2U, Inc.

Industries Educational Resources
Subsidiaries CritiqueIt, Inc., edX LLC, TES, Inc. https://www.sec.gov/Archives/edgar/data/1459417/000145941724000011/a2u202310-kexhibit211.htm
Activism

Companies that offer so-called transgender healthcare for their employees and covered dependents.

Rating Overview

Risk Rating: Medium

2U, Inc. is Medium Risk.

2U, Inc. is Medium Risk. The company often yields to political activism in shaping corporate governance, potentially alienating consumers, dividing employees, and harming shareholders. The company implements race and identity-based policies that replace merit, excellence, and integrity with preferential treatment and outcomes. The company occasionally embraces corporate initiatives that redirect its central focus from business goals to partisan policies and divisive issues at times. This approach fails to safeguard free exercise, free speech, and free enterprise.

Rating Criteria

Corporate Weaponization Risk Levels
Criteria Risk Level
Cancellations Medium Risk
Discriminatory Philanthropy Lower Risk
Employment Protection High Risk

Corporate Weaponization

Corporate Governance and Public Policy Risk Levels
Criteria Risk Level
Advocacy Bias High Risk
Funding Medium Risk
Political Actions No Data

Corporate Governance and Public Policy

Rating Criteria Detail

Criteria Risk Level Rationale

Corporate Weaponization


Criteria:

Has canceled customers, suppliers, or vendors due to their political views or religious beliefs OR corporately boycotts, divests, or sanctions regions, people groups, or industries.

Risk Level:

Medium

Rationale:

2U received a score of 55 on the 2025 Corporate Equality Index (CEI) from the Human Rights Campaign (HRC), a political stakeholder group. The company recruits employees based on sexual identity issues, indicating it prioritizes sexual issues over merit (1)(2). The company integrates ESG into its business practices. From its 2022 ESG Report: “Our commitment to social responsibility is central to everything we do” (3). From its 2024 Proxy Statement: “We include diversity-related measures as key goals in our bonus plan” (4). However, the company has not canceled customers, suppliers, or vendors based on political views or religious beliefs (5).

Criteria:

Charitable giving (including employee matching programs) policies or practices discriminate against charitable organizations based on views or religious beliefs.

Risk Level:

Lower

Rationale:

2U does not appear to discriminate against charitable organizations based on views or beliefs. Its charitable giving focuses on education and equity (1).

Criteria:

Employment policies fail to protect against viewpoint or other discrimination and/or are ideological in nature.

Risk Level:

High

Rationale:

2U offers DEI and allyship training to its employees (1). The company appears to prioritize diversity over merit in its leadership composition. From its 2024 Proxy Statement: “The Company has a strong track record of diversity on the Board and will continue to view diversity as an important consideration in its composition” (2). The company appears to prioritize diversity over merit in its business structure through the establishment of gender and racial targets for its leadership composition. The company is seeking 3 board directors that are either female or from underrepresented communities (3). The company does not provide viewpoint protections for its employees (4).

Corporate Governance and Public Policy


Criteria:

Uses corporate reputation to support causes, organizations, or policies hostile to freedom of expression.

Risk Level:

High

Rationale:

2U opposed various state and local legislation intended to protect parental rights, girls’ sports, bathroom facilities, and gendered spaces (1)(2). The company signed an open letter endorsing the Equality Act, a contentious proposal to amend the 1964 Civil Rights Act by adding sexual orientation and so-called gender identity as protected categories. The legislation would, among other implications, grant biological men access to women-only spaces such as sports teams and public restrooms, and compel healthcare providers to deliver sex-denying healthcare (3). The company supports DEI within its business practices. From its 2024 Proxy Statement: “We have incorporated diversity, equity and inclusion (“DE&I”) into the fabric of our corporate culture” (4).

Criteria:

Uses corporate funds to advance ideological causes, organizations, or policies hostile to freedom of expression.

Risk Level:

Medium

Rationale:

2U’s HRC 2025 CEI rating indicates the company covers transgender related costs for its employees and their children, including paid short-term leave, puberty blockers, cross-sex hormones, chest surgeries, genital surgeries, medical visits and lab monitoring, travel and lodging. By allowing a political stakeholder group to dictate operations, the company increases health care costs and risks dividing employees, alienating customers and harming shareholders (1)(2). Otherwise, there are no publicly known cases of 2U using corporate funds to advance ideological causes, organizations, or policies (3).

Criteria:

Uses corporate political actions and/or financial contributions for ideological, non-business purposes.

Risk Level:

N/A

Rationale:

2U does not operate a PAC or report on its lobbying at this time (1)(2)(3).