I, Nicole Y. Lamb-Hale, personally commit to the following:

Personal Commitment

I. Internal Legal Function

• I have ten direct reports who are the most senior lawyers in the function and I will ensure that 2 or more of my direct reports are African American and 2 or more are women.
• I commit that my successor will be diverse.
• I will ensure that the U.S. legal function is diverse, throughout all levels, specifically representative of women, African Americans and other POCs
• Ensure we begin with a diverse slate for every open position and candidates meet all of the stated qualifications
• Ensure the hiring manager and interviewers have a lens for understanding the business need for diverse talent/representation
• Ensure that I am actively engaged in the recruiting, retention, development and promotion of all diverse lawyers including a detailed workplan
• I will ensure that each of my direct reports includes in their succession plans diverse talent.
• I will sponsor, mentor, and assist African American and diverse talent to ensure visibility to leaders. across the enterprise, development roles (e.g. LCLD, Exec. Coaching, Executive Development programs) and challenging experiences to ensure personal and professional development/growth 
• I will require lawyers to join external trade associations, affiliates and organizations (e.g. ABA, NBA, AIPLA, IPO, LCLD, ACC) to discuss the importance of racial diversity, Cummins commitment to racial diversity, and the execution of our diversity strategies
• I will ensure that all lawyers in the legal function have a workplan that includes diversity engagement, DE&I training (e.g. unconscious bias, courageous conversations about race, why it’s important to understand privilege) and have a safe space to engage in and understand systemic issues related to race and gender 
• I will ensure that legal function employees are actively involved in work streams under Cummins Advocating for Racial Equity (CARE)
• I will ensure that my legal team is equipped to hold external counsel accountable to our Performance Scorecard metrics related to staffing matters with racial diversity (in addition to gender diversity and other diversity metrics) that lead matters as well as work significant hours
• I will continue to use Cummins legal work to develop and promote talent. Although we do not hire lawyers directly from law school, we established a summer intern program and a fall extern program to hire diverse talent and to have visibility to talented law students. We have partnered with our law firms so that our legal interns work on our matters and the law firms thereby have visibility to the talent, we do a rotational program with our law firms and we assist in finding employment. Our interns have a 100% law firm placement rate.

II. External Law Firm Accountability

• Diversity is a core value at Cummins. I commit to reinforce with the CEO and C-Suite Leadership team the value of our continuing retention of law firms and lawyers who share this core value. 
• I will continue to maintain a Preferred Provider list of 25 law firms with at least half of our relationship partners being a POC or woman. Each law firm is required to strive to achieve 60-75% of the hours worked on Cummins matters be performed by POCs and women. 85-95% of all legal work flows through Preferred Provider law firms.
• I will continue to have an “exceptions” process to the Preferred Provider list for African American lawyers/firms, Women law firms, or POC law firms to have visibility and access to additional talent 
• I will continue to have open and transparent conversations with all of my lawyers and law firms, including a meeting with the managing partner about the importance of diversity to Cummins. Accordingly, I will continue to require each law firm to report metrics every 6 mos. We review these metrics (in person) and discuss who worked on our matters, what matters they worked on (for complexity and substance of work performed), how many hours were billed and whether they had visibility to the Cummins internal legal team and/or internal business leaders
• We review staffing of every matter and change staffing where necessary so as to include African American and female lawyers and hold the law firms accountable for ensuring that these lawyers are mentored, trained, supported, and acknowledged for the work
• We encourage (and sometimes require) law firms to have diverse lawyers make presentations to our teams on CLE’s (or substantive matters) for value added services so that we get visibility to talented diverse lawyers
• We engage in DE&I work with our law firms including DE&I training
• Law Firms who reach/exceed the metrics are rewarded with more work, law firms who consistently fail to do so may be (and have been) terminated

Organizational Commitment

• I commit to ensuring that the Cummins organization as a whole is aware of the time, talent and commitment of all the lawyers in the legal function to DE&I, especially in creating the right environment for growth/development for African Americans and female lawyers
• I commit to ensuring that all diverse employees are treated fairly and equitably in the performance evaluation and management process
• I commit to ensuring that our lawyers are members of or lead the entire Company on DE&I initiatives