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Audit the Work, Not Just the Words: When DEI is Optics-Only

There’s a reckoning happening in workplaces across the country and it’s not just about politics, budgets, or remote work. It’s about integrity. It’s about whether the things companies say about diversity, equity, and inclusion (DEI) actually align with what’s happening on the ground. In this week’s episode of What’s the DEIL? Shanté and Natalie of The Norfus Firm get candid (as always) about how reactive compliance, performative programs, and nervous legal maneuvering have begun to eclipse the real point of DEI work: building workplaces that work for everyone.

In a post-2020 world, many companies rushed to show support for DEI initiatives. There were statements, task forces, fellowships, ERGs, and funding. There were promises. But now, as political pressure mounts and misinformation spreads, many employers are quietly (or not so quietly) walking those efforts back. And the result? An increase in optics-only efforts that sound good on paper but do little to drive real change.

Let’s talk about what happens when DEI is performative and why a strategic audit might be the most powerful tool in your company’s arsenal right now.

Performative DEI: The Problem Beneath the Surface

One of the first things Natalie and Shanté discuss in this episode is the difference between strategy and scrambling. Many organizations reacted quickly after George Floyd’s murder and the subsequent national spotlight on racial equity. But reactions, however well-intentioned, are not strategy.

Instead of taking the time to understand what their people actually needed, some companies focused on flashy statements and PR wins. They threw money at fellowships or launched ERGs without sustainable infrastructure. These surface-level moves may have garnered good headlines, but they rarely addressed root issues like equity in promotion, leadership representation, or a sense of belonging at work.

And now that DEI is under public scrutiny, particularly in the legal and political realm, many of those companies are reversing course, unsure how to defend what they built.

This moment is uncomfortable, but it’s also an opportunity. And it starts with a question: If someone audited your DEI program today, would they find substance or spin?

What’s Really at Risk?

To be clear, Shanté and Natalie aren’t minimizing the real fear employers have right now. There’s legitimate concern over lawsuits, reputational risk, and what happens if the government starts investigating your practices. But, as they emphasize, there’s a difference between preparing for potential scrutiny and panicking in the face of it.

As Natalie points out, the law is still the law. Title VII of the Civil Rights Act of 1964 is still in effect. Anti-discrimination statutes are still in effect. Most companies are not being targeted by watchdog groups or government agencies for legal DEI efforts, they’re being watched because their efforts are clumsy, inconsistent, or unclear.

That’s where the audit comes in. Not as a defensive move, but as a proactive, strategic one. A DEI audit, especially one led by experts who understand both the legal framework and the nuances of workplace culture, helps you make sure your people practices align with the law and your values.

In other words: it’s not just about whether your DEI program exists. It’s about whether it’s coherent, compliant, and consistent with the way your business actually functions.

The DEI Audit: What You Should Actually Be Looking At

Let’s break it down. If you’re going to audit your workplace practices through a DEI lens, there are a few critical areas to assess:

1. Representation Data

Do you know who’s working for you and where they sit in the organization? This is about more than race or gender alone. Consider tenure, promotion rates, job levels, pay equity, and access to opportunity across various demographics. Are there trends? Disparities? Blind spots?

The goal isn’t to hire based on identity. It’s to ensure your systems aren’t inadvertently rewarding or punishing people based on characteristics unrelated to job performance or potential.

2. Promotion & Pay Equity

Who gets promoted? Who gets raises? And what’s the criteria behind those decisions?

If you can’t explain why one group is consistently advancing faster than others, or if those decisions are based on vague “culture fit” criteria, you could be sitting on a legal and ethical risk. An audit helps you uncover those gaps and address them before they become a bigger issue.

3. Policy Consistency

Your handbook might say one thing, but are your leaders following it? DEI audits should examine not just what your policies are, but how consistently they’re being applied.

This includes everything from hiring practices to discipline procedures. If your anti-harassment policy isn’t being enforced, for instance, you don’t have a policy. You have a liability.

4. Training and Communication

Have your employees actually been trained on bias, harassment, and compliance? And if so, is that training still relevant, accurate, and aligned with the law?

Many companies are using outdated, one-size-fits-all training programs that don’t reflect the current climate or the specific needs of their workforce. A good audit evaluates both the content of your training and how it’s being received and implemented.

5. Resource Allocation

It’s not just about what you say, it’s about where you put your money. Are your employee resource groups resourced equitably? Are your DEI teams empowered or isolated? Do your diversity programs have actual budget and authority or are they expected to run on vibes and volunteers?

Auditing your resource distribution helps you ensure you’re not just supporting diversity efforts in name only.

6. Narrative Alignment

This is a big one. Do the things you say externally, on your website, in your job postings, in your public statements, align with what your employees are actually experiencing?

If your site says “We’re committed to inclusion,” but your employees are saying “I don’t feel safe speaking up,” there’s a disconnect. That disconnect can lead to internal disillusionment and external scrutiny. And the receipts? They’re everywhere—emails, Glassdoor, Reddit, and investigative journalists.

Legal Fear Shouldn’t Be Leading Your Strategy

The loudest voices right now are coming from corners that want DEI to fail, or at the very least, want to scare you into inaction. But retreating in the face of scrutiny isn’t smart leadership. In fact, as Shanté and Natalie point out, companies that roll back programs out of fear are often making themselves more vulnerable, not less.

Why? Because uncertainty breeds inconsistency. Inconsistency in your employment practices is what lands you in court, not the mere existence of a DEI program.

Instead, reframe your approach. Don’t retreat. Audit. Review. Improve. Communicate. When you have clarity about your practices and their legal grounding, you can lead from a place of strength.

Final Thoughts: Don’t Just Say It, Prove It

In the episode’s final minutes, Shanté drops a truth bomb: “Put words on the page that you actually intend to live by.” Because guess what? If you say you care about equity, belonging, and inclusion, your employees and the public are going to hold you to it. And if you can’t show your work, that story will write itself and not in your favor.

DEI is not a buzzword. It’s not a hashtag. And it’s not a side hustle. It’s a critical part of how you attract talent, build trust, reduce risk, and drive innovation.

So stop treating it like an accessory. And start treating it like the strategic priority it is.

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Author Bio

NATALIE E. NORFUS

Natalie E. Norfus is the Founder and Managing Owner of The Norfus Firm. With nearly 20 years of experience as a labor and employment attorney and HR/DEI practitioner, Natalie is known for her creative problem-solving skills. She specializes in partnering with employers to develop effective DEI and HR strategies, conducting thorough internal investigations, and providing coaching and training to senior leaders and Boards of Directors.

Throughout her career, Natalie has held various significant roles in HR and DEI. She has served as the Chief Diversity Officer for multi-billion-dollar brands, where she was responsible for shaping the vision of each brand’s DEI initiatives. She has also worked as outside counsel in large law firms and in-house before establishing her own firm.

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