Upbound Group, Inc. (UPBD)

Criticisms on file

• No disclosed environmental targets or emissions data; regulatory risk noted for increased climate disclosure requirements and potential supply chain disruption from climate events

  Source: UPBD 10-K Risk Factors: 'Environmental impacts and increased focus by stakeholders on environmental issues could adversely affect our business, financial condition and operating results'; MD&A macroeconomic conditions section

Disclosed initiatives

No disclosed initiatives on file for this pillar.

Criticisms on file

• High hourly employee turnover; tight labor market creates wage inflation and recruitment pressures; no disclosed diversity targets for executive/board leadership

  Source: UPBD 10-K Risk Factors: 'If we are unable to attract, train and retain managerial personnel and hourly associates in our Rent-A-Center stores and staffed Acima locations, our reputation, sales and operating results may be materially and adversely affected'
• Workforce integration risks from Brigit acquisition; Brigit segment not previously subject to Sarbanes-Oxley controls

  Source: UPBD 10-K Risk Factors: 'we may face challenges integrating Brigit, which was not subject to the rules and regulations promulgated under Sarbanes-Oxley prior to its acquisition by us, into our internal control infrastructure'

Disclosed initiatives

• Employee Attraction and Retention Strategy

  Company acknowledges need to compete for talent with consumer fintech firms and manage labor costs via training and retention programs for hourly associates

Criticisms on file

• $72.0 million legal accrual for pending regulatory and litigation matters; active FTC settlement compliance for Brigit segment

  Source: UPBD 10-K Item 1A Risk Factors and MD&A: 'at December 31, 2025, we had estimated legal accruals of $72.0 million included in accrued liabilities in our Consolidated Balance Sheet for pending legal and regulatory matters'
• Multistate and District of Columbia Attorneys General investigations involving Acima business practices; settlement expected to include injunctive relief

  Source: UPBD 10-K Risk Factors: 'in connection with the Multistate and District of Columbia Attorneys' General matters described in Note M, if we are able to reach final binding settlement agreements, we expect that any potential settlement of such matters would include injunctive relief regarding various aspects of Acima's business'
• Brigit previously settled with FTC; ongoing compliance obligations and risk of material regulatory enforcement

  Source: UPBD 10-K Risk Factors: 'Brigit previously entered into a settlement with the FTC under which it continues to have ongoing compliance obligations, noncompliance with which could result in material regulatory enforcement'
• Arbitration agreement enforceability challenged in courts; risk of class action litigation and mass arbitrations

  Source: UPBD 10-K Risk Factors: 'Our use of arbitration agreements may not allow us to avoid costly litigation or mass arbitrations'; 'judicial, regulatory or legislative actions may restrict or eliminate the enforceability of such agreements and waivers'
• Active enforcement focus from FTC, CFPB, and state regulators on lease-to-own and EWA industries; risk of unfavorable legislative changes and regulatory interpretation

  Source: UPBD 10-K Risk Factors: 'Federal and state regulatory authorities are increasingly focused on the lease‑to‑own industry' and 'Federal and state regulatory authorities are increasingly focused on the EWA industry'

Disclosed initiatives

• Internal Control Improvement

  Company implementing Sarbanes-Oxley Section 404 compliance and internal control framework to address integration of Brigit and ensure reliable financial reporting
• Executive Leadership Transition

  CEO transition June 2025 (Fahmi Karam appointed); new CFO appointed November 2025; Chief Growth Officer added September 2025