Arrow Electronics' 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

Item	Detail
Company	Arrow Electronics, Inc. (NYSE: ARW), the Centennial, Colorado–headquartered global distributor of electronic components and enterprise computing solutions. Approximately 22,230 employees worldwide as of December 31, 2025, of whom roughly 5,860 are in the Americas
Federal-contractor nexus	Arrow Electronics' 2025 Form 10-K states that "certain of the company's business units contract or subcontract with U.S. government agencies" and describes the January 21, 2025 executive orders requiring federal contractors to certify that they do not operate DEI programs violating federal anti-discrimination law. Arrow's immixGroup business sells to federal agencies through wholly owned subsidiaries immixTechnology and EC America on vehicles including GSA contracts, DOD ESI agreements, ITES-SW2 and NASA SEWP V
Documents reviewed	Nine company-published documents, 2021–2026: the ESG Reports for 2021, 2022 and 2023; the Corporate Stewardship and Impact Reports for 2024 and 2025; and the proxy statements filed in 2021, 2022, 2023, 2024 and 2025, plus the 2025 Form 10-K
Practices documented	(1) Executive annual cash incentive objectives tied to "diversity and equality-related measures" for 2022 and 2023, inside an incentive whose non-financial component was weighted at 30%; (2) numeric multi-year goals to grow representation of women leaders globally and of leaders of underrepresented race/ethnicity in the U.S., with published attainment; (3) talent acquisition designed to "achieve diverse representation in our applicant and interview pools"; (4) leadership, mentoring and alumni programs described as being for women, and a stated commitment to grow a leadership pipeline "for women and employees of underrepresented race/ethnicity groups"
Source-document status	Orphaned, and the current reports are silent. As of August 2026, arrow.com/company/corporate-social-responsibility/reporting returns a 404 and Arrow's live ESG page links only the 2025 report. The 2021, 2022 and 2023 ESG Report PDFs still load from their direct arrow.com addresses and are linked below. The reports published in March 2025 and March 2026 were renamed "Corporate Stewardship and Impact" and contain no workforce gender or race/ethnicity data, no representation goals and no reference to the 2025 goal — with no explanation of what became of it

Did Arrow Electronics tie executive pay to diversity measures?

The company announced the linkage in the proxy statement filed March 30, 2022:

"quantitative performance objectives related to carbon emission reduction and diversity and equality-related measures will be a component of our executive annual cash incentive plan for 2022"— Arrow Electronics, Inc., Proxy Statement (DEF 14A), filed March 30, 2022 (source)

Its ESG report for the same year put the same commitment in operational terms:

"To further demonstrate Arrow's commitment to the importance of these efforts, quantitative performance objectives related to the above-referenced carbon emission reduction and diversity and equality-related measures were specified as components of the 2022 annual cash incentive plan for executives."— Arrow Electronics, Inc., Environmental, Social, and Governance 2022 Report (April 2023), p. 12 (PDF)

Two years later, the company confirmed the mechanism had run for a second year:

"quantitative performance objectives related to carbon emission reduction and diversity and equality-related measures were components of our executive annual cash incentive plan for 2022 and 2023."— Arrow Electronics, Inc., Proxy Statement (DEF 14A), filed March 26, 2024 (source)

The proxy statements describe the annual cash incentive as weighted "Absolute EPS (70%) and Strategic ESG Goals (30%)." What that means operationally is that for two years, up to three-tenths of the annual cash bonus of Arrow Electronics' named executive officers turned on a basket of non-financial objectives, and diversity measures were expressly among them — while the same executives set the goals that flowed down to the managers who made hiring, promotion and succession decisions.

One limit on the public record should be stated plainly. Arrow Electronics never published how much of the 30% component the diversity objectives carried, what the numeric thresholds were, or what payout resulted from hitting them. Nor is it a matter of public record whether any individual manager's own bonus carried a similar linkage. Those figures, if they exist in writing, sit in internal compensation documents.

Did Arrow Electronics set racial or gender representation goals?

The goal is stated in a single sentence, repeated across reports:

"Grow representation of women leaders globally and leaders who are of underrepresented race/ethnicity in the U.S. by 0.5 percentage points in each category in 2022, and by two percentage points in each category by the end of 2025."— Arrow Electronics, Inc., Environmental, Social, and Governance 2022 Report (April 2023), p. 52 (PDF); the same goal is set in the 2021 Report (March 2022), pp. 10 and 21 (PDF)

Arrow Electronics then reported results against the goal in percentage-point terms:

"Grew representation of women leaders globally by 1.5 percentage points, exceeding the target of 0.5 percentage point growth by 1.0 percentage points. Grew representation of leaders who are of underrepresented race/ethnicity in the U.S. by 1.3 percentage points, exceeding the target of 0.5 percentage point growth by 0.8 percentage points."— Arrow Electronics, Inc., Environmental, Social, and Governance 2022 Report (April 2023), p. 52 (PDF)

The underlying figures were published as well: women leaders globally rose from 32.6% in 2021 to 34.1% in 2022, and leaders of underrepresented race/ethnicity in the U.S. from 25.2% to 26.5%. The following year, the direction reversed:

"In 2023, representation of women leaders globally declined by 0.78 percentage points, and representation of leaders who are of underrepresented race/ethnicity grew by 0.04 percentage points."— Arrow Electronics, Inc., Environmental, Social, and Governance 2023 Report (March 2024), p. 17 (PDF)

The 2023 report attributes the decline to "an enterprise-wide initiative to simplify the company's organizational structure" begun in August 2023, and restates the underlying ambition in a form worth reading carefully:

"Arrow remains committed to our multiyear aspiration of growing diverse leadership representation on our journey to align Arrow's leadership representation with our overall employee representation and the total available talent market."— Arrow Electronics, Inc., Environmental, Social, and Governance 2023 Report (March 2024), p. 17 (PDF)

In plain terms: for at least three consecutive years, Arrow Electronics published a target for what share of its leadership should be women and what share should be people of underrepresented race/ethnicity in the United States, measured itself against those numbers annually, reported the result to the percentage point, and — for two of those years — carried diversity objectives inside its executives' cash bonus plan. A published aspiration is not, by itself, an unlawful act. What matters legally is whether the number changed who was actually promoted into a leadership role. The managers, HR business partners and talent-review participants who worked those years are the people best placed to know.

Did Arrow Electronics use race or sex in hiring and interviewing?

The employment-side language appears in the talent acquisition section of the ESG reports:

"Our global talent acquisition teams are equipped with best-in-class technology, market data, and reporting that enable us to recruit unique talent pipelines and achieve diverse representation in our applicant and interview pools by:… Using referral campaigns to access employees' diverse networks and professional affiliations; Building inclusive and diverse interview and selection teams"— Arrow Electronics, Inc., Environmental, Social, and Governance 2023 Report (March 2024), p. 42 (PDF); the same "Inclusive and diverse interview and selection teams" item appears in the 2022 Report, p. 48

The board-level language is more explicit about demographics, and it ran across at least three consecutive proxy statements:

"The Board has retained a recruitment firm to assist the Corporate Governance Committee in actively identifying and evaluating potential diverse Board candidates and sets clear expectations that candidate slates should include women and candidates of underrepresented race/ethnicity"— Arrow Electronics, Inc., Proxy Statement (DEF 14A), filed March 30, 2022 (source); substantially the same sentence appears in the proxies filed April 5, 2023 and March 26, 2024

We draw the distinction because it is a real one. A slate expectation applied to directors is a corporate-governance practice; a slate rule applied to jobs is an employment practice, and the two are governed by different bodies of law. On the public record, Arrow Electronics applied the express demographic slate expectation to its board. For employment roles, what it published is a stated objective of demographic representation in applicant and interview pools, and the design of interview and selection teams around it — a goal, not a written threshold with a documented consequence for missing it. Whether recruiters at Arrow Electronics operated to an internal numeric pool requirement is not something the public documents answer. The recruiters and hiring managers would know.

Did Arrow Electronics run programs restricted by race or sex?

The clearest example is the mentoring program, described in the 2022 ESG report as

"a nine-month mentorship between women leaders who have either completed one of Arrow's leadership development programs (the mentors) and the middle-level high-potential women talent (the mentees)"— Arrow Electronics, Inc., Environmental, Social, and Governance 2022 Report (April 2023), p. 53, APAC Women Mentoring Program (PDF)

The alumni network attached to it is defined by the program that feeds it:

"Amplify is a community of Arrow employees providing program alumni an opportunity to stay connected to each other after completing the women's leadership program."— Arrow Electronics, Inc., Environmental, Social, and Governance 2022 Report (April 2023), p. 53 (PDF)

And the technology-track initiative names both the audience and the purpose:

"Advancement of Women in Technology: Guiding managers to engage women in growing and advancing their careers to support our long-term goal of growing representation of women leaders across the organization; paired with a pilot program for nominated women to participate in courses, mentorships, and other stretch assignments"— Arrow Electronics, Inc., Environmental, Social, and Governance 2022 Report (April 2023), p. 42 (PDF)

The 2023 report carries the same idea forward and adds race to it, listing among the company's talent priorities "Growing a leadership talent pipeline for women and employees of underrepresented race/ethnicity groups through targeted development opportunities" (p. 48), and recording that Arrow "Invested in women in our workforce via our Amplify and Arrow Women Empowerment (AWE) programs to grow skills and confidence through learning and executive networking" (p. 40).

We state the limit of this category honestly. In the IBM matter the Justice Department alleged programs whose "eligibility, participation, access or admission" was "limited on the basis of race or sex." Arrow Electronics did not publish a program rule in those terms. What it published is a set of development, mentoring and networking tracks that it consistently described as being for women, and a stated intention to build a leadership pipeline for women and for employees of underrepresented race/ethnicity. Whether a man in a comparable role could have been nominated for the pilot, joined the mentoring program, or been included in the pipeline described in 2024 is not something the public documents settle. Employees who were nominated — and employees who were not — are the people who know how selection actually worked.

What happened to Arrow Electronics' DEI reporting?

Verified in August 2026:

• arrow.com/company/corporate-social-responsibility/reporting — 404. An archived copy of that page from December 25, 2022 is preserved at the Internet Archive
• careers.arrow.com/us/en/diversity,-equity,-and-inclusion — 404
• Arrow's live ESG page links only the 2025 Corporate Stewardship and Impact Report; the 2021, 2022 and 2023 ESG Reports are no longer indexed there
• The 2021, 2022 and 2023 ESG Report PDFs — all still load from their direct arrow.com/company/wp-content/uploads/… addresses, each linked in the Sources section below

The substantive change is in the content, not the URLs. The 2023 report devoted pages to goals, attainment, workforce demographics by sex and by U.S. race/ethnicity, promotion rates, and named women's programs. The 2024 report, published in March 2025 — two months after Executive Order 14173 — contains none of it. There is no paragraph explaining the change, no restatement of the 2025 goal, and no statement that the goal was met, missed or withdrawn. The goal simply stops appearing.

If any part of your own situation depends on what these reports said, download the PDFs rather than bookmarking them. A page that no longer links a document is one configuration change away from no longer serving it.

How Arrow Electronics' DEI program changed, 2021–2026

Date	Development
March 2022	The 2021 ESG Report sets the goal to "grow representation of women leaders globally" and "leaders who are of underrepresented race/ethnicity in the U.S." by 0.5 percentage points in 2022 and two percentage points by the end of 2025, and publishes full workforce demographics by sex and U.S. race/ethnicity
March 30, 2022	The proxy statement announces that "quantitative performance objectives related to carbon emission reduction and diversity and equality-related measures will be a component of our executive annual cash incentive plan for 2022," and that the board "sets clear expectations that candidate slates should include women and candidates of underrepresented race/ethnicity"
April 2023	The 2022 ESG Report reports the goal overachieved — women leaders +1.5 points, leaders of underrepresented race/ethnicity in the U.S. +1.3 points — confirms the diversity objectives were "specified as components of the 2022 annual cash incentive plan for executives," and describes the women's leadership program, the Amplify alumni network, the APAC Women Mentoring Program and the Advancement of Women in Technology pilot
April 5, 2023	The proxy statement records the annual cash incentive as "Absolute EPS (70%) and Strategic ESG Goals (30%)" and states that the diversity and carbon objectives were incorporated "Beginning in 2022"
August 2023	Arrow begins an "enterprise-wide initiative to simplify the company's organizational structure"; the 2023 report later attributes the decline in women's leadership representation to it
March 2024	The 2023 ESG Report reports women's leadership representation down 0.78 points and underrepresented race/ethnicity leadership up 0.04 points, restates the multiyear aspiration to align leadership representation with overall employee representation, and lists "Growing a leadership talent pipeline for women and employees of underrepresented race/ethnicity groups through targeted development opportunities"
March 26, 2024	The proxy statement confirms the diversity-linked objectives "were components of our executive annual cash incentive plan for 2022 and 2023"
Jan. 21, 2025	Executive Order 14173 directs federal agencies to require contractors to certify that they do not operate DEI programs that violate federal anti-discrimination law
March 2025	The annual report is renamed the Corporate Stewardship and Impact 2024 Report. Workforce gender and race/ethnicity data, the representation goals and the DEI section are all absent. No explanation is given, and the 2025 goal is not mentioned
2025 proxy	The proxy statement for the May 2025 annual meeting describes the annual cash incentive as Absolute EPS (70%) and Strategic Goals (30%), with no diversity or ESG-diversity component. Board discussion shifts from demographic composition to "a variety of backgrounds, attributes, and experiences"
Feb. 2026	The 2025 Form 10-K adds a risk factor describing the January 2025 executive orders and the contractor certification requirement, and states that "certain of the company's business units contract or subcontract with U.S. government agencies"
March 2026	The Corporate Stewardship and Impact 2025 Report likewise contains no workforce demographic data and no representation goals
Aug. 2026	The CSR reporting index page and the careers DEI page both return 404. The 2021–2023 ESG PDFs remain live at their direct addresses. Verified August 2026

Why these practices matter legally

Two recent Supreme Court decisions changed the landscape for these claims. 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 (2025), a unanimous Court rejected the "background circumstances" rule — previously applied in several federal circuits — that had required majority-group plaintiffs to clear a higher evidentiary bar before a Title VII claim could proceed. Separately, 42 U.S.C. § 1981 prohibits race discrimination in the making and enforcement of contracts, including employment relationships, and carries a four-year window with no agency filing requirement. (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 practices the Department identified in the IBM matter are the categories this page uses as its framework: "using a diversity modifier that tied bonus compensation to achieving demographic targets"; altering "interview criteria based on race or sex through the use of 'diverse interview slates'"; developing "race and sex demographic goals for business units"; and offering "training, partnerships, mentoring, leadership development programs and educational opportunities only to certain employees, with eligibility, participation, access or admission limited on the basis of race or sex" (DOJ press release). In the Deloitte matter the government described, among other things, "non-public race and sex-based workforce composition goals for business units" and programs "where eligibility to participate was limited on the basis of race and sex" — the same shapes, documented in a second contractor. (False Claims Act, 31 U.S.C. §§ 3729–3733.)

Arrow Electronics' own 2025 Form 10-K states the parallel fact in its own words:

"Certain of the company's business units contract or subcontract with U.S. government agencies, and on January 21, 2025, the U.S. President issued certain executive orders imposing new requirements on federal contractors and subcontractors prohibiting certain 'diversity, equity, and inclusion' practices in employment, procurement, and contracting activities, and requiring a certification that the contractor or subcontractor does not operate diversity, equity, and inclusion programs that violate federal anti-discrimination laws."— Arrow Electronics, Inc., Form 10-K for the fiscal year ended December 31, 2025, Risk Factors (source)

To be clear about what is and is not established: no court or agency has found that Arrow Electronics' practices violated any law, and the IBM settlement itself resolved allegations without any admission or determination of liability. But practices like those documented above — a leadership representation target measured to the percentage point, executive bonus objectives tied to diversity measures, and development tracks described as being for women and for employees of underrepresented race/ethnicity, at a company whose business units sell to federal agencies — are precisely the categories that can give rise to liability under Title VII, § 1981 and, where federal certifications are involved, the False Claims Act.

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 Arrow Electronics?

If you worked at Arrow Electronics, Inc. — or applied there — between roughly 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 years when the company published a numeric target for the share of leadership positions held by women and by employees of underrepresented race/ethnicity, and reported its progress against that target annually.
• You applied for a role and never reached an interview, during a period when the company's stated recruiting objective was to "achieve diverse representation in our applicant and interview pools."
• You were not nominated for a leadership development program, mentorship or sponsorship track that the company described as being for women, or for the pipeline it described as being for "women and employees of underrepresented race/ethnicity groups."
• You were an executive, manager, recruiter or HR professional whose own bonus or scorecard carried the diversity objectives Arrow put into the 2022 and 2023 executive cash incentive plan — someone with first-hand knowledge of what the thresholds actually were, how attainment was measured, and what managers were told about them.
• You worked in or with immixGroup, immixTechnology, EC America or another Arrow business unit that sells to federal agencies, and know how the company's representations about its employment practices were made to the government.
• You were affected by the August 2023 "organizational simplification" and believe demographic considerations played a part in who was selected or retained.

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

What could a claim against Arrow Electronics 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.

Qui tam complaints are filed under seal, so the relator's identity is not disclosed to the defendant at the outset.

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 Arrow Electronics occupies at roughly 22,000 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. Several state civil-rights statutes are likewise uncapped, including Michigan's Elliott-Larsen Civil Rights Act. 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 $1.1 million jury judgment against the Michigan State Police, and a $460,000 reverse-discrimination settlement for three corrections officers. Prior results do not guarantee a similar outcome.

Class action potential

Class actions are built on a single policy applied to many people — and a companywide leadership representation target, published annually and measured to the percentage point, is by construction a single policy. So is a bonus plan objective carried by the executives who set promotion practice across the company. 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 promise of any outcome. The fastest way to learn where your situation falls is to start a confidential intake.

Sources