From proxy statements to 10-K’s and investor relations websites to ESG reports, Labrador announced that 2023 has had the highest levels of transparency across the board. The communications and design firm analyzed disclosures of the S&P 250 companies to rank companies based on accessibility, precision, comparability, availability, and clarity. Many Center members received awards, including Boston Scientific, Verizon, Target, GE, AIG, Procter & Gamble and TE Connectivity.
Highlights of the report include:
Proxy Statement
- The average length of S&P 250 proxies is now 103 pages long. This has driven increased need for full-page tables of contents (48%) and interactive, hyperlinked navigation (14%).
- More than three-quarters (78%) of companies now include an ESG highlights section, averaging 3.4 pages, in the proxy. This is a considerable increase from a few years ago, when these were typically only seen in the CSR report. About 87% of companies present board diversity statistics.
- The new SEC-mandated pay versus performance disclosure averages 3.8 pages in length and is almost always located next to Pay Ratio at the end of the compensation tables.
Form 10-K
- Companies have expanded HCM disclosures considerably, with big increases in DEI (90%) and culture and engagement (66%). However, most disclosures are nowhere near as quantitatively detailed as upcoming SEC regulations will require (see separate story).
The report also goes into great detail on other disclosures such as website, Code of Conduct, ESG frameworks, and cybersecurity disclosures and is worth a look when drafting your own disclosures.

Megan Wolf
Director, Practice, HR Policy Association and Center On Executive Compensation