Consultant Semler Brossy’s new report, ESG+Incentives, examines the prevalence of various ESG metrics as part of incentive compensation structures among companies in the S&P 500. Although some view ESG targets as just too nebulous to measure—how do you measure company culture?—and too amenable to “architecting” to ensure executive payouts, the use of ESG metrics as part of executive compensation plans appears to be a growing trend. The report concludes that the majority of companies in the S&P 500 now include ESG metrics, largely reflecting increased stakeholder interest in human capital and environmental issues. In 2022, “there was a nearly 23% increase in the proportion of S&P 500 companies applying ESG metrics in incentive plans, at 70% prevalence compared to 57% prevalence a year ago”—that’s a 13 percentage point increase year over year. Metrics related to human capital management were included most often as part of comp plans—used by 65% of all companies in the S&P 500, meaning that almost all companies that included any ESG metrics included HCM metrics.  And, while environmental metrics still remained scarce at only 23%, that percentage reflects a 64% increase over the 14% reported last year. The report indicates that the predominant metric overall was diversity and inclusion (46% of companies in the S&P 500); carbon-footprint metrics predominate in the environmental category, having increased by over 300% from last year.

The report indicates that ESG metrics are primarily included as part of annual comp plans (98% of those that use ESG metrics), but the use of ESG metrics as part of long-term incentive plans appears to be growing (currently only 14%). Of that 14%, approximately 11% include ESG metrics in both types of plans. About 41% used a scorecard approach, which identifies a group of metrics that are not individually weighted, but form part of a broader initiative. SB indicates that the scorecard approach “allows companies to designate a certain percentage of an incentive plan to a group of two or more metrics, which may include strategic or operational goals in addition to ESG. The scorecard provides Committees more discretion to assess performance and to update goals and priorities each year without adjusting the fundamental incentive plan design.” About 23% of companies in the S&P 500 that include ESG metrics use “discrete, weighted metrics,” which are metrics that are assigned “a specific goal and a designated weighting.” SB contends that discrete weighted metrics are “often the most impactful design elements in incentive plans, used primarily for metrics that are “operationally focused, as opposed to sustainability oriented. [SB expects] that this trend is driven by the longer experience with these metrics and relative ease of goal setting.” And 28% are purely discretionary, with ESG metrics that are “not fully quantified but rather included as an additional layer of discretionary considerations that may impact final payouts, generally in an individual component.”

ESG can include a broad mix of metrics, but SB has divided the mix into three categories: human capital management, environmental and a group of operational, consumer-focused and broader social measures, which SB has grouped together as “other ESG.” More specifically, in the category of “other ESG” SB includes customer satisfaction (employed as a metric by 32% of companies in the S&P 500), community engagement (11%), product quality (10%) and cybersecurity (6%). According to SB, 65% of all companies in the S&P 500 include some type of HCM metrics, only 23% include environmental metrics and 41% use metrics in the “other” category. About 45% of companies in the S&P 500 include metrics from two or more ESG categories; 14% include a mix from all categories. 

Human capital

As noted above, HCM is the category most commonly included in comp plans.  In the SB report, HCM includes as metrics diversity and inclusion (which was used in 46% of all S&P 500 comp plans), safety (33%), talent development (27%), employee satisfaction (22%), turnover/retention (20%) and company culture (16%). SB found that all HCM metrics increased “substantially in prevalence year over year,” driven, SB believes, by “stakeholder focus on talent-related issues, intense competition for talent, and the growing knowledge of how to measure and assess HCM performance.”

Consistent with last year, D&I is both the most prevalent metric within HCM and overall ESG (46% of companies in the S&P 500, compared to 28% last year), and the metric that experienced the second highest year-over-year increase of 64% (18 percentage points). Notwithstanding the dominance of D&I, SB found that companies generally looked at accomplishments in the category of HCM more holistically, with 86% of companies including at least one other HCM metric along with D&I, and about 61% including at least two additional HCM metrics.


As noted above, environmental metrics appear least often as a category of ESG metrics, but the category increased significantly by 64% year over year, from 14% to 23%, the largest increase in category year over year. Included among environmental metrics are carbon footprint (used as a metric by 16% of companies in the S&P 500), emissions/chemical containment (8%), energy efficiency (5%), waste reduction (4%), sustainable sourcing (3%), and water consumption (2%). Why the big increase? SB attributes it to the growth in use of carbon footprint metrics, which “have been a key driver of this increase and have emerged as the environmental metric of choice for S&P 500 companies. Carbon footprint metrics experienced an over 300% year-over-year increase in prevalence, from 5% to 16% prevalence across the S&P 500. This was the largest increase among all ESG metrics year over year.”

According to SB, environmental metrics have historically been tricky to incorporate into comp plans because they are sometimes poorly defined and hard to assess or quantify. SB suggests that “goal-setting and measuring achievements in a timely manner” have presented challenges that have deterred companies from incorporating environmental measures.  However, in light of increasing pressure on climate from major institutional investors, together with “two-thirds of S&P 500 companies having set greenhouse gas emissions reduction targets,” SB expects carbon footprint metrics to continue to lead among environmental measures. In addition, adoption of the recent SEC proposal on climate disclosure “may further accelerate this trend. [SB expects] that as more companies are disclosing information around how they consider environmental measures in compensation, they are setting the standard and paving a path for more companies to follow suit.”

Posted by Cydney Posner