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Leaders in Diversity At Covington, we see the differences among us as an asset and a source of strength. We believe that excellence in the practice of law knows no racial, ethnic, gender, religious, sexual orientation, or other boundaries. By recruiting, retaining, developing, and promoting a diverse group of lawyers, we advance the interests of our clients, our practice, and our entire profession. Our women, minority, and LGBT+ lawyers lead more than half our practice and industry groups and serve in senior roles on our management, associate advisory, hiring, and evaluation committees. Covington’s recent diversity recognitions include: The American Lawyer, “A-List” based on four key categories, including diversity Human Rights Campaign, 100 percent “Corporate Equality Index” rating for LGBT+ policies Euromoney Legal Media Group, “Americas Women in Business Law Awards” Law360, ranked sixth among “The Best Law Firms for Minority Attorneys” and ranked seventh among “The Best Law Firms for Minority Partners” © 2018 Covington & Burling LLP. All rights reserved.

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Leaders in Diversity At Covington, we see the differences among us as an asset and a source of strength. We believe that excellence in the practice of law knows no racial, ethnic, gender, religious, sexual orientation, or other boundaries. By recruiting, retaining, developing, and promoting a diverse group of lawyers, we advance the interests of our clients, our practice, and our entire profession.

Our women, minority, and LGBT+ lawyers lead more than half our practice and industry groups and serve in senior roles on our management, associate advisory, hiring, and evaluation committees. Covington’s recent diversity recognitions include:

• The American Lawyer, “A-List” based on four key categories, including diversity

• Human Rights Campaign, 100 percent “Corporate Equality Index” rating for LGBT+ policies

• Euromoney Legal Media Group, “Americas Women in Business Law Awards”

• Law360, ranked sixth among “The Best Law Firms for Minority Attorneys” and ranked seventh among “The Best Law Firms for Minority Partners”

© 2018 Covington & Burling LLP. All rights reserved.

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Covington & Burling LLP

2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

One CityCenter850 Tenth Street, NWWashington, DC 20001-4956Phone: 202 662 6000Fax:https://www.cov.com/

LOCATIONSWashington, DC; New York, NY; San Francisco, CA; Silicon Valley, CA; Los Angeles, CA; London, England; Brussels, Belgium; Beijing & Shanghai,China; Seoul, South Korea; Dubai, United Arab Emirates; Frankfurt, Germany; Johannesburg, South Africa

DIVERSITY LEADERSHIPHead(s) of Firm: Timothy C. Hester, Chairman of the Management CommitteeDiversity team leader(s): Michael Imbroscio / Catharina Min (Co-Chairs), Keir Gumbs, Loretta Shaw-Lorello

NUMBER OF ATTORNEYSTOTAL NUMBER OF ATTORNEYS

Currently As of December 31, 2017

Firmwide 1218 1222U.S. offices only 1037 1053

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Law Firm Demographic Profile

Does your firm have more than one tier of partnership?

No

ASSOCIATES (2017) SUMMER ASSOCIATES (2017)

Men Women

White/Caucasian 224 148African-American/Black 13 14

Hispanic/Latino 9 19Alaska Native/American Indian 0 0

Asian 37 44Native Hawaiian/Pacific Islander 0 0

Multiracial 8 18Openly LGBTQ 22 12

Individuals with disabilities 0 0Total 291 243

Men Women

White/Caucasian 58 49African-American/Black 2 2

Hispanic/Latino 3 2Alaska Native/American Indian 1 0

Asian 6 19Native Hawaiian/Pacific Islander 0 0

Multiracial 1 2Openly LGBTQ 7 6

Individuals with disabilities 0 0Total 71 74

EQUITY PARTNERS (2017) NON-EQUITY PARTNERS (2017)

Men Women

White/Caucasian 169 49African-American/Black 4 4

Hispanic/Latino 4 3Alaska Native/American Indian 0 0

Asian 9 6Native Hawaiian/Pacific Islander 0 0

Multiracial 1 1Openly LGBTQ 6 2

Individuals with disabilities 0 0Total 187 63

Men Women

White/Caucasian n/a n/aAfrican-American/Black n/a n/a

Hispanic/Latino n/a n/aAlaska Native/American Indian n/a n/a

Asian n/a n/aNative Hawaiian/Pacific Islander n/a n/a

Multiracial n/a n/aOpenly LGBTQ n/a n/a

Individuals with disabilities n/a n/aTotal n/a n/a

OF COUNSEL (2017) NEW HIRES (2017)

Men Women

White/Caucasian 151 56African-American/Black 6 12

Hispanic/Latino 7 8Alaska Native/American Indian 0 0

Asian 10 13Native Hawaiian/Pacific Islander 0 0

Multiracial 4 2Openly LGBTQ 7 5

Individuals with disabilities 0 0Total 178 91

Men Women

White/Caucasian 69 43African-American/Black 5 11

Hispanic/Latino 5 6Alaska Native/American Indian 0 0

Asian 12 16Native Hawaiian/Pacific Islander 0 0

Multiracial 3 12Openly LGBTQ 8 2

Individuals with disabilities 0 0Total 94 88

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Strategic Plan and Diversity Leadership

How does the firm's leadership communicate the importance of diversity to everyone at the firm?

The firm's leadership communicates the importance that it places on diversity through targeted publications, diversity-focused events, affinity groups, mentoring programs, routinecommunications, and policies and practices. The Diversity Initiatives Committee maintains an intranet site dedicated to recent diversity activities and programs. The site enablesmembers of the firm to view upcoming and recent diversity meetings and activities, other diversity-related content and information on external programs. Links to the firm'sProfessional Development, Women's Forum, and Work-Life Balance programs are also provided. Our Women's Forum and Affinity Group leaders meet regularly with theirmembers. These groups provide additional opportunities for our attorneys and staff to engage through panel discussions and networking events focused on diversity and inclusionwithin the legal profession.

Covington maintains a diversity page, www.cov.com/diversity, highlighting our commitment to diversity and inclusion as well as the accomplishments and awards we havereceived for our efforts. The Diversity Initiatives Committee publishes diversity-related content through the Diversity Update, a newsfeed that distributes information about events,sponsorships, programs, and key wins involving our attorneys. We cross-promote this and other relevant content on our social media platforms, including Facebook, LinkedIn, andTwitter.

Who has primary responsibility for leading diversity initiatives at your firm?

Michael Imbroscio / Catharina Min (Co-Chairs), Keir Gumbs, Loretta Shaw-Lorello

Does your law firm currently have a diversity committee?

Yes

If yes, does the committee's representation include one or more members of the firm's management/executive committee (or equivalent)?

Yes

If yes, how many attorneys are on the committee, and in 2017, what was the total number of hours collectively spent by the committee in the furtherance ofthe firm's diversity initiatives?

Total attorneys on committee: 23Total hours spent on diversity: 1830

Does the committee and/or diversity leader establish and set goals or objectives consistent with management's priorities?

Yes

Has the firm undertaken a formal or informal diversity program or set of initiatives aimed at increasing the diversity of the firm?

Yes

If yes, is it formal or informal?

Formal

How often does the firm's management review the firm's diversity progress/results?

Quarterly

How is the firm's diversity committee and/or firm management held accountable for achieving results?

The Management Committee, which consists of eight members elected by the full partnership, is responsible for guiding the strategic direction of the firm and overseeing thefirm's major business and policy decisions. Two women partners, Catherine Dargan, one of our African-American partners, and Louise Nash, the former managing partner of ourLondon office, serve on the Management Committee. In addition, virtually every woman, minority, and openly LGBT partner at Covington participates in firm or practice groupmanagement. Moreover, our women, minority, and openly LGBT lawyers play senior leadership roles in 32 individual practice and industry groups within the firm and senior roleson firm committees, including our associate advisory, business, diversity, evaluation, hiring, and legal personnel committees.

Diversity is a fundamental in our firm's strategic planning. We have developed an approach to succession that includes an emphasis on a diverse talent pool and the inclusion ofwomen, minority, and LGBT attorneys in firm leadership. Beyond this, we actively seek to introduce a diverse team of attorneys to our clients, and are prioritizing opportunitiesfor women, minority, and LGBT attorneys to lead engagements. Increasing diversity is also one of our goals in lateral hiring, while we pursue our vision of firm growth.

To measure and assess the effectiveness of our efforts, we track promotion and retention rates among targeted groups. The Special Committee on Women and Diversity InitiativesCommittee monitor and report on the progress of women, minority, and LGBT attorneys in all facets of the firm's activities, from recruiting through promotion and leadershipopportunities.

Is your firm minority-owned or women-owned?

No

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Law Firm Diversity Initiatives

INITIATIVES FOR ALL DIVERSE ATTORNEYS

AlreadyCompleted

CurrentlyAddressing

Not a CurrentPriority

X X Undertake communication from firm management that diversity is a top priority of the firm

X X Formalize diversity plan and committee with action steps and accountability to management

X Conduct firmwide diversity training for all attorneys and staff

X X Focus on strengthening firm's mentoring program

X X Conduct internal diversity needs assessment (e.g., culture and environment surveys) and/or retain diversityconsultant to examine how firm culture might be more welcoming of minorities

X X Support law firm's internal affinity networks

X Hire a director of diversity or other full-time professional to implement the firm's diversity program

X X Coordinate or work with clients on diversity issues

X X Develop/expand relationships with minority bar associations and other legal diversity organizations to offerfirm's support of these networks

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Law Firm Diversity Initiatives

INITIATIVES SPECIFICALLY FOR MINORITY ATTORNEYS

AlreadyCompleted

CurrentlyAddressing

Not a CurrentPriority

X Increase the number of minority attorneys at the associate level

X Increase the number of minority attorneys at the partnership level

X X Increase the number of minority attorneys in leadership positions

X X Focus on strengthening firm's mentoring program for minority attorneys

X Manage/monitor allocation of work assignments and/or hours billed to ensure minority attorneys have equalaccess/inclusion on top client matters

INITIATIVES SPECIFICALLY FOR WOMEN ATTORNEYS

AlreadyCompleted

CurrentlyAddressing

Not a CurrentPriority

X Institute a formal part-time policy that addresses partnership prospects

X Increase the number of women at the associate level

X Increase the number of women at the partnership level

X X Increase the number of women in leadership positions

X X Focus on strengthening firm's mentoring program for women

X X Manage/monitor allocation of work assignments and/or hours billed to ensure women have equal access/inclusion to top client matters

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Law Firm Diversity Initiatives

INITIATIVES SPECIFICALLY FOR OPENLY LGBTQ ATTORNEYS

AlreadyCompleted

CurrentlyAddressing

Not a CurrentPriority

X Offer same-sex domestic partners the same benefits available to married individuals

X Increase the number of LGBTQ attorneys at the associate level

X Increase the number of LGBTQ attorneys at the partnership level

X Increase the number of LGBTQ attorneys in leadership positions

X Ensure that EEO and non-discrimination policies specifically address gender identity

INITIATIVES SPECIFICALLY FOR ATTORNEYS WITH DISABILITIES

AlreadyCompleted

CurrentlyAddressing

Not a CurrentPriority

X Increase the number of attorneys with disabilities at the associate level

X Increase the number of attorneys with disabilities at the partnership level

X Increase the number of attorneys with disabilities in leadership positions

X Ensure that EEO and non-discrimination policies specifically address individuals with disabilities

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Pipeline Initiatives

Does your firm actively engage in initiatives to feed the diversity pipeline by encouraging minority students to consider law as a career and/or assisting themin pursuing such opportunities?

Participate in established pipeline programs, such as SEO, Legal Outreach, Prep for Prep or Street Law

Fund scholarships for minority high school or college students

Mentor high school or college students

Participate in or host mock trial programs or career events

Provide internships or employment to minority high school or college students

Outreach to middle school students

Please discuss any additional efforts to reach out to diverse undergraduates, high school, middle school or grade school students.

We participate in the Sponsors for Educational Opportunity (SEO) Career program, which is the nation's premiere summer internship program for talented underrepresenteddiverse students. We also participate in the Leadership Council on Legal Diversity (LCLD) 1L Scholars Program, a program that gives selected law students 1L summer associatepositions. The 1L LCLD Scholars Program is designed to strengthen the legal pipeline by expanding the number of opportunities for diverse first-year law students.

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Recruitment - New Associates

Does your firm annually recruit at any of the following types of institutions?

Ivy League schools: Columbia University; Cornell University; Harvard University; University of Pennsylvania; Yale University

Other private schools: American University; Duke University; Fordham University; George Washington University; Georgetown University; New York University; NorthwesternUniversity; Stanford University; University of Chicago; University of Southern California; Vanderbilt University; Washington & Lee University

Public state schools: University of California, Berkeley; University of California, Los Angeles; University of Maryland; University of Michigan; University of North Carolina;University of Virginia; William & Mary

Historically Black Colleges and Universities (HBCUs): Howard University

Diversity job fairs: Bay Area Diversity Career Fair, Lavender Law Career Fair, Harvard Black Law Student Association Job Fair, Hispanic National Bar Association Career Fair,UCLA Law Firm Diversity Reception, Veteran's Legal Career Fair

Do you have any special outreach efforts directed to encourage minority law students to consider your firm?

Hold a reception for minority students

Advertise in minority law student association publications

Participate in or host minority law student job fairs

Sponsor minority law student association events

Firm lawyers participate on career panels at schools

Outreach to leadership of minority student organizations

Scholarships or intern/fellowships for minority students

Other (please specify)Lead or participate in panels to give minority students guidance on how to interview with large law firms; Founder and lead organizer of the DC "Road Show" to encourageAfrican-American law students to consider practice in large Washington firms; Participate in the Sponsors for Educational Opportunity Corporate Law Program.

Do you have any programs specifically targeted at first-year students?

Yes, we recruit a small number of 1L summer associates into our summer program in certain offices. We conduct outreach to law student affinity groups and participate indiversity events and receptions at all of the law schools where we recruit.

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Recruitment - New Associates

ALL 2L SUMMER ASSOCIATES (2017) OFFERS MADE* (2017)

* Summer associates who received an offer of full-time employment

Men Women

White/Caucasian 56 48African-American/Black 2 2

Hispanic/Latino 3 2Alaska Native/American Indian 1 0

Asian 6 19Native Hawaiian/Pacific Islander 0 0

Multiracial 1 2Openly LGBTQ 7 5

Individuals with disabilities 0 0Total 69 73

Men Women

White/Caucasian 56 47African-American/Black 2 2

Hispanic/Latino 3 2Alaska Native/American Indian 1 0

Asian 6 19Native Hawaiian/Pacific Islander 0 0

Multiracial 1 2Openly LGBTQ 7 5

Individuals with disabilities 0 0Total 69 72

OFFERS ACCEPTED* (2017) NEITHER ACCEPTED NOR DECLINED (2017)

* Summer associates who accepted an offer of full-time employment * Summer associates who neither accepted nor declined an offer of full-timeemployment because of postgraduate clerkship/fellowship

Men Women

White/Caucasian 36 35African-American/Black 1 1

Hispanic/Latino 2 2Alaska Native/American Indian 1 0

Asian 4 15Native Hawaiian/Pacific Islander 0 0

Multiracial 1 0Openly LGBTQ 4 4

Individuals with disabilities 0 0Total 45 53

Men Women

White/Caucasian 6 7African-American/Black 1 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 1 2Native Hawaiian/Pacific Islander 0 0

Multiracial 0 1Openly LGBTQ 2 0

Individuals with disabilities 0 0Total 8 10

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Recruitment - Lateral Associates and Partners

LATERAL ASSOCIATE HIRES (2017) LATERAL OF COUNSEL HIRES (2017)

Men Women

White/Caucasian 18 12African-American/Black 1 3

Hispanic/Latino 0 2Alaska Native/American Indian 0 0

Asian 3 8Native Hawaiian/Pacific Islander 0 0

Multiracial 0 4Openly LGBTQ 0 1

Individuals with disabilities 0 0Total 22 29

Men Women

White/Caucasian 10 6African-American/Black 1 3

Hispanic/Latino 2 1Alaska Native/American Indian 0 0

Asian 4 3Native Hawaiian/Pacific Islander 0 0

Multiracial 1 2Openly LGBTQ 2 1

Individuals with disabilities 0 0Total 18 15

LATERAL PARTNER HIRES* (2017) NEW PARTNERS PROMOTED* (2017)

* Both equity and non-equity * Both equity and non-equity promoted from associate or of counsel rank

Men Women

White/Caucasian 5 2African-American/Black 0 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 1 1Native Hawaiian/Pacific Islander 0 0

Multiracial 0 1Openly LGBTQ 2 0

Individuals with disabilities 0 0Total 6 4

Men Women

White/Caucasian 7 6African-American/Black 0 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 0 0Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 1 0

Individuals with disabilities 0 0Total 7 6

NEW EQUITY PARTNERS* (2017)

* Whether hired laterally or promoted from within

Men Women

White/Caucasian 12 8African-American/Black 0 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 1 1Native Hawaiian/Pacific Islander 0 0

Multiracial 0 1Openly LGBTQ 3 0

Individuals with disabilities 0 0Total 13 10

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Recruitment - Lateral Associates and Partners

What activities does the firm undertake to attract diverse attorneys?

Partner programs with women, minority, LGBTQ or disability-focused bar associations

Participate at diversity job fairs

Attend events at diversity legal organizations

Seek referrals from other attorneys

Utilize online job services (e.g., MCCA Job Bank)

Hire recruiting professional who specializes in identifying diverse candidates

Other (please specify)

Do you use executive recruiting/search firms to seek to identify new diversity hires (partners or associates)?

Yes

If yes, are any of these executive recruiting/search firms women and/or minority-owned?

Yes

If yes, list all women and/or minority-owned executive search/recruiting firms to which the firm paid a fee for placement services in the past 12 months:

Volta Talent Strategies LLC

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Retention and Professional Development

A T T O R N E Y S W H O L E F T T H E F I R M I N 2 0 1 7

1ST-YEAR ASSOCIATES 2ND-YEAR ASSOCIATES

Men Women

White/Caucasian 5 6African-American/Black 0 1

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 0 5Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 5 12

Men Women

White/Caucasian 3 2African-American/Black 0 0

Hispanic/Latino 2 0Alaska Native/American Indian 0 0

Asian 0 0Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 5 2

3RD-YEAR ASSOCIATES 4TH-YEAR ASSOCIATES

Men Women

White/Caucasian 1 4African-American/Black 0 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 2 1Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 3 5

Men Women

White/Caucasian 4 3African-American/Black 0 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 0 0Native Hawaiian/Pacific Islander 0 0

Multiracial 1 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 5 3

5TH-YEAR ASSOCIATES 6TH-YEAR ASSOCIATES

Men Women

White/Caucasian 2 2African-American/Black 0 1

Hispanic/Latino 1 0Alaska Native/American Indian 0 0

Asian 0 0Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 1 0

Individuals with disabilities 0 0Total 3 3

Men Women

White/Caucasian 3 1African-American/Black 0 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 0 2Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 3 3

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Retention and Professional Development

A T T O R N E Y S W H O L E F T T H E F I R M I N 2 0 1 7

7TH-YEAR ASSOCIATES 8TH-YEAR PLUS ASSOCIATES

Men Women

White/Caucasian 1 2African-American/Black 0 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 0 0Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 1 2

Men Women

White/Caucasian 3 4African-American/Black 0 1

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 1 0Native Hawaiian/Pacific Islander 0 0

Multiracial 0 1Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 4 6

OF COUNSEL NON-EQUITY PARTNERS

Men Women

White/Caucasian 12 2African-American/Black 2 2

Hispanic/Latino 1 0Alaska Native/American Indian 0 0

Asian 1 1Native Hawaiian/Pacific Islander 0 0

Multiracial 0 1Openly LGBTQ 1 0

Individuals with disabilities 0 0Total 16 6

Men Women

White/Caucasian n/a n/aAfrican-American/Black n/a n/a

Hispanic/Latino n/a n/aAlaska Native/American Indian n/a n/a

Asian n/a n/aNative Hawaiian/Pacific Islander n/a n/a

Multiracial n/a n/aOpenly LGBTQ n/a n/a

Individuals with disabilities n/a n/aTotal n/a n/a

EQUITY PARTNERS

Men Women

White/Caucasian 1 0African-American/Black 0 1

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 0 0Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 1 1

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Retention and Professional Development

Please identify the specific steps you are taking to reduce the attrition rate of diverse attorneys.

Develop and/or support internal employee affinity groups (e.g., networks within the firm for minorities, women, LGBTQ attorneys, or individuals with disabilities)

Increase/review compensation relative to competition

Increase/improve current work/life programs

Adopt dispute resolution process

Succession plan includes emphasis on diversity and greater inclusion of minority men and women in firm leadership

Work with diverse attorneys to develop career advancement plans

Introduce diverse attorneys to key clients, including to lead engagements

Review work assignments and hours billed to key client matters to make sure diverse attorneys, particularly minority attorneys (for whom research indicates a greaterinclusion problem), are not being excluded

Strengthen mentoring program for all attorneys

Professional skills development program for all attorneys

Provide a gender-neutral parental leave policy that covers adoptions

Other (please specify)Transgender benefits offered

Does your firm have part-time/flex-time policies that permit attorneys (male or female) to work alternative schedules?Yes

What impact, if any, will the decision to work part time have on an attorney's ability to make a partner, or if already a partner, to remain a partner at yourfirm?

Attorneys who work part time remain eligible for consideration of partnership. If the cumulative effect of the attorney's individual part-time arrangement is to omit more than theequivalent of a full year during the associate years, consideration for partnership will ordinarily be deferred accordingly.

How many current equity partners have worked part time, exclusive of maternity/paternity leave or short-term disability?

15

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Retention and Professional Development

PART-TIME ATTORNEYS PART-TIME ATTORNEYS TOTAL NUMBER OF ATTORNEYS(2017) Men Women Total (full and part-time)

Associates 3 19 22 534

Of counsel 16 10 26 269

Non-equity partner n/a n/a n/a n/a

Equity partner 0 6 6 250

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Management Demographic Profile

F I R M W I D E C O M M I T T E E S 2 0 1 7

EXECUTIVE/MANAGEMENT COMMITTEE* HIRING COMMITTEE*

* Attorneys on the Executive/Management Committee or equivalent * Attorneys on Hiring Committee or equivalent

Men Women

White/Caucasian 6 0African-American/Black 0 1

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 0 0Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 6 1

Men Women

White/Caucasian 11 3African-American/Black 0 1

Hispanic/Latino 1 1Alaska Native/American Indian 0 0

Asian 3 3Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 1 0

Individuals with disabilities 0 0Total 15 8

The numbers included above are U.S. only. The eighth member of theManagement Committee, Louise Nash, is a female partner in our Londonoffice.

PARTNER REVIEW COMMITTEE* ASSOCIATE REVIEW COMMITTEE*

* Attorneys on the Partner Review Committee or equivalent * Attorneys on the Associate Review Committee or equivalent

Men Women

White/Caucasian n/a n/aAfrican-American/Black n/a n/a

Hispanic/Latino n/a n/aAlaska Native/American Indian n/a n/a

Asian n/a n/aNative Hawaiian/Pacific Islander n/a n/a

Multiracial n/a n/aOpenly LGBTQ n/a n/a

Individuals with disabilities n/a n/aTotal n/a n/a

Men Women

White/Caucasian 14 4African-American/Black 0 0

Hispanic/Latino 0 0Alaska Native/American Indian 0 0

Asian 2 0Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 0 0

Individuals with disabilities 0 0Total 16 4

The firm does not have a partner review committee.

ATTORNEYS ON THE DIVERSITY COMMITTEE OREQUIVALENT

Men Women

White/Caucasian 6 4African-American/Black 2 3

Hispanic/Latino 2 2Alaska Native/American Indian 0 0

Asian 2 2Native Hawaiian/Pacific Islander 0 0

Multiracial 0 0Openly LGBTQ 2 3

Individuals with disabilities 0 0Total 12 11

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

Management Demographic Profile

O T H E R L E A D E R S H I P R O L E S

Leadership positions (2017) U.S. office headsPractice group/

department leaders Committee leaders

Total number of positions 7 101 197

Number of such positions held by:

Minorities 0 10 44

Women 2 29 65

LGBTQ attorneys 0 2 5

Individuals with disabilities 0 0 0

Please provide information regarding all diverse attorneys who currently head offices, practice groups and committees. Enter responses inthe following format: Attorney, Office location/Practice group/Committee (No. of attorneys in office/practice group/committee).

U.S. OFFICE HEADS

How many offices does your firm have in the United States? 5

Minorities heading offices: [No response]

Women heading offices: Los Angeles (27); Silicon Valley (34)

LGBTQ attorneys heading offices: [No response]

Individuals with disabilities heading offices: [No response]

PRACTICE GROUP/DEPARTMENT LEADERS

Minorities heading practices: Chair of Antitrust (6); Chair of Commercial Litigation (4); Chair of Communications & Media (2); Chair of Financial Institutions (2); Chair ofHealth Care (2); Chair of M&A (2); Chair of Private Funds & Investments (2); Vice-Chair of Securities & Capital Markets (3); Vice-Chair of Tax (3); Chair of White Collar (3)

Women heading practices: Chair of Advertising & Consumer Law (2); 2 Chairs of Antitrust (6); Vice-Chair of Antitrust (6); Chair of Appellate (2); Chair of Arbitration (1); Chairof Bankruptcy & Restructuring (1); 2 Chairs of Class Actions (2); Chair of Commercial Litigation (4); Chair of Communications & Media (2); Vice-Chair of Employment (1); 2Chairs of Food & Drug (2); Chair of Government Contracts (2); 2 Chairs of Health Care (2); 2 Chairs of Industries, Regulatory & Legislative (IRL) Umbrella Group (3); 2 Vice-Chairs of International Trade & Finance (6); Chair of M&A (2); Chair of Patent Office (1); Vice-Chair of Pharmaceutical Litigation & Investigations (3); Chair of Private Funds &Investments (2); Chair of Real Estate (1); Chair of States (1); 2 Chairs of White Collar (3)

LGBTQ attorneys heading practices: Chair of Energy (Oil & Gas, Utilities) (2); Chair of Patent Office (1)

Individuals with disabilities heading practices: [No response]

COMMITTEE LEADERS

Minorities heading committees: Chair of Associate Advisory Committee (3); 4 Chairs of Associate Integration (6); 3 Chairs of Associate Ombudspersons (6); 6 Chairs of DiversityInitiatives (10); 9 Chairs of Firm-wide Initiatives (32); 9 Chairs of Hiring (24); Chair of Legal Personnel – U.S. Offices (26); 3 Vice-Chairs of Legal Personnel – U.S. Offices(26); Chair of Loss Prevention (6); 2 Chairs of Parental Leave Coordinators (7); Chair of Part-Time Work (4); 2 Vice-Chairs of Public Service Committee (6); Chair of StandingCommittee on Women (1); Chair of Women's Forum (7)

Women heading committees: Chair of Associate Advisory Committee (3); 2 Chairs of Associate Integration (6); Chair of Associate Life and Development (1); 3 Chairs ofAssociate Ombudspersons (6); 2 Chairs of Benefits (2); Chair of Business Committee (4); Chair of Charitable Contributions Committee (2); 2 Chairs of Counsel, Senior Lawyers& Advisors (6); 7 Chairs of Diversity Initiatives (10); Chair of Evaluation Committee (1); 8 Chairs of Firm-wide Initiatives (32); Chair of General Counsel (9); 8 Chairs of Hiring(24); 4 Chairs of Legal Personnel – US Offices (26); 2 Vice-Chairs of Legal Personnel – US Offices (26); Chair of Lunch Program (2); Chair of Marketing and RelationshipManagement (2); 3 Chairs of Part-time Work (4); Chair of Professional Development Committee (1); Vice-Chair of Public Service Committee (6); Chair of Standing Committeeon Women (1); Chair of Strategic Pricing (3); 7 Chairs of Women's Forum (7)

LGBTQ attorneys heading committees: Chair of Business Committee (4); Chair of Diversity Initiatives (10); Chair of Firm-wide Initiatives (32); Chair of Hiring (24); Chair ofStrategic Pricing (3)

Individuals with disabilities heading committees: [No response]

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

The Firm Says

Our Diversity Initiatives Committee is Co-Chaired by Michael Imbroscio, a senior litigator and Co-Chair of our firm's Product Liability Practice, and Catharina Min, a corporatepartner and Vice-Chair of the Venture Capital / Emerging Companies practice. Mr. Imbroscio served as hiring partner for the firm for nearly a decade and brings to bear extensiveexperience in diversity issues. Ms. Min serves as Chair of the Women's Forum in Silicon Valley. Together, they provide strategic leadership on diversity and inclusion relatedto the identification and recruitment of a diverse talent pool, mentoring and professional development, community building, and internal and external promotion of the firm'sachievements.

Affinity Groups

Reflecting the diverse backgrounds of our lawyers, Covington has established five Diversity Committee subcommittees: African American/Black, Asian American, Hispanic/Latino, LGBT, and Veterans. Affinity Groups contribute to our firm culture and provide additional opportunities for mentoring, community building, and professionaldevelopment.

Each group plans its activities, including events and sponsorships, with the goal of providing career development and addressing any challenges that the group's members mayface.

Women's Forum

Similarly, the Women's Forum is a firm wide initiative designed to facilitate interaction among women lawyers at all levels of the firm. Through regularly scheduled programsand initiatives, the Women's Forum provides opportunities for our women lawyers to network with each other and discuss issues of common interest, including career growth,mentoring, and business and professional development.

The Women's Forum hosts industry panels, plans regular social events, and facilitates attendance at events concerning women in the law. For example, Covington has sponsoredand hosted events for DirectWomen, National Association of Women Lawyers, Women's Bar Association, National Women's Law Center, and National Partnership for Women &Families. The Washington Women's Forum sponsors Mentoring Groups, which meet quarterly.

Diversity in the Legal Profession

Covington understands that promoting diversity is never complete, and strives to lead by example, continuing to raise the bar for our entire profession. In New York, SanFrancisco, and Washington we have joined with other major firms in making public commitments to increase diversity in our ranks. We were a founding member of the Districtof Columbia Conference on Opportunities for Minorities in the Legal Profession and an original signatory of the Conference's Policy Statement Regarding Minority Hiring andRetention. We endorse the New York City Bar Association's Statement of Diversity Principles, and we were a charter signatory of the No Glass Ceiling Initiative of the BarAssociation of San Francisco. We are a proud signatory of the American Bar Association Commission's "Disability Diversity in the Legal Profession: A Pledge for Change." Bysigning the Pledge, we publicly demonstrate our commitment to diversity and encourage others in the legal field to sign the Pledge.

Recruiting

We aim to attract and develop a diverse talent pool; we are committed to looking for talented lawyers from outside our firm while ensuring that junior lawyers can rise topartnership from within our own ranks. In the US, we support a variety of student groups at law schools, such as the Black Law Students Association, the Latino Law StudentsAssociation, the Asian Pacific American Law Students Association, the South Asian Law Students Association, OutLaw, and Law Veterans Organizations. We not only providefinancial support to these groups, but also participate in meaningful ways, including speaking on panels regarding law firm life, attending job fairs and conferences, and meetingwith law students in informal settings to discuss legal careers and to provide counseling on interviewing strategies.

Our London office has partnered with Bright Network, an organization started in 2013, to create a network of the brightest students and connect them with the best careeropportunities. The organization supports a diverse membership. 75% of the network's members are state-educated, 58% are female, 40% are Black, Asian & Minority Ethnic and43% are the first generation to attend a university. In conjunction with Warwick University, we have developed a mentoring program. Students are paired with associates in ourLondon office who provide advice on law applications and life as a lawyer as well as any other questions they may have. We also hold an open day in our office each year whichincludes talks about the Firm and our practice areas as well as practical sessions such as mock interviews and resume tips.

In addition, we sponsor several specialty bar associations and national organizations, including the National Asian Pacific American Bar Association, South Asian Bar Associationof Northern California, Korean-American Bar Association, National LGBT Bar Association, Lambda Legal, and the Hispanic Bar Association of the District of Columbia. Ourattorneys serve in leadership roles in these organizations and speak at national and local conferences. Covington also funds participation in these events through conference andtable sponsorships.

We participate in the Sponsors for Educational Opportunity (SEO) Career program, which is the nation's premiere summer internship program for talented underrepresentedstudents. We also participate in the Leadership Council on Legal Diversity (LCLD) 1L Scholars Program, a program designed to strengthen the diversity of the legal pipeline byproviding 1L summer association positions to a diverse pool of talented first-year law students.

Retention and Career Development

The firm recognizes that professional development is one of the key reasons why lawyers stay with the firm and has improved the resources dedicated to fulfilling the evolvingneeds of our lawyers. Elaine Stone serves as the Managing Partner for Associate Life and Development. Elaine, along with the firm's Chief Legal Personnel Officer, TimmWhitney, oversee new initiatives and improvements in current programs to help associates strengthen their development and career paths. Her previous service on the firm'sManagement Committee equips Ms. Stone to steer these efforts at a very high level.

The firm also has a committed team devoted to associate life and development, led by Ms. Stone. This team is a group of senior partners of the firm and involves partners atall levels in mentoring diverse associates through the evaluation, staffing, and professional development processes. These efforts are focused on ensuring that the firm offersopportunities for associate development, focusing on retention and promotion of diverse associates.

In addition to our robust internal development offerings, we participate in the Leadership Council on Legal Diversity's (LCLD) action programs, which are designed to help adiverse generation of new lawyers ascend to positions of leadership. We nominate high achieving partners and associates for both the LCLD Fellows and Pathfinders Programs,and the firm sponsors their participation through the LCLD leadership training and relationship building programs each year.

Covington & Burling LLP2018 VAULT/MCCA LAW FIRM DIVERSITY SURVEY

Response to Spring 2018 Vault/MCCA Law Firm Diversity Survey. Complete survey results available in Law Firm Diversity Database

(http://mcca.vault.com). Copyright © 2018 Vault.com Inc. and Minority Corporate Counsel Association, Inc. All rights reserved.

To measure and assess the effectiveness of our diversity and inclusion efforts, we are tracking our promotion and retention rates among our underrepresented groups. The firm hasa Standing Committee on Women, led by Emily Henn, a litigation partner in our Silicon Valley office. This Committee develops an annual report to the Management Committeeand monitors the progress of women in all facets of the firm's activities, from recruiting through promotion and leadership opportunities. The Diversity Committee similarlymonitors the progress of our lawyers of color and LGBT lawyers.

Additionally, the firm has partnered with Diversity Lab and several other leading law firms to pilot the "Mansfield Rule" to boost diversity within the firm and the profession. TheMansfield Rule measures whether law firms have affirmatively considered women lawyers and lawyers of color-at least 30 percent of the candidate pool-for promotions, seniorlevel hiring, and significant leadership roles in the firm. The Mansfield Rule was inspired by the NFL's Rooney Rule which requires every NFL team to interview at least oneminority candidate for head coach vacancies and doubled the number of minorities hired into those roles.

Finally, the centerpiece of an effective professional development program that promotes diversity and inclusion is a diversity and inclusion education or training program. To thatend, we have engaged one of the best trainers in the industry to conduct unconscious bias training for lawyers across the firm, which we are rolling out in phases. Although therehas been a lot of dialogue on implicit and unconscious bias, unpacking this concept to understand the myriad of "mental shortcuts" we take that impact how we work with andvalue others is critical to the diversity and inclusion journey of any organization.