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

Published August 16, 2026 · Last updated August 21, 2026 · By Fett Law — Michigan Employment Discrimination Attorneys

JPMorgan Chase & Co., the largest U.S. bank, documented four categories of demographic employment practices in its own 2019–2023 reports: executive pay reviews tied to diversity progress, diverse-slate hiring expectations defined by sex and ethnicity, representation goals tracked on a scorecard, and programs aimed at specific racial groups. 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

Item	Detail
Company	JPMorgan Chase & Co. (NYSE: JPM), the largest U.S. bank by assets; roughly 300,000 employees worldwide
Federal nexus	Designated by the U.S. Treasury Department under a financial agency agreement (announced September 2023) to provide account-validation services for federal payments; also listed by Treasury as a provider of banking and payment services to federal agencies
Documents reviewed	10+ company-published documents, 2019–2025: ESG Reports 2019–2023, Sustainability Report 2024, Workforce Composition Disclosures 2020–2023, PwC Racial Equity Commitment Audit (2022)
Practices documented	(1) Executive pay evaluations tied to diversity progress; (2) diverse-slate hiring expectations defined by sex and ethnicity; (3) representation goals tracked via scorecard, plus a numeric Black-student hiring goal; (4) fellowship and sponsorship programs aimed at specific racial groups or one sex
Source-document status	All cited documents remain live on jpmorganchase.com (verified August 2026). JPMorgan Chase renamed its DEI policy to "Diversity, Opportunity and Inclusion" (DOI) in 2025 — it did not remove the record.

Did JPMorgan Chase tie executive pay to diversity targets?

The company first disclosed the link in its 2020 report:

"As part of these efforts, we are taking actions to build a more diverse workforce, including establishing an executive accountability framework, which strengthens the way we incorporate diversity and inclusion priorities and processes into year-end performance evaluations and compensation decisions for senior executives." — JPMorgan Chase 2020 Environmental, Social & Governance Report, p. 19 (source)

The 2021 report described the mechanism in more detail, including a scorecard:

"Our Accountability Framework, which was launched in 2020 and enhanced in 2021, is used to evaluate senior leaders, including Operating Committee members, on behaviors, practices and progress toward goals related to the Firm's diversity, equity and inclusion priorities, and to incorporate that into year-end performance and compensation assessments. The framework includes a scorecard for tracking progress toward representation goals." — JPMorgan Chase 2021 Environmental Social & Governance Report, p. 27 (source)

The same report's highlights page framed the commitment as holding executives accountable in pay:

"Build a more equitable and representative workforce and hold executives accountable by incorporating priorities and progress into year-end performance evaluations and compensation decisions for members of the Operating Committee and their direct reports." — JPMorgan Chase 2021 Environmental Social & Governance Report, p. 23

The 2022 report confirmed the framework was still operating: "Our Accountability Framework, which we continue to enhance over time since its launch in 2020, is used to evaluate senior leaders, including Operating Committee members, on behaviors, practices and progress toward goals related to the Firm's DEI priorities, and to incorporate that into year-end performance and compensation assessments." (2022 ESG Report, p. 40, source.)

In plain terms: for at least three performance years, the people who decided who got hired and promoted at JPMorgan Chase were themselves evaluated — with money at stake — partly on demographic "representation" progress in their organizations. When a manager's own year-end number depends in part on the demographic composition of their team, employees and applicants have a direct interest in how that pressure was applied to individual decisions.

Did JPMorgan Chase require diverse slates in hiring?

"To achieve diverse hiring and representation outcomes at all levels, diverse slates are an important consideration in our comprehensive recruiting efforts, and we track and monitor data about the use of diverse slates accordingly. In hiring new employees in the U.S., recruiters and managers are expected to consider a diverse slate of candidates of no less than one woman and one U.S. ethnically diverse candidate. Globally, diverse slates are defined as including no less than one woman." — JPMorgan Chase 2020 Environmental, Social & Governance Report, p. 21 (source)

The 2021 report repeated the policy and made the racial definition explicit:

"Diverse slates are an important consideration in our comprehensive recruiting efforts and are tracked and monitored by the Firm. In hiring new employees, managers and recruiters are expected to consider a diverse slate of candidates. Diverse slates are defined – in the U.S. – as no less than one woman and one ethnically diverse candidate (defined as Equal Employment Opportunity Commission classifications other than White) and – outside the U.S. – as including no less than one woman." — JPMorgan Chase 2021 Environmental Social & Governance Report, p. 30 (source)

By the 2022 report, the published description had been softened to race- and sex-neutral language — "we expect managers to consider a slate of candidates who bring a wide range of perspectives, experiences, and skill sets" (2022 ESG Report, p. 43) — an editorial change worth noting when dating how long the demographic definition was in effect.

For an applicant, a demographically defined slate expectation cuts both ways. Candidates outside the favored definitions may compete for fewer effective openings when a slate must be balanced; candidates inside them may be added to interview processes the employer never intended to be real. A proposed class action, Jackson v. JPMorgan Chase & Co. (E.D. Mich., filed December 15, 2025), alleges the second scenario: according to the complaint, a Black candidate with more than 20 years of experience was given a "perfunctory" interview for a managing director role — allegedly without his resume ever being requested — while a less experienced White candidate was hired. These are allegations, not findings; JPMorgan Chase has not responded publicly in the coverage cited. (HR Dive coverage.)

Did JPMorgan Chase set racial or gender representation goals?

"ABP is helping drive the firm's efforts to hire at least 4,000 Black students as apprentices, interns and full-time analysts by 2024; by the end of 2020, we were halfway to that goal." — JPMorgan Chase 2020 Environmental, Social & Governance Report, p. 20, describing the Advancing Black Pathways program (source)

Unlike some peer institutions, JPMorgan Chase did not publish firmwide numeric representation targets by job level. But its 2021 report states that the scorecard used in executive pay reviews tracked "progress toward representation goals" (2021 ESG Report, p. 27) — language indicating that internal goals existed and were being measured, even where their numeric values were not disclosed. The company also published annual Workforce Composition Disclosures from 2020 through 2023 breaking down gender and ethnicity at every level from the Board to the campus class; the 2023 edition reports, for example, that 67% of the U.S. campus and internship class identified as ethnically diverse (2023 Workforce Composition Disclosure).

Operationally, a numeric demographic hiring goal — like 4,000 Black students by 2024, reported as "halfway" complete — is a target someone is responsible for hitting. Employees who worked in recruiting or line management during this period may have first-hand knowledge of how those goals translated into individual hiring instructions.

Did JPMorgan Chase run programs restricted by race or sex?

"The ABP Fellowship program is aimed at helping Black college undergraduates get on a path to internships and entry-level roles with the Firm after graduation. In 2021, we grew the program to 169 students, up from 74 in 2020. Nearly 90% of the 2021 Fellows went on to accept internship offers with our Firm." — JPMorgan Chase 2021 Environmental Social & Governance Report, p. 27 (source)

The same report states that Advancing Hispanics & Latinos "prepared to launch the 2022 Fellowship Program, expanding fellowship opportunities offered by the Firm to Hispanic and Latino students" (p. 28). The 2022 report describes an "Executive Director ('ED') Sponsorship" program "designed for ED woman talent working at the Firm in Latin America and Canada" (2022 ESG Report, p. 46). The firm also organized identity-specific leadership structures — Asian, Black, Hispanic and LGBT+ Executive Forums and, from 2021, dedicated Centers of Excellence for particular demographic communities.

The legal significance of such programs turns on eligibility and benefit: a program whose participants are selected by race or sex, and which delivers a concrete employment advantage — here, a pipeline where nearly 90% of Fellows received internship offers — allocates opportunity by protected trait. Employees or students who were told a program "wasn't for them," or who administered these programs, may have relevant first-hand knowledge. (For balance: JPMorgan Chase has described its Business Resource Groups as "inclusive groups" open broadly, and the fellowship programs' formal eligibility terms are not spelled out in the ESG reports themselves.)

How JPMorgan Chase's DEI program changed, 2019–2026

Year	Development
2019	Advancing Black Pathways launches; DEI disclosure appears within the annual ESG report series
2020	Executive Accountability Framework established, linking diversity progress to senior-executive pay reviews; diverse-slate expectations published with sex/ethnicity definitions; 4,000-Black-student hiring goal disclosed as "halfway" met; $30 billion Racial Equity Commitment announced; Global Head of DEI role created; Workforce Composition Disclosure series begins
2021	Accountability Framework "enhanced" and extended to more senior leaders; scorecard tracks "representation goals"; ABP Fellowship grows to 169 students (≈90% to internships); three new demographic Centers of Excellence launch (Advancing Hispanics & Latinos, Asian & Pacific Islander Affairs, LGBT+ Affairs)
2022	Accountability Framework continues per the 2022 report; published slate language drops demographic definitions; PwC completes independent Racial Equity Commitment audit (Nov. 22, 2022)
2023	2023 ESG Report retains a named "Diversity, Equity and Inclusion" chapter (p. 53); final standalone Workforce Composition Disclosure published (2023 data)
Jan. 2025	Executive Order 14173 targets DEI programs at federal contractors
Mar. 2025	Internal memo (reported Mar. 24, 2025) renames DEI to "Diversity, Opportunity and Inclusion" (DOI); "equity" removed from web pages; COO Jennifer Piepszak: "the 'e' always meant equal opportunity… not equal outcomes"
Oct. 2025	Renamed "Sustainability Report 2024" published ~6 months later than the historical spring cadence — no named DEI chapter (now "Human Capital"); standalone workforce disclosure discontinued and folded into an appendix
Dec. 2025	Jackson v. JPMorgan Chase & Co. (E.D. Mich.) filed, alleging sham diversity interviews of Black candidates (allegations, not findings)
2026	Full report archive remains live on jpmorganchase.com; the current company page, retitled "Diversity, Opportunity and Inclusion," still lists seven identity-specific "Affairs" offices and ten business resource groups

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 (2025), the Court unanimously rejected the rule that majority-group plaintiffs must meet a higher evidentiary bar to bring discrimination claims. Separately, 42 U.S.C. § 1981 prohibits race discrimination in the making and enforcement of contracts — including employment relationships — and carries its own four-year window with no agency filing requirement. (Statutes: Title VII, § 1981.)

For federal contractors, a second layer arrived on April 10, 2026, when 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 diversity-linked bonus compensation, diverse interview slates, demographic goals for business units, and race- or sex-restricted access to training and leadership programs (DOJ press release). Those four categories parallel the four practice categories documented in JPMorgan Chase's own reports. The parallel fact on the nexus side: J.P. Morgan announced in September 2023 that it had been "designated by the United States Treasury Department under a financial agency agreement" to provide account-validation services for federal payments (announcement), and Treasury's Financial Management Marketplace lists JPMorgan Chase Bank, N.A. as a provider of banking and payment services to federal agencies.

To be clear about what is and is not established: no court or agency has found that JPMorgan Chase's practices violated any law, and the IBM settlement itself resolved allegations without an admission of liability. But practices like those documented above — pay tied to demographic progress, demographically defined slates, numeric race-specific hiring goals, and race- or sex-targeted programs — 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 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 JPMorgan Chase?

If you worked at JPMorgan Chase — or applied there — between 2019 and 2025, the documented practices above may have touched your career in ways worth examining:

• You were passed over for a hire or promotion while managers were being evaluated, with pay at stake, on demographic representation in their organizations.
• You interviewed but sensed the process wasn't real — or were slotted into an interview to satisfy a slate expectation rather than considered on your merits.
• You were excluded from a fellowship, sponsorship, or pipeline program — or told it wasn't for you — because of your race or sex.
• You were a manager, recruiter, or HR professional with first-hand knowledge of how representation goals, slate tracking, or the Accountability Framework scorecard were actually implemented.

Because JPMorgan Chase does 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 JPMorgan Chase 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 in the case, 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. And 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 JPMorgan Chase 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 definition for U.S. hiring, one Accountability Framework covering senior leaders across the firm, demographically defined programs operating at scale. A proposed class action, Jackson v. JPMorgan Chase & Co. (E.D. Mich., filed December 2025), is already pending on related allegations. Historic employment-discrimination class settlements show the scale 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 or request a free consultation.

Sources

All JPMorgan Chase documents below were live on jpmorganchase.com when this page was published; page citations refer to the PDF as published.

• JPMorgan Chase, 2020 Environmental, Social & Governance Report (pub. 2021) — PDF
• JPMorgan Chase, 2021 Environmental Social & Governance Report (pub. Apr. 19, 2022) — PDF
• JPMorgan Chase, 2022 Environmental Social Governance Report (pub. 2023) — PDF
• JPMorgan Chase, 2023 Environmental Social Governance Report — PDF
• JPMorgan Chase, Sustainability Report 2024 (pub. Oct. 2025) — PDF
• JPMorgan Chase, Workforce Composition Disclosures, 2020–2023 data years — 2020 · 2021 · 2022 · 2023
• PwC, 2022 Racial Equity Commitment Audit Report (Nov. 22, 2022) — PDF
• JPMorgan Chase, "Diversity, Opportunity and Inclusion" (current company page) — link
• U.S. Department of Justice, "IBM Pays $17 Million to Resolve Allegations of Discrimination Through Illegal DEI Practices" (Apr. 10, 2026) — press release
• J.P. Morgan, "J.P. Morgan to Provide Account Validation Services to the U.S. Government" (Sept. 27, 2023) — announcement; U.S. Treasury FM QSMO Marketplace listing — link
• HR Dive, "JPMorgan conducted 'fake' interviews of Black candidates, lawsuit alleges" (Dec. 2025), re Jackson v. JPMorgan Chase & Co. (E.D. Mich.) — article
• HR Dive, "JPMorgan trades DEI for 'DOI'" (Mar. 2025) — article
• Title VII, 42 U.S.C. § 2000e-2 — statute; 42 U.S.C. § 1981 — statute; False Claims Act, 31 U.S.C. §§ 3729–3733 — statute