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

Published August 27, 2026 · Last updated August 27, 2026 · By Fett Law — Michigan Employment Discrimination Attorneys

Key facts

Did AECOM tie pay and its cost of capital to diversity targets?

The cost of capital

The first linkage is unusual and AECOM was proud of it. On February 8, 2021 the company announced an amended and extended credit facility — a $1.15 billion revolving facility and a $247 million term loan — carrying pricing incentives tied to two measures:

"In addition, reflecting AECOM's commitment to advancing its environmental, social and governance (ESG) initiatives and delivering a better world, the facility includes incentives linked to achieving certain sustainability, and diversity and inclusion goals. These measures include:

• Reducing greenhouse gas emissions at a rate that is consistent with AECOM's previously announced Science Based Targets that align with the target reductions included in the Paris Agreement.

• Continued increase in the percentage of women in the organization to further promote inclusion and diversity."

— AECOM, "AECOM amends and extends its credit facility and links borrowing cost to sustainability and diversity goals," February 8, 2021 (source)

AECOM's chief executive described what the company had done in plain terms in the same release:

"I am proud that we are one of the earliest companies in the U.S. to take action by linking our cost of capital to our sustainability, and diversity and inclusion objectives."

— Troy Rudd, Chief Executive Officer, AECOM, February 8, 2021 (source)

Executive compensation

The second linkage runs through executive pay. AECOM's 2022 ESG Report states it on the page describing the company's governance standards:

"We're holding ourselves to high standards by incorporating ESG-related key performance indicators (KPIs) into our CEO and officer compensation this year"

— AECOM, 2022 ESG Report, p. 27 (source). AECOM told shareholders the same thing: its proxy statements filed January 20, 2022 and January 30, 2023 each list, among the company's practices, "Incorporated ESG-related key performance indicators (KPIs) in compensation metrics for CEO and key NEOs" (2023 proxy).

Leaders' personal goals in the performance and reward process

The most explicit statement that diversity goals sat inside how AECOM leaders were assessed and paid appears in its United Kingdom gender pay gap reporting, signed by regional leadership:

"I hold myself and my leadership team accountable for our progress, with all senior leaders across our business in Europe set at least one ED&I personal goal as part of our performance and reward process."

— AECOM, UK Gender Pay Gap Report 2021, Foreword (source)

The practice was extended and formalised the following year, and hardened the year after that:

"In 2023, we have introduced new Inclusive Leadership Goals, to support our leaders on their journey of inclusion. Each leader was asked to commit to one ED&I goal, and our ED&I SteerCo will track and support these."

— AECOM, UK Gender Pay Gap Report 2022 (source). The 2023 edition states it more flatly still: "ED&I targets are embedded into all our leaders' goals." (source)

What this meant in practice. A general statement that a company values diversity costs nothing. A measure that moves the interest rate a company pays, a key performance indicator inside the compensation of the chief executive and officers, and a mandatory personal goal in every senior leader's performance and reward file are three different things — each one creates a reason for the people making hiring and promotion decisions to care about the demographic composition of their teams. One limit on the public record should be stated plainly: AECOM never published the weighting of the diversity component inside any bonus, or the specific numeric threshold attached to it. The executives, HR and compensation staff who set those thresholds, and the leaders who wrote their own ED&I goals, are the people who know how they were measured.

Did AECOM set numeric representation goals for women and for its regions?

The global target was announced with AECOM's Sustainable Legacies strategy and published in the company's first ESG report:

"Ensuring women comprise at least 20 percent of senior leadership roles and at least 35 percent of the overall workforce in the near term"

— AECOM, 2021 Environmental, Social & Governance Report, p. 4; restated at p. 11 as "To ensure women comprise at least 20 percent of senior leadership roles and at least 35 percent of the overall workforce," and at p. 22 as "Ensuring that women account for at least 35% across our company" and "Ensuring that women account for at least 20% of senior leadership" (source)

The target was carried forward and measured. The 2022 ESG Report restates it and publishes the running score:

"To ensure women comprise at least 20 percent of senior leadership roles and at least 35 percent of the overall workforce in the near term"

"We continue to make progress against this ambitious goal, with women in 18 percent of leadership roles and making up 33 percent of our overall workforce."

— AECOM, 2022 ESG Report, pp. 8–9; the same figures appear at p. 20: "As of September 30, 2021, across our global employee base, approximately 33 percent were women, including 18% within leadership roles." (source)

By the 2024 report, AECOM recorded the leadership leg of the target as met:

"As of September 30, 2023, across our global employee base, approximately 34% were women, including more than 20% within leadership roles."

— AECOM, Delivering Sustainable Legacies: Our 2024 Sustainability Report, p. 31; the report's opening pages record that AECOM "achieved our near-term goal of women comprising at least 20% of our leadership" and would "continue to make further progress against our 35% near-term target of women company-wide" (source)

The regional targets

Alongside the global gender target, AECOM built a second layer that it described as region-specific and that it did not publish in numbers. Its 2022 ESG Report says so four separate times:

"Implemented diversity-specific KPIs and associated near- and long-term targets in each region within our business"

"To achieve specific and culturally relevant diversity goals implemented within each region of our business, while investing in underrepresented groups within the regions of our business"

— AECOM, 2022 ESG Report, pp. 4, 8; repeated at p. 9 and again at p. 20: "In addition, we have implemented diversity-specific KPIs and associated near- and long-term targets in each region within our business." (source). The 2024 Sustainability Report carries the same commitment forward and describes it as "Achieving specific and culturally relevant diversity goals implemented within each region of our business based on local community demographics."

One of those regional numbers did become public. AECOM's United Kingdom gender pay gap report for 2024 discloses both the target and the fact that it was exceeded:

"The proportion of women in leadership positions has also risen from 14.5 per cent in 2023 to 17.5 per cent in 2024, surpassing our regional target of 16 per cent."

— AECOM, UK Gender Pay Gap Report 2024, p. 1 (source). The 2025 edition drops the figure and says only that AECOM will "continue to set gender representation targets across our region" (source).

The board

AECOM also applied a race-explicit commitment at board level. Its proxy statement filed January 17, 2025 states:

"The Board is also committed to appointing a racially and/or ethnically diverse director within a year of the 2025 Annual Meeting, following Ms. Kennard's departure from the Board."

— AECOM, Proxy Statement (DEF 14A) filed January 17, 2025 (source). AECOM's Corporate Governance Guidelines, as described in its proxies from January 2021 through January 2025, provided that the Board "should include representation of individuals from underrepresented communities, including people of different genders, experiences, ages, races and ethnic backgrounds" — language dropped from the proxy filed January 20, 2026.

What this meant in practice. A representation target with a defined population, a defined percentage and a deadline is a number someone is accountable for reaching. When it is paired — as AECOM's was — with region-level key performance indicators, with an ED&I goal in each senior leader's performance and reward file, and with a borrowing cost that moved on the percentage of women in the organisation, it becomes a number that has consequences for the people who miss it. Whether any individual hiring, promotion or assignment decision at AECOM was in fact made on the basis of sex or race is a separate, factual question that turns on the evidence in that particular case. The recruiters, HR business partners and line managers who were handed the regional numbers are the people best placed to describe how they were carried into decisions.

Did AECOM run programmes restricted by sex?

The programme was announced in 2021:

"In 2022, we are launching a new career development programme specifically designed for our female employees to help upskill, empower and unlock career opportunities."

— AECOM, UK Gender Pay Gap Report 2021, "Inclusive careers" (source)

It launched under the name Empower, and AECOM described its eligibility twice in the following year's report — once in the leadership foreword and once in a participant's own words:

"These include early careers campaigns, diverse selection panels and our new Empower career development programme designed to help women further their careers."

"I was fortunate to be given the opportunity to attend the Empower programme, which is a career development programme targeted at women in the business."

— AECOM, UK Gender Pay Gap Report 2022 (source)

The programme is still running, under the name Balanced Talent, and AECOM's most recent report describes it in terms that leave no ambiguity about who it is for:

"Our female career development programme Balanced Talent, delivered by an external partner, continues to equip women with the tools, networks and confidence they need to progress in their careers."

"The Balanced Talent Alumni community further supports participants' ongoing development through quarterly calls on high-impact topics, along with access to senior leaders to enhance engagement and visibility."

— AECOM, UK Gender Pay Gap Report 2025, p. 8 (source)

The second sentence is the one to read closely. What the alumni community provides is not general skills training but "access to senior leaders to enhance engagement and visibility" — the currency of promotion. A development track that supplies visibility to senior decision-makers, and that is open only to employees of one sex, is a difference in the terms and conditions of employment, not a difference in enrichment.

Two further items in the same series carry eligibility conditions:

"AECOM Women in Construction Scholarship in partnership with the University of Salford, which is designed to help increase the number of women completing construction-related undergraduate degrees and provides one female student from a low-income background studying Construction Project Management with support throughout their three years of study."

— AECOM, UK Gender Pay Gap Report 2021 (source)

"we have recently launched a programme of reverse mentoring, where our senior leaders will be mentored over a nine-month period, by employees from diverse backgrounds and under-represented groups."

— AECOM, UK Gender Pay Gap Report 2022 (source). AECOM's earlier description of the same idea, in its 2021 ESG Report at p. 22, was a "reverse mentoring program pairing junior professionals with our executive leadership team" — pairing by seniority, with no demographic condition stated.

The reverse-mentoring change is worth noticing on its own. In 2021 the pairing criterion AECOM published was seniority. By 2022 the published criterion for who could be a mentor to the senior leadership team — a position of unusual access — was membership of a "diverse background" or an "under-represented group."

On employee resource groups. AECOM operates ten employee resource groups organised by community, including BeBold (Black community), the Ethnic Diversity Network, JUNTOS (Hispanic/Latinx community), MOSAIC (Asian Pacific Islander community), Gender Alliance and the Women's Leadership Alliance. AECOM's 2022 ESG Report describes at least one of them as bringing together colleagues "and our allies," and this page does not claim that any AECOM employee resource group was closed to employees outside its named community — no AECOM document reviewed says that it was, and the absence of an express open-to-all statement is not evidence of a closed door.

Did AECOM use race or sex in hiring and selection?

This section documents a narrower practice than the corresponding sections on several other companies in this series, and the difference is real. What AECOM did publish is this:

"From rolling out unconscious bias training for hiring managers, increasing the diversity of interview panels and embedding gender-inclusive language in job adverts to using diverse representation of profiles in our marketing collateral, we have put in place a range of initiatives to facilitate the hiring of more female talent."

— AECOM, UK Gender Pay Gap Report 2021, talent strategies section (source)

"These include early careers campaigns, diverse selection panels and our new Empower career development programme designed to help women further their careers."

— AECOM, UK Gender Pay Gap Report 2022 (source)

AECOM also published intake figures broken out by sex and by ethnicity, and used them as measures of success — "In 2022, 25% of our early careers intake was from an ethnic minority background, up 6 per cent"; "we are half way through our current early careers recruitment campaign and currently sitting at 41% female hires" (UK Gender Pay Gap Report 2022) — and its 2024 Sustainability Report frames recruitment as "Ensuring, through our recruitment efforts, that our teams reflect the diversity of the communities we serve."

What this record does and does not establish should be kept separate. A demographic composition requirement placed on the panel is a requirement about who evaluates candidates. A requirement placed on the slate is a requirement about who gets evaluated at all, and it is the second that was among the practices at issue in the government's federal-contractor settlements. AECOM published the first and did not publish the second. Whether AECOM's internal recruiting systems carried slate conditions, requisition gates or demographic approval steps that were never published is a question about internal records, and the recruiters and hiring managers who worked inside those systems are the people who would know.

How AECOM's DEI program changed, 2019–2026

AECOM had no diversity disclosure in its annual report before fiscal 2020, built a targeted programme between 2021 and 2023, and by 2025 had removed every number from it — without deleting a single document.

Why these practices matter legally

Two recent Supreme Court decisions matter for anyone weighing a claim of this kind. In Muldrow v. City of St. Louis (2024), the Court held that an employee challenging a discriminatory job transfer need show only some harm to the terms or conditions of employment, not a "significant" disadvantage. In Ames v. Ohio Department of Youth Services, decided unanimously on June 5, 2025, the Court rejected the rule — previously applied in several federal circuits — that a plaintiff from a majority group must produce extra "background circumstances" evidence before a discrimination claim can proceed. Separately, 42 U.S.C. § 1981 prohibits race discrimination in the making and enforcement of contracts, including employment relationships, carries a four-year window, requires no agency filing first, and has no cap on damages. (Title VII, 42 U.S.C. § 2000e-2.)

The False Claims Act route for federal contractors

On April 10, 2026, the U.S. Department of Justice announced that IBM would pay $17,077,043 to resolve False Claims Act allegations that it failed to comply with anti-discrimination requirements in its federal contracts — the first settlement under the DOJ's Civil Rights Fraud Initiative. In August 2026 the government resolved a second, larger matter: under a settlement agreement effective August 21, 2026, five Deloitte entities agreed to pay $21,500,000, of which $9,995,000 was restitution, covering conduct from January 1, 2017 through the settlement date. The certification hook is specific — Title VII as incorporated into federal contracts and FAR clause 52.222-26 — and the government's theory reached not only what Deloitte certified to its contracting agencies but what it "publicly represented" about its compliance. The agreement adds a second and independent theory: that Deloitte "allocated costs to its federal government contracts relating to these practices and sought payment and reimbursement under its federal government contracts for such costs." The whistleblower was paid $4,300,000. Both settlements resolved allegations only, with no determination of liability, and Deloitte denies the conduct.

The two theories map onto AECOM's business differently, and both are worth stating. AECOM is a federal contractor by its own disclosure: its Form 10-K reports that "Approximately 7%, 7%, and 5% of our revenue was derived through direct contracts with agencies of the U.S. federal government in the years ended September 30, 2025, 2024, and 2023, respectively" — $1,107.3 million in fiscal 2025 alone — with named prime work for FEMA, the U.S. Army Corps of Engineers, the Federal Aviation Administration, the Environmental Protection Agency and the General Services Administration. And AECOM's own risk factors concede the exposure in terms the company chose itself:

"Furthermore, as a government contractor, we are subject to an increased risk of investigations, criminal prosecution, civil fraud actions, whistleblower lawsuits, and other legal actions and liabilities to which purely private sector companies are not, the results of which could materially adversely impact our business. For example, from time to time we may be subject to qui tam lawsuits, which typically allege that we have made false statements or certifications in connection with claims for payment, or improperly retained overpayments, from the government. These suits may remain under seal (and hence, be unknown to us) for some time while the government decides whether to intervene on behalf of the qui tam plaintiff."

— AECOM, Form 10-K for the fiscal year ended September 30, 2025, filed November 19, 2025, Item 1A, Risk Factors (source)

That risk is not hypothetical for AECOM. On October 24, 2023 the company paid the United States $11.8 million to resolve False Claims Act allegations in United States ex rel. Robert Romero v. AECOM, Inc., et al., No. 16-cv-15092 (E.D. La.), arising from its work as FEMA's technical assistance contractor on Hurricane Katrina recovery between 2006 and 2010. The whistleblower, Robert Romero, received more than $2.4 million. As the Department of Justice stated, "The claims resolved by the settlement are allegations only, and there has been no determination of liability."

To be clear about what is and is not established here: no court or agency has found that AECOM's diversity practices violated any law; this page located no discrimination charge, EEOC action, OFCCP enforcement proceeding or False Claims Act matter involving AECOM's DEI practices; and both the IBM and Deloitte settlements resolved allegations without any admission or determination of liability. What can be said is that the categories of conduct the government has now twice pursued — numeric demographic goals for business units, compensation tied to those goals, and programmes whose eligibility is limited by race or sex — are categories AECOM's own documents describe, and that AECOM is a federal contractor of the kind the theory reaches. Whether any particular AECOM certification was false, in any particular period, is a fact-specific question the public record does not settle. For the complete framework — the four illegal DEI practice categories and when you can sue — see our guide, Is DEI Illegal? 4 Illegal DEI Practices & When You Can Sue.

Were you affected by these practices at AECOM?

If you worked at AECOM — or applied there — between 2021 and 2025, the documented practices above may have touched your career in ways worth examining:

• You were passed over for a promotion into a leadership role during a period when AECOM had published a target that women comprise at least 20 percent of senior leadership, was reporting its progress toward that number every year, and had told the market its cost of borrowing moved with the percentage of women in the organisation.
• You were excluded from a career-development programme — Balanced Talent, Empower, or a regional equivalent — because of your sex, and with it from the "access to senior leaders" that AECOM says the programme's alumni community provides.
• You were not selected as a mentor to the senior leadership team in a reverse-mentoring programme whose published mentor pool was defined as employees "from diverse backgrounds and under-represented groups."
• You applied for a role in AECOM's European business during a period when the company published that it was using diverse selection panels and increasing the diversity of interview panels expressly to hire more female talent.
• You were a senior leader required to set an ED&I personal goal "as part of our performance and reward process," or a manager handed a regional diversity KPI, and you know how that number was translated into instructions about hiring and promotion.
• You were a recruiter, HR business partner or compensation professional with first-hand knowledge of what the regional diversity targets actually contained — the numbers AECOM never published — or of how the ESG key performance indicators in officer compensation were set and measured.

There is a separate question worth asking if your work touched AECOM's federal business. The False Claims Act's qui tam mechanism lets an individual bring a claim on the government's behalf, and potentially share in any recovery, where a company certified compliance with federal anti-discrimination requirements while doing something else — the theory the Justice Department used against IBM and Deloitte. The Deloitte agreement adds a second route that applies wherever a contractor allocated the costs of these practices to its federal contracts and sought reimbursement for them. Whether AECOM made certifications of that kind, in any particular period, is a fact-specific question the public record does not answer; it is the sort of thing an insider knows. Qui tam complaints are filed under seal, so a whistleblower's identity is initially protected while the government investigates. Both Title VII and the False Claims Act prohibit retaliation against people who assert their rights or report violations.

A federal settlement is not a substitute for your own claim: when the Justice Department resolved the Deloitte matter, it expressly preserved the EEOC's right to pursue charges alleging the very same conduct, and preserved individual liability. Nothing about that settlement compensated a single employee or applicant.

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

What could a claim against AECOM be worth?

Whistleblower rewards under the False Claims Act

Under 31 U.S.C. § 3730(d), a qui tam relator receives 15–25% of the government's recovery when the Department of Justice intervenes, and 25–30% when the relator proceeds without intervention. The Deloitte settlement supplies a paid benchmark rather than a projection: the relator received $4,300,000 — exactly 20% of a $21,500,000 recovery. That settlement also shows why False Claims Act exposure outruns the money actually lost. Of the $21.5 million, $9,995,000 was restitution — roughly the government's single damages — so the resolution came to about 2.15 times the actual loss, because FCA recoveries are built on multiplied damages plus per-claim penalties. As a second illustration, arithmetic alone: an intervened case resolving at IBM's $17,077,043 would pay a relator roughly $2.6–$4.3 million. A contractor with a larger federal book or a longer conduct period could produce a materially larger number.

AECOM's own history supplies a third data point, and it is the closest one: in the 2023 FEMA matter, relator Robert Romero received more than $2.4 million from an $11.8 million settlement.

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 — $50,000 for employers with 15 to 100 employees, $100,000 for 101 to 200, $200,000 for 201 to 500, and $300,000 for more than 500, the bracket AECOM occupies with roughly 51,000 employees worldwide. 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 several state civil-rights statutes are likewise uncapped — including Michigan's Elliott-Larsen Civil Rights Act and California's Fair Employment and Housing Act, which governs a substantial part of AECOM's U.S. workforce. 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 and retaliation result, and a $1.6 million racially hostile work environment result. Prior results do not guarantee a similar outcome.

Class action potential

Class actions are built on a single policy applied to many people. A representation target set at company level and cascaded into regional key performance indicators, and a development programme whose eligibility rule is the same for every employee in the region, are by construction common policies rather than individual decisions. Historic employment-discrimination class settlements show the range 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.

Every case depends on its own facts — these figures show the range the law makes possible, not a prediction. The fastest way to learn where your situation falls is to start a confidential intake.

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