goes to two levels of review. Employees and applicants who were interviewed, screened, or passed over during those years — and the recruiters and managers who ran the process — are the people who know how that requirement actually operated.

Did Wells Fargo set racial or gender representation goals?

The goal architecture is documented in three places. First, the company's own DE&I Report language quoted above, which ties leader-level representation goals directly to performance evaluation and compensation. Second, Wells Fargo's SEC filings: the FY2022 Form 10-K stated a "goal to increase diverse representation in leadership roles," and the human capital sections of the FY2020–FY2023 10-Ks reported representation figures against that objective. Third, the June 2020 public commitment reported by Banking Dive: Scharf set a goal to double the number of Black leaders within five years, at a point when Black employees made up about 6% of senior management, and Wells Fargo said that Operating Committee members' "efforts to increase representation and inclusion of diverse employees at the bank will be reflected in their year-end pay packages."

Wells Fargo also published the numbers those goals were measured against. Its 2022 DE&I Report reported that "diverse executive representation" — managers one to three levels below the CEO earning $100,000 or more — rose from 41.7% in December 2020 to 44.3% in December 2021, and that diverse external executive hires rose from 38.2% to 42.2% over the same period. The December 2023 racial equity assessment recorded that racial and ethnic diversity on the Operating Committee, excluding the CEO, moved from 0 of 13 members (0%) at the end of 2019 to 4 of 15 (26.7%) as of September 30, 2023.

A goal expressed as a percentage that must rise, assigned to a named leader, and attached to that leader's pay is a target somebody is accountable for hitting. The published documents establish the target and the accountability; what they do not describe is how the accountability translated into any particular hiring, promotion, or transfer decision. That is knowledge held by people who were inside the process.

Did Wells Fargo run programs restricted by race or sex?

The most explicitly demographic design was the Diverse Leaders Program, described in published materials as offering "several different tracks, including Asian and Pacific Islander, Black/African American, Latino, and Lesbian/Gay/Bisexual/Transgender Leaders programs," each a "transformational three-day 'deep dive' leadership experience designed specifically to develop high-potential talent." The original hosting page for that description has since been redirected away.

Wells Fargo's own reports describe the internal advancement programs and the demographic composition of who got into them:

"We created the Building Diverse Pathways program to increase the diversity of the Wells Fargo financial advisor population and produce a robust pipeline of diverse candidates interested in entering the financial services industry. … In its initial posting, the application for the Building Diverse Pathways program received more than 1,000 resumes for the 50 openings."Wells Fargo & Company, 2023 Diversity, Equity, and Inclusion Report, June 2023, p. 12 (report deleted from wellsfargo.com in May 2025)

"Establishing and recruiting for a new companywide Sophomore Discovery Fellowship Program, with 83% of participants coming from a historically underrepresented background, and 64% of participants identifying as female."Wells Fargo & Company, 2024 Diversity, Equity, and Inclusion Report, published August 2024, p. 13, "Attracting talent" (report deleted from wellsfargo.com in May 2025)

Other programs in the same family are documented with the same kind of composition reporting. The Operating Committee Sponsorship Program, launched in 2021, paired employees with Operating Committee sponsors; the 2022 DE&I Report described 42 diverse employees mentored monthly by Operating Committee members, and the racial equity assessment found that roughly half of participants had earned promotions or new roles by September 2023. The Glide — Relaunch returnship reported 105 U.S. hires with 87% from underrepresented groups, and the racial equity assessment recorded that its spring 2023 cohort was 78% racially or ethnically diverse with a minimum $100,000 base salary on conversion. Wells Fargo's Career Development Program, which supported its OneTen Coalition commitment, reported that more than 75% of its 2023 participants came from historically underrepresented backgrounds. The Premier Banker Associate Program was described as "[l]aunched in 2022 as part of our efforts to expand diversity throughout the premier banker role," with associates promoted to senior banker on completion.

A balancing point belongs here. Most of these published descriptions state a program's purpose and report the demographic makeup of who participated; with the exception of the Diverse Leaders Program's group-defined tracks, they do not state on their face that anyone was formally barred from applying because of race or sex. The legal significance of a program turns on how eligibility actually worked in practice and what concrete career benefit — a promotion, a sponsor, a conversion to a $100,000 role — it delivered. Those facts live with the people who ran the programs and the people who were told a program was, or was not, for them.

One item in the record remains unverified: Wells Fargo Advisors' "Black/African American advisor programs & resources" page (wellsfargoadvisors.com/joinwfadvisors/baa-resources.htm) now returns a 404. A Wayback Machine capture dated July 14, 2025 exists, and its contents have not yet been read. It is identified in Sources and is not relied on above.

How Wells Fargo's DEI program changed, 2019–2026

Why these practices matter legally

Title VII of the Civil Rights Act of 1964 prohibits employers from making employment decisions because of race or sex — and it protects every race and both sexes. Two recent Supreme Court decisions sharpened that rule. In Muldrow v. City of St. Louis (2024), the Court held that a plaintiff challenging a discriminatory job transfer need show only some harm from the change in terms or conditions of employment, not a "significant" disadvantage. In Ames v. Ohio Department of Youth Services (decided June 5, 2025), the Court unanimously rejected the rule that majority-group plaintiffs must clear a higher evidentiary bar to bring a discrimination claim. Separately, 42 U.S.C. § 1981 prohibits race discrimination in the making and enforcement of contracts — including employment — and carries its own four-year window with no agency filing requirement. (Statutes: Title VII, § 1981; opinions: Muldrow, Ames.)

For federal contractors there is a second layer. On April 10, 2026, International Business Machines Corporation paid $17,077,043 to resolve allegations — under the Justice Department's Civil Rights Fraud Initiative, in DOJ's first False Claims Act settlement of its kind — that it certified compliance with federal anti-discrimination requirements while operating DEI practices including "a diversity modifier that tied bonus compensation to achieving demographic targets," altered "interview criteria based on race or sex through the use of 'diverse interview slates,'" "race and sex demographic goals for business units," and training, mentoring and leadership programs whose eligibility was "limited on the basis of race or sex" (DOJ press release). DOJ stated that "the claims resolved by the United States in the settlement are allegations only and there has been no determination of liability."

The parallel fact on the nexus side is documented by the federal government itself. In announcing the 2020 conciliation agreement, the Department of Labor stated that Wells Fargo operates "under contract with many federal departments and agencies, including the Securities and Exchange Commission and U.S. Department of Veterans Affairs," and resolved the matter under Executive Order 11246, which "prohibits federal contractors from discriminating in employment based on race, color, religion, sex, national origin, sexual orientation or gender identity" (DOL release). Executive Order 14173, signed January 21, 2025, directs that federal contracts include a term requiring the counterparty "to certify that it does not operate any programs promoting DEI that violate any applicable Federal anti-discrimination laws," and a term making compliance with federal anti-discrimination law "material to the government's payment decisions" for False Claims Act purposes (90 FR 8633).

To be clear about what is and is not established: no court or agency has found that Wells Fargo's DEI practices violated Title VII or § 1981, the shareholder settlements resolved allegations without any admission of liability, and the IBM settlement itself resolved allegations with no determination of liability. But practices like those documented above — compensation keyed to representation progress, a 50% diverse-slate expectation with a diverse interviewer requirement, representation goals assigned to named leaders, and development programs organized around race or sex — are precisely the categories that can give rise to liability under Title VII and § 1981, and, for companies doing business with the federal government, potential False Claims Act exposure. For a plain-English breakdown of where the legal line falls, see Is DEI Illegal? 4 Illegal DEI Practices & When You Can Sue.

Were you affected by these practices at Wells Fargo?

If you worked at Wells Fargo & Company — or applied there — between roughly 2019 and 2025, the documented practices above may have touched your career in ways worth examining:

• You were passed over for a promotion or left off an interview slate for a senior professional or manager role while the company expected a 50% diverse candidate slate and a diverse interviewer on first-round panels.
• You were excluded from a leadership, sponsorship, fellowship, or pipeline program — the Diverse Leaders Program, the Operating Committee Sponsorship Program, BOLD, Building Diverse Pathways, Glide — Relaunch, the Sophomore Discovery Fellowship — or were told one wasn't for you, because of your race or sex.
• You were a manager, recruiter, or HR professional whose own evaluation and compensation were affected by progress on representation numbers, or who has first-hand knowledge of how the slate guidelines and representation goals were actually applied.
• You interviewed for a role at Wells Fargo that had already been filled, or watched that happen — the practice at the center of the securities litigation the bank settled for $85 million.
• You were laid off or separated during a Wells Fargo headcount reduction and signed a severance agreement without anyone reviewing whether you were giving up a discrimination claim.

Because Wells Fargo does substantial business with the federal government, insiders with knowledge of demographic employment practices during the certification period may also have information relevant to a False Claims Act qui tam claim — a mechanism that lets individuals bring claims on the government's behalf and potentially share in any recovery. Qui tam complaints are filed under seal, so a whistleblower's identity is initially protected. Both Title VII and the False Claims Act prohibit retaliation against people who assert their rights or report violations.

If any of these fits, it costs nothing to find out where you stand — meet our DEI discrimination lawyers, or start below.

What could a claim against Wells Fargo be worth?

Whistleblower rewards under the False Claims Act

Under 31 U.S.C. § 3730(d), a qui tam whistleblower (called a "relator") is entitled to 15–25% of what the government recovers when the Justice Department intervenes, and 25–30% when the relator litigates without government intervention. For scale: on a settlement the size of IBM's $17,077,043, the intervened-case whistleblower share would be roughly $2.6 million to $4.3 million. Because False Claims Act recoveries are built on treble damages plus per-claim penalties, recoveries against very large contractors can run substantially higher.

Damages in individual discrimination cases

Back pay and front pay are uncapped under Title VII. Compensatory and punitive damages under Title VII are capped by employer size — $300,000 for employers with more than 500 employees, the bracket Wells Fargo occupies — but race claims under 42 U.S.C. § 1981 carry no damages caps at all, which is one reason race discrimination cases are often pleaded under it, and many state civil-rights statutes (including Michigan's Elliott-Larsen Civil Rights Act) are likewise uncapped. Prevailing plaintiffs generally recover attorney's fees on top. For a sense of what employment discrimination cases can produce, Fett Law's own results include a $10.5 million race and age discrimination class action against Ford Motor Company, a $2 million disability harassment result, and a $1.6 million racial harassment result. Prior results do not guarantee a similar outcome.

Class action potential

Class actions are built on a single policy applied to many people — and the practices documented above are companywide by design: one slate expectation covering most senior U.S. professional and manager roles, one set of representation goals reaching the Operating Committee and other leaders, development programs operating at national scale across a workforce that exceeded 200,000. Historic employment-discrimination class settlements show what such cases can reach: Coca-Cola paid $192.5 million (2000), Texaco $176.1 million (1996), and Novartis $175 million (2010) to resolve class claims. Wells Fargo's own securities settlement over the diverse-slate statements was $85 million.

Every case depends on its own facts — these figures show the range the law makes possible, not a promise of any outcome. The fastest way to learn where your situation falls is to start a confidential intake or request a free consultation.

Sources