Northrop Grumman'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 Northrop Grumman tie executive pay to diversity targets?

Northrop Grumman described the linkage before it became a formula. Its 2019 Sustainability Report lists among the company's governance practices:

"The incorporation of non-financial ESG performance metrics into our annual incentive compensation program. These metrics include quality, customer satisfaction, engagement and inclusion, operational efficiency, diversity, environmental sustainability and safety."

— Northrop Grumman, 2019 Sustainability Report, p. 7 (source)

The same report states who reviewed it:

"Diversity is one of the company's non-financial ESG performance metrics and is reviewed by the Compensation Committee of the Board of Directors."

— Northrop Grumman, 2019 Sustainability Report, p. 19 (source)

Northrop Grumman repeated that sentence to the Securities and Exchange Commission, in the Human Capital section of its Form 10-K, for three consecutive fiscal years — 2020, 2021 and 2022:

"Diversity is one of the company's non-financial ESG performance metrics and is reviewed by the Board of Directors."

— Northrop Grumman Corporation, Form 10-K for fiscal year 2020, filed January 28, 2021, Item 1, Human Capital, "Diversity, Equity and Inclusion" (source); the identical sentence appears in the fiscal 2021 and fiscal 2022 Forms 10-K

In February 2022 the arrangement became a weighted formula, disclosed to shareholders in a Form 8-K filed after the Compensation Committee approved that year's incentive goals:

"The financial metrics selected for inclusion in the ICP (and their relative weightings) are as follows: cash flow from operations before discretionary pension funding (35%); segment operating income growth (35%); adjusted operating margin rate* (20%); and non-financial metrics (10%). The non-financial metrics in the ICP are: People (diversity, equity & inclusion and employee experience), Environment (environmental sustainability), and Customer (quality and customer satisfaction)."

— Northrop Grumman Corporation, Form 8-K, Item 5.02, event date February 15, 2022, filed February 18, 2022 (source). Emphasis added. The identical language was filed again for the 2023 plan year on February 17, 2023

The company's proxy statements print the same structure in a summary box headed "Non-financial Metrics in Annual Incentives," with "People" resolving to "Diversity | Employee Experience | Safety" in the 2022 proxy and "Diversity | Employee Experience" in the 2023 and 2024 proxies. The proxy introduces it this way: "To reinforce these commitments we include related non-financial metrics in our executive compensation program" (2022 Proxy Statement, p. 7).

What the proxies do not say, the sustainability reports do. Northrop Grumman published both the weighting and — unusually for this series — the definition of the diversity metric itself. On the weighting:

"In February 2022, we revised our annual incentive plan design to include non-financial metrics in our core metrics… The non-financial metrics account for 10% of the overall 2022 annual incentive plan score and include specific metrics for performance across ESG topics."

— Northrop Grumman, 2022 ESG Report, p. 10 (source). Emphasis added. The 2023 Sustainability Report, p. 12, repeats it for the following year: "The non-financial metrics account for 10% of the overall 2023 annual incentive plan score"

And on what the diversity metric actually measured — the single most consequential line in Northrop Grumman's published record:

"Representation of females and people of color in all management level positions with respect to internal and external benchmarks."

— Northrop Grumman, 2022 ESG Report, p. 27, definition of the "Diversity" non-financial incentive metric (source); the same definition appears in the 2023 Sustainability Report, p. 12 (source)

What this meant in practice. For the executives covered by Northrop Grumman's annual incentive plan in 2022 and 2023, a tenth of the plan score turned on a block of non-financial measures, and one of those measures moved with the share of women and people of color holding management positions. Executives paid on that basis set the priorities that reach the recruiters, hiring managers and business-unit leaders who make individual hiring and promotion decisions. What Northrop Grumman has never published is the numeric benchmark the metric was scored against, how many points the diversity component carried inside the 10%, or whether any similar measure reached managers below the executive level. Those are internal documents. The people who were scored on them know what they said.

The metric was renamed, not removed. The February 2024 Form 8-K calls it "Diversity, Inclusion and Belonging" — "equity" dropped. The February 19, 2025 Form 8-K calls it "Inclusion and Belonging" — "diversity" dropped. The February 13, 2026 Form 8-K restructures the plan around "strategic performance metrics" worth 30%, of which one is "Belonging." Across all of it, the 10% non-financial weighting held constant from 2022 through 2025. The words changed; the mechanism stayed.

Did Northrop Grumman require diverse slates in hiring and promotion?

Northrop Grumman stated the practice in its own report, in the talent-acquisition section:

"We ensure a diverse slate of candidates is considered for all Northrop Grumman leadership opportunities."

— Northrop Grumman, 2020 Sustainability Report, p. 19 (source)

The most specific description of how the practice operated comes from Northrop Grumman personnel speaking on the record. In an interview published by the Economic Development Corporation of Utah on July 5, 2021, Kerri Harris, identified as a Manager, HR Business Partner at Northrop Grumman, described the requirement in operational terms:

"For any manager role (and higher), we create a diverse slate of candidates before we begin the interview process."

"We also require diverse interview panels to ensure varied perspectives in the hiring process."

— Kerri Harris, Manager, HR Business Partner, Northrop Grumman, in "Diversity in the Workplace: A Conversation with Northrop Grumman," Economic Development Corporation of Utah, July 5, 2021 (source)

A second Northrop Grumman HR professional in the same interview described the measurement cadence:

"We measure our progress quarterly. We are always looking for ways to improve representation."

— Iris Lovell, Senior Principal, HR Business Partner, Northrop Grumman, same interview (source)

One limit on the record should be stated plainly, because it cuts both ways. Slate language appears in Northrop Grumman's own published reports only in the 2020 edition; we did not find it in the 2019, 2021, 2022 or 2023 reports, and the phrase "diverse slate" appears in no Northrop Grumman SEC filing at all. The July 2021 interview is a statement by named company employees hosted on a third party's website — which is very likely why it survived when the company's own diversity pages came down. It is evidence of the practice, not of its duration.

What this meant in practice. If a requisition for a manager-level or leadership role could not move to interviews until the candidate pool satisfied a demographic condition, then the composition of the slate — not only the merits of each candidate — was part of what determined who reached an interview and who did not. A published slate practice does not by itself decide any individual case. What matters legally is whether the demographic condition changed an actual decision. The recruiters, HR business partners and hiring managers who built those slates and sat on those panels are the people best placed to know.

Did Northrop Grumman set racial or gender representation goals?

The 2019 report announces the close of one goal cycle in its highlights:

"We met our 5-year employee diversity goals in 2019, and since 2010, have achieved significant progress"

— Northrop Grumman, 2019 Sustainability Report, p. 2, "2019 Highlights — People" (source)

The body of the same report names the plan and reports the movement it produced:

"In 2019, the final year of our 2015–2019 diversity plan, we recorded growth in almost all areas. Since 2010, the representation of females increased at the Vice President level and above from 16% to 33% and at the entry- and mid-level management level from 22% to 28%. Also since 2010, representation of People of Color increased at the Vice President level and above from 11% to 18% and at the entry- and mid-level management level from 19% to 29%."

— Northrop Grumman, 2019 Sustainability Report, pp. 18–19 (source). Emphasis added

The next cycle began immediately:

"in 2020, we established our third set of five-year diversity goals."

— Northrop Grumman, 2020 Sustainability Report, p. 1 (source). Emphasis added

Northrop Grumman published the results those cycles produced, by level, year after year. Its Forms 10-K reported that "[a]cross our U.S. employee population, as of December 31, 2022, 25 percent are female, 37 percent are people of color, 18 percent are veterans and 8 percent are persons with disabilities," and that "[a]t the vice president level, 34 percent are female and 19 percent are people of color" (fiscal 2022 Form 10-K, Item 1). The 2023 Sustainability Report reported 25% women and 38% employees of color companywide, and 35% female and 20% people of color at vice president level and above (p. 31), along with a breakdown of that year's 14,500 external hires — "3,300 Women," "6,200 People of Color."

One distinction matters and we state it plainly. Northrop Grumman published the existence of the goals, the groups they named, the levels they applied to, the cadence at which they were reviewed, and the results achieved — and it published that the incentive metric was scored against internal and external benchmarks. It never published the benchmark values or the target percentages. Those numbers, if they exist in writing, sit in internal goal-setting and scorecard documents rather than in any public report.

Did Northrop Grumman run programs restricted by race or sex?

The 2020 Sustainability Report records participation in a named leadership program:

"69 participants completed our Women in Leadership program."

— Northrop Grumman, 2020 Sustainability Report, p. 21 (source). Emphasis added

The same report describes a selection process for the company's ninth annual Women's Conference in which "400+ women were selected" (p. 24). The 2022 ESG Report describes a program organized around a named ethnic and sex-defined population:

"the Adelante ERG launched a working group for Latina women and their allies. Known as the Mujeres Initiative, the group has piloted a LatinX and Hispanic Employee Advocacy Program, known as Mujeres Circles"

— Northrop Grumman, 2022 ESG Report, p. 29 (source). Emphasis added

Northrop Grumman also reported a large employee-resource-group structure organized around protected characteristics — "more than 24,000 employees" in "12 Employee Resource Groups with 260+ chapters" in 2019, growing to 14 groups, 280 chapters and more than 30,000 members by 2023, including the African American Task Group, the Asian Pacific Professional Network and Adelante, each with executive sponsorship.

We state the limit of this category honestly. In the IBM and Deloitte matters the Justice Department described programs "where eligibility to participate was limited on the basis of race and sex." Northrop Grumman published no program terms of that kind. What it published is a set of programs it named and described by the sex or ethnicity of the people in them, a selection process for one of them, and executive sponsorship attached to groups organized by protected characteristic. Whether those descriptions reflected who happened to join, or a rule about who could, is not something the public documents settle. The employees who administered nominations and selections for Women in Leadership, the Women's Conference and the Mujeres programs would know.

Which Northrop Grumman DEI documents disappeared from its website?

Verified in August 2026:

• northropgrumman.com/corporate-responsibility/diversity-equity-and-inclusion — 404 Not Found
• northropgrumman.com/esg/diversity-equity-and-inclusion — silently resolves to the corporate homepage; no 404, no DEI content
• northropgrumman.com/esg/diversity-equity-and-inclusion/building-our-diverse-team — now /corporate-responsibility/belonging/building-our-team, retitled "Building Our Team." The DEI narrative is gone; EEO demographic charts for 2022, 2023 and 2024 remain, embedded as images
• The sustainability-reports index — live, but pruned to 2025 documents only. The 2019 through 2024 reports quoted throughout this page are delinked from the site while remaining downloadable at their original file addresses
• The successor page, /corporate-responsibility/belonging — live, with no representation goals, no slate practice and no targets

The cleanest record of the change is in Northrop Grumman's SEC filings, because they are dated and immutable. The Form 10-K filed January 25, 2024 contains a Human Capital subsection headed "Diversity, Equity and Inclusion" reporting that "as of December 31, 2023, 25 percent are female, 38 percent are people of color, 18 percent are veterans and 8 percent are persons with disabilities," and stating that the company strives "to reach all parts of the diverse talent pools available now and in the future." In the Form 10-K filed January 30, 2025, that heading does not exist. The Human Capital subsections are "Our Values and Culture," "Talent Management," "Employee Health and Safety" and "Collective Agreements." The workforce demographics are gone, and "diverse talent pools" has become "broadening talent pools."

Six days before that filing, on January 24, 2025, Northrop Grumman published a statement headed "Company Statement: Presidential Executive Orders (DEI)":

"We are actively reviewing our policies and processes and taking the necessary steps to ensure compliance with the Presidential Executive Orders for the work entrusted to us… Underpinned by our values, we hire, promote and pay based on merit and performance resulting in the best team to deliver for our customers."

— Northrop Grumman, "Company Statement: Presidential Executive Orders (DEI)," January 24, 2025 (source)

The pattern was not unique to Northrop Grumman. A February 2025 trade-press report described it across the sector: "Major defense primes are scrubbing their websites to remove references to DEI… Breaking Defense found that large defense companies like BAE Systems, General Dynamics, L3Harris, Lockheed Martin, Northrop Grumman and RTX have clumsily removed webpages associated with previous DEI initiatives, which still appear in search engine results but redirect to dead links" (Breaking Defense, February 2025).

If any part of your own situation depends on what these reports said, download the PDFs linked in the Sources section rather than bookmarking them. Files that are already unreachable by navigating the site are one configuration change away from being unreachable altogether.

How Northrop Grumman's DEI program changed, 2019–2026

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 (June 5, 2025), a unanimous Court rejected the "background circumstances" rule — previously applied in several federal circuits — that 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.

That second theory — public representations of compliance, and cost allocation to federal contracts — is why a contractor's own published reporting is part of the picture rather than mere background. Northrop Grumman Corporation is among the largest federal contractors in the United States: its fiscal 2025 Form 10-K states that sales to the U.S. government accounted for 84% of sales, and the Congressional Research Service ranks it fourth among Department of Defense contractors at $18.6 billion in FY2024 obligations. The contracting environment tightened twice in that period. Executive Order 14173 (January 21, 2025) requires contractors to certify that they do not operate DEI programs violating federal anti-discrimination law and makes that compliance "material to the government's payment decisions for purposes of section 3729(b)(4)" of the False Claims Act. Executive Order 14398 (March 26, 2026) goes further, requiring a contract clause under which the contractor agrees it "will not engage in any racially discriminatory DEI activities." Whether any Northrop Grumman entity made certifications of that kind in a given period, and what they said, is a fact-specific question the public record does not settle.

A government settlement resolves only the government's claims. The executed Deloitte agreement is explicit about its own limits: it reserves the EEOC's right to pursue "any pending or future charge," including charges "which may allege the same covered conduct described in this Agreement" (¶ 5(d)); it reserves "[a]ny liability of individuals" (¶ 5(g)); and it reserves administrative liability including suspension and debarment (¶ 5(c)). Nothing about either settlement compensated a single employee or applicant.

To be clear about what is and is not established: no court or agency has found that Northrop Grumman Corporation's practices violated any law, we located no discrimination charge, EEOC action, OFCCP enforcement matter or False Claims Act case concerning its DEI practices, and both settlements described above resolved allegations without any admission or determination of liability. But practices like those documented in Northrop Grumman's own reports — an incentive metric scored on the representation of women and people of color in management, a stated diverse-slate practice for manager-level and leadership roles, successive representation goal cycles, and development programs described by the sex and ethnicity of their participants — are precisely the categories that can give rise to liability under Title VII and § 1981, and, for federal contractors, to 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 Northrop Grumman?

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

• You were passed over for a manager-level or leadership role during a period when the company said it created a diverse slate of candidates before the interview process began.
• You applied and never reached an interview for a leadership opening, and cannot account for it against your record.
• You were an executive whose annual incentive score carried the diversity metric — someone who knows what benchmark it was scored against, how many points it was worth inside the 10%, and what was communicated downward about hitting it.
• You were a recruiter, HR business partner or hiring manager who built those slates, sat on those interview panels, or reported the quarterly representation numbers. The company said it measured progress quarterly; the people who produced those numbers know how they were produced.
• You were not nominated for Women in Leadership, the Women's Conference, or the Mujeres programs — or you were, and know how participants were selected.
• You worked on Northrop Grumman's federal contracts and have first-hand knowledge of what the company certified about its employment practices, or how the costs of those practices were charged.
• You were slotted into an interview for a role that was already decided, to satisfy a slate requirement. Slate rules injure the candidates they nominally favor too.

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.

There is a separate question worth asking if your work touched Northrop Grumman's government 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 in both settlements above. 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.

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 Northrop Grumman 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.

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 Northrop Grumman occupies with approximately 95,000 — 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 and California's Fair Employment and Housing Act, both of which govern parts of Northrop Grumman'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 $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 practice of building a demographically defined slate for every manager-and-above requisition is, by construction, companywide. So is an incentive metric measured on the representation of women and people of color across all management levels. 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 or request a free consultation.

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