NCR Voyix'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

Between 2020 and 2024, NCR Voyix Corporation — known as NCR Corporation until October 2023 — published documents describing diversity, equity and inclusion practices that reached executive pay, recruiting and employee development. Its own proxy statement told shareholders that 2021 bonus payouts moved on "our DEI initiative results," and its annual reports describe a "university diversity network to attract, hire, and grow diverse talent" and a mentoring initiative "designed to support the development of women across NCR." Through its subsidiary NCR Government Systems LLC, the company holds federal contracts, including a $335 million Defense Department award announced in January 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, and a $21.5 million Deloitte settlement in August 2026.

Key facts

Did NCR Voyix tie executive pay to diversity results?

The 2022 proxy statement describes the change in the company's own words:

"New for 2021, we added to our Annual Incentive Plan a +/- 20 percent “Stakeholder Metrics” Modifier, consisting of ESG goals (+/- 10%) and NPS goals (+/- 10%)." NCR Corporation, 2022 Proxy Statement (DEF 14A), filed March 22, 2022

The same proxy identifies what the modifier turned on. The Stakeholder Metrics Modifier could increase or decrease 2021 bonus payouts by 20 percent based on:

"our ESG performance, our NPS performance, our Employee NPS performance, our DEI initiative results, our Sustainalytics Information Security Score, and the publication of our greenhouse gas emissions with forward-looking reduction goals." NCR Corporation, 2022 Proxy Statement (DEF 14A), filed March 22, 2022

Supplemental proxy materials the company filed with the SEC in April 2022 itemize the ESG targets inside that modifier. One of them is described by reference to a demographic group:

"ESG stakeholder targets (+/- 10% modifier) include establishing a diverse supplier program; launching a key talent initiative designed to engage, develop and retain key employees, with an emphasis on traditionally underrepresented groups; improving the Company's Sustainalytics score; commencing greenhouse gas emissions reporting; implementing a leadership development program for key talent; and launching a baseline measurement of eNPS" NCR Corporation, Additional Proxy Soliciting Material (DEFA14A), filed April 12, 2022

For the following year the company strengthened the arrangement rather than dropping it. The 2023 proxy statement states:

"In 2022, we have strengthened our commitment to meeting our ESG goals by shifting the annual incentive payout modifier to independent, stand-alone metrics for ESG and NPS performance (instead of a modifier) representing 10 percent of the final 2022 annual incentive payout for each category (combined ESG and NPS goals weighted 20% in the aggregate)." NCR Corporation, 2023 Proxy Statement (DEF 14A), filed March 22, 2023

"ESG goals include measures related to employee satisfaction (eNPS), workforce diversity reporting, data privacy and security program performance and GHG emissions reporting and reduction commitments." NCR Corporation, 2023 Proxy Statement (DEF 14A), filed March 22, 2023

The same proxy discloses the end of the arrangement: "For 2023, the AIP will be entirely focused on meeting rigorous financial and customer performance requirements."

What this meant in practice. For the 2021 and 2022 performance years, an NCR executive's cash bonus was measured, in part, against how the company performed on diversity. The company's published wording matters here in both directions. The 2022 metric it named was "workforce diversity reporting" — a disclosure measure, not a headcount outcome — and the page does not claim otherwise. But the 2021 modifier was tied to "our DEI initiative results" without qualification, and the itemized target list includes a talent initiative defined by "an emphasis on traditionally underrepresented groups." What those results were scored on, and whether any of it touched individual hiring or promotion decisions, are not answered by the public filings. They would be known to the executives who were measured and to the human-resources staff who did the measuring.

Sources: 2022 DEF 14A · April 12, 2022 DEFA14A · 2023 DEF 14A.

Did NCR Voyix require diverse slates in hiring and promotion?

The recruiting pipeline appears first as a plan and then as an operating program. In the fiscal 2021 and fiscal 2022 annual reports, under the DE&I roadmap:

"Launching a university diversity network to attract, hire, and grow diverse talent" NCR Corporation, Annual Report on Form 10-K for fiscal 2021 and fiscal 2022, Human Capital Resources

By the fiscal 2024 annual report it is described as something the company runs:

"Our targeted university diversity network to attract, hire, and grow diverse talent through key partnerships" NCR Voyix Corporation, Annual Report on Form 10-K for fiscal 2024, filed February 27, 2025, Human Capital Management

At the board level, the company was explicit about seeking candidates by sex and race:

"Our Board is committed to actively seeking women and minority director candidates for consideration." NCR Corporation, 2022 Proxy Statement (DEF 14A), filed March 22, 2022

What this meant in practice. A recruiting network organized around "diverse talent" is a sourcing decision, and sourcing sits upstream of hiring. The filings never define "diverse," never state an eligibility rule, and never describe a requirement that any particular slate contain candidates of any particular race or sex. That distinction is legally meaningful: widening where an employer looks is generally lawful, while conditioning who gets considered or chosen on race or sex is where Title VII problems begin. Which of those was actually happening inside NCR's recruiting process is not something a 10-K answers. Recruiters, hiring managers and university-relations staff would know.

Sources: FY2021 Form 10-K · FY2022 Form 10-K · FY2024 Form 10-K.

Did NCR Voyix set racial or gender representation goals?

When NCR published its first ESG reports on March 31, 2022, the company framed its demographic data as a starting point rather than a commitment. Its chief human resources officer said:

"Our 2021 employee demographic data gives us a benchmark so we can continue to develop a more inclusive culture and improve our global diversity." Patrice Graves, Chief Human Resources Officer, NCR Corporation, "NCR Commits to Net Zero Emissions and Provides Diversity Baseline Metrics in Inaugural Environmental, Social and Governance (ESG) Reports," March 31, 2022

The figures the company published, as of November 30, 2022, were: "24% of our global workforce self-identify as women"; "42% of our U.S. workforce self-identify as ethnically and/or racially diverse"; and "28% of our U.S. management positions are held by people who self-identify as women." No goal is attached to any of them in the documents reviewed.

On November 20, 2023, the shareholder advocacy group As You Sow filed a resolution asking for more. Its resolved clause reads:

"Shareholders request that NCR Voyix report to shareholders on the effectiveness of the Company's diversity, equity, and inclusion efforts." As You Sow, "NCR Voyix: Disclosure of Key Diversity and Inclusion Metrics," filed November 20, 2023, 2024 annual meeting

The proposal states the reason: "As of this proposal's filing date, NCR had not yet released its consolidated EEO-1 form, nor had it shared sufficient hiring, retention, or promotion data." The resolution's status is recorded as "Resolution Withdrawn, Agreement Reached." No consolidated EEO-1 report has appeared since, and the 2024 and 2025 proxy statements contain no workforce demographic figures at all.

What this meant in practice. The absence of a published target is not the absence of a program. NCR's bonus plan measured "workforce diversity reporting" in 2022, and its 2021 modifier turned on "DEI initiative results" — so the company was scoring itself on something. What it was scoring, and against what internal numbers, is precisely what its public documents do not say. Internal dashboards, scorecards and representation reports of the kind that exist at most large employers would answer the question. Employees who saw those materials hold information the public record does not.

Sources: March 31, 2022 ESG announcement · 2023 DEF 14A · As You Sow resolution.

Did NCR Voyix run programs restricted by race or sex?

The clearest example, from the fiscal 2022 annual report:

"Launched a mentoring initiative led by our Women in NCR (WIN) Business Resource Group designed to support the development of women across NCR" NCR Corporation, Annual Report on Form 10-K for fiscal 2022, Human Capital Resources

From the fiscal 2021 annual report:

"Completed a Mentorship Program led by our Black Professionals Forum Business Resource Group designed to provide professional guidance and career coaching" NCR Corporation, Annual Report on Form 10-K for fiscal 2021, Human Capital Resources

And the sponsorship commitment, which appears as a roadmap item in fiscal 2021 and fiscal 2022 and as an operating program in fiscal 2024:

"Development of diverse talent through sponsorship initiatives and targeted development" NCR Voyix Corporation, Annual Report on Form 10-K for fiscal 2024, filed February 27, 2025, Human Capital Management

What this meant in practice. Sponsorship is not mentoring. A sponsor advocates for someone in the rooms where promotions and assignments are decided — which is why the Justice Department's recent settlements have treated sponsorship programs as employment decisions rather than as networking. A program described as being for the development of women, or for "diverse talent," signals to everyone else that it is not for them, whether or not a written rule says so. Employees who applied and were turned away, or who understood they should not apply, know something the filings do not record.

Sources: FY2021 Form 10-K · FY2022 Form 10-K · FY2024 Form 10-K.

How NCR Voyix's DEI program changed, 2019–2026

This timeline is built from the company's own published documents and from checks of its live web pages. Where a later document no longer states something an earlier one did, the change is described as it appears — NCR Voyix has not, in the documents reviewed, published an explanation of when or why the DEI language was removed.

Why these practices matter legally

Title VII. 42 U.S.C. § 2000e-2 makes it unlawful to discriminate in hiring, promotion, compensation, or terms and conditions of employment because of race, color, religion, sex or national origin. The statute protects every employee, not only members of historically underrepresented groups.

Muldrow (2024). The Supreme Court held that a plaintiff challenging a discriminatory job transfer need show only some harm to a term or condition of employment, not a "significant" or "material" disadvantage. Exclusion from a leadership pipeline, a sponsorship program or a promotion track is the kind of injury that reasoning now reaches.

Ames (2025). In a unanimous decision, the Court struck down the "background circumstances" rule that some courts had used to require majority-group plaintiffs to make an extra showing before their claims could proceed. Read the opinion.

Section 1981. 42 U.S.C. § 1981 prohibits race discrimination in the making and enforcement of contracts, including employment. It requires no EEOC charge, has a four-year limitations period, and carries no statutory damages cap. That matters more than usual for a company headquartered in Georgia, which has no general fair-employment statute covering private-sector employees — federal law does the work.

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. The practices the government described included a "diversity modifier that tied bonus compensation to achieving demographic targets," "diverse interview slates," "race and sex demographic goals for business units," and programs limited by "race or sex."

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.

What a government settlement does not do. It releases the United States' claims and nothing else. The Deloitte agreement expressly reserves "any currently pending or future charges filed with the Equal Employment Opportunity Commission," and states that this "includes charges which may allege the same covered conduct described in this Agreement." It separately reserves "any liability of individuals," and administrative remedies including suspension and debarment. An individual's own claims are untouched by any of it.

The parallel fact for NCR Voyix Corporation is its federal-contractor status. Its subsidiary NCR Government Systems LLC holds GSA Schedule contract GS-35F-0082V and won a $335 million, five-year Defense Information Systems Agency award announced in January 2025 — while the DEI programs described above were still being reported in the company's annual filings. Whether that combination creates exposure for any particular company depends on the certifications it actually made and the practices actually in place — questions no public document answers by itself. 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 NCR Voyix?

The documents above describe systems, not individual decisions. Whether anything unlawful happened to you turns on facts only you and your records hold. These situations are worth a conversation:

• You were passed over for a promotion or a leadership role at NCR or NCR Voyix between roughly 2020 and 2025, in an organization whose executives were being scored on DEI results.
• You were not selected through the university recruiting pipeline, or you saw how candidates were sourced and screened through the "university diversity network."
• You wanted into a mentoring or sponsorship program — the WIN mentoring initiative, the Black Professionals Forum mentorship program, or "targeted development" for diverse talent — and were told it was not for you, or understood that without being told.
• Your own bonus moved with the Stakeholder Metrics modifier or the ESG metric in 2021 or 2022 — you know what you were asked to deliver and how "DEI initiative results" were actually scored.
• You are a manager, recruiter or HR professional who saw the internal diversity dashboards, the scorecards behind the ESG metric, or how candidate pools were built.
• You raised a concern about any of this and something happened to you afterward — a rating, a reassignment, a layoff, a termination.

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.

A consultation costs nothing and is confidential. If NCR Voyix Corporation certified compliance with anti-discrimination requirements in its federal contracts while these practices operated, an insider with first-hand knowledge may also hold a False Claims Act whistleblower claim — those complaints are filed under seal, so the employer is not told while the government investigates, and a relator who succeeds can receive 15–30% of the government's recovery. Title VII and the False Claims Act both prohibit retaliation against people who assert these rights or report concerns.

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 NCR Voyix be worth?

False Claims Act whistleblower rewards

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.

Damages in individual discrimination cases

Back pay and front pay are uncapped under Title VII. Compensatory and punitive damages are capped by employer size — $50,000 for employers with 15–100 employees, $100,000 for 101–200, $200,000 for 201–500, and $300,000 for employers with more than 500 employees, which is where a company the size of NCR Voyix sits. 42 U.S.C. § 1981 has no damages cap at all, which is why race claims are frequently pleaded under it. Many state statutes are also uncapped — Michigan's Elliott-Larsen Civil Rights Act among them. Prevailing plaintiffs generally recover attorney's fees on top.

For scale, prior results obtained by this firm include a $10.5 million race and age discrimination class action against Ford Motor Company, a $2 million disability harassment and retaliation result, a $1.6 million racially hostile work environment result, and a $1.1 million jury judgment against the Michigan State Police. Prior results do not guarantee a similar outcome.

Class action potential

One policy applied to many employees is what class actions are built on. Where a single compensation metric, a single recruiting pipeline, or a single program-eligibility practice reaches an entire population of employees, the common question that makes a class viable is already present. Historic employment-discrimination class recoveries give the scale: Coca-Cola settled for $192.5 million in 2000, Texaco for $176.1 million in 1996, and Novartis for $175 million in 2010.

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

Sources