Key lives its commitment to the principle of equity at every level across our workforce.

At Key, our commitment to pay equity is foundational to our culture. We support this commitment through our compensation practices in the following ways:

  • We maintain a formal compensation structure to establish pay on the basis of objective factors, including external survey data, required education and experience. We regularly review this structure in light of market trends and internal equity.
  • We have a pay-for-performance philosophy in which pay decisions are based on the assessment of individual performance, business unit performance and the performance of Key. These decisions also consider performance against risk expectations and whether an employee has exhibited behaviors consistent with our values.
  • We conduct robust annual statistical analyses of pay and performance decisions. These analyses compare compensation and performance ratings of employees in similar roles to assess whether males and females and minorities and non-minorities are compensated equitably. . A regression analysis is conducted to compare race and gender against variables which should impact pay (e.g., role, performance rating, length of service).

To the extent that statistical disparities are identified, further analysis is conducted to identify whether valid job-related factors explain the disparity. Otherwise, the disparity is remediated. As part of these analyses, we review all elements of pay (salary and discretionary incentives, including both cash and long-term) for all employees, other than for our executive team whose pay is set by the Compensation and Organization Committee of our Board of Directors). In our most recent review conducted year-end 2020, differences were found for less than 0.2% of employees, and adjustments were made to resolve the disparities. All other differences were determined to be based on job-related reasons, and no adjustments were necessary for those employees.

In compliance with various state and local laws and as part of Key’s long-standing commitment to equal employment opportunity, Key does not seek current base compensation information from applicants, regardless of location, or consider an applicant’s compensation history when formulating an offer. Key also provides salary range information when requested by applicants, thereby supporting greater pay transparency during the hiring process and further enhancing practices that support pay equity and fairness.

We continually assess and enhance our practices. For example, the framework used to analyze pay discrepancies has been in place for more than 10 years, and it has evolved over this time to become even more comprehensive. Therefore, we believe our practices are an effective control to monitor and address pay inequities.

Results will be shared with the Executive Leadership Team and our Board of Directors.

Key is an Equal Opportunity and Affirmative Action Employer.