Facebook’s Civil Rights Audit 4. Auditors’ Observations Regarding Facebook’s Internal D & I Efforts Overall, the constant change in diversity and inclusion at Facebook— driven by the development of new projects and initiatives and the expansion of existing programming — reflects ongoing innovation and interest in D & I. The Auditors further believe that Facebook’s new focus on D & I integration and ensuring greater accountability in the application of D & I policies and strategies through things like leadership scorecards are steps in the right direction. To identify issues and assess program effectiveness, Facebook reports that the company uses quantitative and qualitative assessments, feedback from surveys and regular focus groups with under-represented people, coupled with established third-party research. The Auditors urge Facebook to make at least some of this data and feedback public (in its annual Diversity Report) so that the civil rights community and the general public can better understand the effectiveness of the company’s myriad programs and initiatives. However, because the Auditors are not privy to this data or feedback, the Auditors cannot speak to the effectiveness of any particular program or initiative. Further, while the Auditors did not have an opportunity to conduct surveys or interviews of employees, in their discussions with employees they observed a disconnect between the experiences described by a number of the employee resource group representatives and the diversity and inclusion policies, practices, and initiatives described by Facebook. The Auditors have made a number of recommendations based on conversations with ERG representations and company leadership. (i) Comprehensive study. Anecdotal accounts the Auditors heard suggest that efforts to instill inclusive practices or ensure consistent application of diversity-enhancing policies may have not yet taken hold on a systemic level. These observations signal that a more comprehensive (both quantitative and qualitative) study of how consistently Facebook’s diversity and inclusion-based policies or strategies are being applied internally would be valuable. The Auditors believe that continuing to develop data and metrics for assessing the effectiveness of its inclusion, and D & I integration efforts is critical to evaluating and guiding Facebook’s D & I strategy. While Facebook publishes its employment figures annually in its diversity report, those figures primarily speak to Facebook’s hiring and recruiting efforts — they do not offer a clear illustration of whether/how Facebook’s initiatives, policies, trainings, and tools designed to advance inclusion and D & I integration have impacted employee experiences or have translated to progress in cultivating a culture of inclusion. These additional metrics would provide critical insight in those areas. Further, the results could help Facebook identify where it may need to refocus attention and consider ways to revise, expand, improve, and/or redesign their existing programs (ii) Continued improvement on infrastructure. The Auditors encourage Facebook to continue to invest in building out systems and internal infrastructure to make sure diversity and inclusion strategies are prioritized, applied with consistency, embedded in everyday company practices, and ultimately create an inclusive culture. For example, the Auditors believe that practices such as the consistent application of the Diverse Slate Approach and exhibiting inclusive behavior are metrics upon which all employees, managers, and executives 68