Fair Pay & Worker Respect

Upstart's CEO, Dave Girouard, had a pay ratio of 37:1 in 2023.

This ratio is calculated by dividing his total compensation of $7,115,630 by the median employee compensation of $191,700. This data is sourced from proxy statements filed with the SEC.

Fair Trade & Ethical Sourcing

Upstart Holdings, Inc. operates as an AI lending marketplace, generating revenue from referral and platform fees for loan originations and servicing, and providing technology and analytics services. Its business model does not involve the procurement or trade of physical commodities.

Consequently, the provided articles, which discuss fair lending practices and general corporate social responsibility, do not contain any specific, concrete data points relevant to the ethical sourcing KPIs, such as fair trade certification share, supplier audit frequency, forced or child labor incidents, supply chain traceability, remediation speed, ethical clause coverage in supplier contracts, materials risk index, or supplier diversity spend related to physical goods.

Honest & Fair Business

Upstart Holdings, Inc. received a subpoena from the SEC on November 17, 2023, regarding disclosures related to its AI models and loans.

The company cooperated with the SEC, and the probe was closed as of May 7, 2025. Additionally, a three-year no-action letter from the CFPB, issued in 2017, was terminated in June 2022. This termination occurred because Upstart sought to modify its underwriting and pricing model, which interfered with the CFPB's review process. No specific quantitative data points were provided in the articles for any of the defined KPIs, such as regulatory fines, transparency index scores, or the presence and strength of a whistle-blower policy.

Kind to Animals

Upstart Holdings, Inc. operates as an AI lending marketplace, providing digital services.

Its business model does not involve physical products, animal-derived ingredients, animal testing, animal husbandry, or animal agriculture. Therefore, all KPIs related to cruelty-free certifications, animal testing, animal-derived inputs, animal operations, and animal welfare policies are not applicable to the company's activities.

No War, No Weapons

Upstart Holdings, Inc. operates as an AI lending marketplace, connecting consumers with partner banks and credit unions for various loans.

The company's revenue is derived from referral and platform fees from these lending activities. No evidence in the provided articles suggests any involvement in arms manufacturing, military contracts, dual-use technology, sales to embargoed regimes, or any other activities related to war or weapons. The company's core business model, as described, does not involve any defense or arms-related activities, making these KPIs not applicable.

Respect for Cultures & Communities

No cultural appropriation incidents have been reported.

The company's operations, primarily as an AI lending marketplace, do not inherently involve activities that typically require cultural impact assessment protocols, Free, Prior, and Informed Consent (FPIC) processes, or direct community governance inclusion. There is no evidence of specific cultural site disruptions or the need for a social license to operate. No information is available regarding a cultural incident response framework.

Safe & Smart Tech

Upstart underwent a years-long fair lending monitorship, which identified approval disparities for Black applicants.

The company implemented a Proxy Identification Methodology, an Age Proxy Policy, enhanced disparate impact testing protocols, and adopted a practical significance threshold for adverse impact ratios. Upstart created a Fair Lending team, implemented more frequent bias testing, and improved model governance processes. However, Upstart disagreed with a key recommendation for a less discriminatory alternative model, claiming it would compromise accuracy, and the monitor did not validate Upstart's proposed alternative. Transparency about specific algorithm changes has been limited, citing intellectual property concerns. Upstart encrypts all customer data, including data in transit, using modern encryption standards. Multi-factor authentication is offered to all customers and mandated for individuals accessing customer data. The company has a vulnerability reporting mechanism and engages third-party auditors to review its security program. Upstart states it collects data directly from consumers, consumer reporting agencies, or from consumer interactions, and aims for transparency in credit decision factors. However, the company made changes to its educational data usage, moving from average SAT/ACT scores to average post-graduation income for school grouping, and estimates demographic attributes via location and surname using the BISG methodology rather than collecting it directly. Upstart's AI lending algorithm exhibited bias in 2021, resulting in 10-15% higher denial rates for Black and Hispanic applicants compared to white applicants with similar creditworthiness. Upstart cooperated with the CFPB investigation, but limited transparency about specific algorithm changes and failed to address disparities in interest rates and terms.