Cummins Confidential Special: CEI 100 – The Checkbox Crown And The Confidence Trick

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Cummins loves numbers that look like rankings and behave like alibis. The Corporate Equality Index score of 100 is one of its favourites.

One hundred sounds definitive. Perfect. Finished. Case closed.

It is none of those things.

CEI 100 is not a verdict. It is not an audit. It is not proof of anything that happens when a worker is inconvenient, unwell, expensive, or no longer photogenic.

It is a checklist. Cummins filled it in. Cummins passed. Cummins now sells the result to customers and investors as reassurance.

That is where this stops being cosmetic and starts looking misleading.

The Badge Cummins Wants You To Believe In

Cummins boasts that it scored 100 on the Human Rights Campaign Foundation’s Corporate Equality Index. It frames this as being a “Best Place to Work for LGBTQ Equality”.

The language is deliberate. “Best”. “Equality”. “Top score”.

Those words are chosen to make customers and investors infer safety, decency, and low risk.

The problem is that CEI does not measure any of that.

What CEI 100 Actually Certifies

CEI is a policy-based survey completed by the company itself. A score of 100 means Cummins demonstrated that it has written policies, stated commitments, benefits structures, training, and public-facing positioning that match the framework for that year.

That is it.

There is no employee vote. No anonymous workforce feedback. No investigation of complaints. No testing against legal outcomes. No penalty mechanism for lived experience to override paperwork.

The CEI itself spells it out. It is a roadmap to inclusive policies and practices, but it cannot provide a holistic assessment of unique workplace cultures or individual experiences.

Cummins knows this.

Cummins uses the badge anyway.

The Non-Ranking Disguised As Leadership

Here is the trick Cummins never explains.

CEI does not rank companies. There is no first place. No top ten. No league table.

In the 2022 CEI, a record 842 businesses met all criteria and earned a 100 percent rating and the “Best Place to Work” designation. That is not elite performance. That is a mass-participation gold star.

So when Cummins implies leadership, superiority, or excellence, it is leaning on a false impression created by a number that looks competitive. It is not.

CEI is binary. Pass or fail. Badge or no badge.

Yet Cummins markets it like a crown.

Not Pay-To-Play, Just Pay-To-Package

Cummins will say CEI is not pay-to-play. Technically, that is correct. There is no cheque written directly for the score.

That is not the point.

CEI is pay-to-participate in substance. It is opt-in submission, internal resource allocation, policy engineering, consultant optimisation, communications packaging, and annual repetition.

The currency is not cash. The currency is narrative control.

Cummins spends time and money ensuring it qualifies, then monetises the result in PR, recruitment, ESG decks, and customer-facing trust theatre.

That is not independent validation. That is self-certified credibility laundering.

The Pattern TCAP Has Already Exposed

This is not an isolated badge. CEI sits neatly alongside the rest of Cummins’ confidence stack.

Disability:IN and its membership ecosystem. Disability Equality Index scores. Corporate mental health awards. ESG lists. The whole “look how good we are” buffet.

TCAP has already shown how this works.

Self-report. Submit. Score. Badge. Repeat.

Real people still get chewed up when the branding stops working.

CEI does not break that pattern. It perfects it.

Why This Can Mislead Customers And Investors

This is where Cummins crosses from spin into risk.

When Cummins presents CEI 100 as evidence of equality leadership, it invites stakeholders to infer low discrimination risk, strong governance, safe culture, and reduced human capital exposure.

CEI does not measure those things.

Customers choosing suppliers may believe they are dealing with a low-risk organisation. Investors assessing ESG and human capital risk may believe exposure is contained.

That belief is not supported by what CEI actually evaluates.

This is not about whether the score is “accurate”. It is about whether the impression created is honest.

A checklist score is being used like a warranty sticker.

That is a confidence trick.

The Real Function Of CEI Inside Cummins

CEI gives Cummins a number it can point to when challenged.

Not evidence. Not accountability. Not outcomes.

Just a number.

A number that looks authoritative enough to end the conversation.

The Question Cummins Never Answers

If Cummins’ culture is as inclusive, safe, and equitable as its badge wall suggests, why does it need so many certificates to convince people?

Why does a company so confident in its ethics lean so heavily on schemes that never investigate, never verify, and never look at consequences?

Because badges do not testify. Badges do not sue. Badges do not bleed.

Bottom Line

CEI 100 is not proof of equality. It is proof of paperwork.

Used responsibly, it is a benchmarking tool. Used the way Cummins uses it, it becomes a trust proxy.

And when trust proxies are sold to customers and investors as if they were reality, that is no longer just PR fluff.

That is misdirection.

Lee Thompson – Founder, The Cummins Accountability Project

Sources

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