Shareholder Advocacy

wheatNatural Investments uses the power of share ownership to influence corporate policy.

Managers of funds and other products held in our client portfolios are committed to various forms of advocacy:

  1. Dialogue with management
  2. Filing and supporting shareholder resolutions
  3. Testimony to regulators and elected officials addressing corporate reforms

Our Director of Social Research serves on the Public Policy Committee of USSIF: The Forum for Sustainable and Responsible Investment as well as the American Sustainable Business Council. The firm is also a member of American Business for Clean Energy.

On select environmental, social, and governance issues, our firm will independently participate in public policy and shareholder advocacy initiatives of particular interest. This is done through signing onto letters written by other investment, social research, or related firms to corporate management, regulatory agencies, elected officials, or amicus Supreme Court briefs. We also meet in person with elected representatives in Congress and the regulatory agencies to share the perspective of our firm and industry about important legislative issues.


In the past few years, our efforts have included the following…

Advocacy in 2014

  • Meetings with various SEC Commissioners and staff, including Office of Investor Advocate, to protect right of shareholders to file resolutions
  • SEC disclosure effectiveness review
  • Payment disclosure by extractives rule
  • Pay disparity disclosure
  • Corporate political contributions disclosure
  • Climate Protection Act (the Boxer-Sanders bill)
  • Advocacy for SRI option for federal employees legislation
    Financial Transactions Tax
  • Comments on the Proposed SEC 2014-2018 Draft Strategic Plan, proposal on ESG disclosure from 2009 requesting mandatory corporate environmental, social and governance (ESG) disclosure and making ESG or “sustainability” reporting a top priority
  • Conflict minerals letter to the European Commission
  • Participation in Climate Summit
  • Meeting with U.S. Chamber of Commerce to find areas of common ground
  • Letter to Congress rejecting the Partnership to Build America Act allowing U.S. multinational corporations to bring home offshore profits tax-free if some of the money is used to buy bonds in an infrastructure bank.

Natural Investments supported various corporate engagement and policy initiatives in 2014:

  • Investor letter to the Top 50 corporate opponents of Prop 37 and I-522 conveying concerns about political spending to oppose GMO labeling referenda
  • Investor letters – one to the U.S. Environmental Protection Agency (EPA) and one to the United States Department of Agriculture (USDA) – expressing concern over the deregulation of new genetically engineered (GE) crops, developed by Dow Chemical, known as Enlist, designed to survive repeated spraying of the herbicide (2,4-D) until a thorough environmental review of these crops has been conducted.
  • Successful campaign with Exxon to get them to acknowledge fracking risk
  • Pressure on apparel companies operating in Bangladesh to sign worker safety accord
  • Letter to Bank of America in support of shareholder resolution calling for a Climate Change Report including a request that the company Assess/Report on GHG Emissions Resulting from their Lending Portfolio.

Advocacy in 2013

Michael joined the USSIF Public Policy Committee to shape policy priorities and oversee the organization’s strategic policy agenda, including providing guidance on USSIF’s statements on:

  • the longstanding value of shareholder advocacy as an exercise of owner rights;
  • the range of options for addressing fossil fuels and SRI;
  • President Obama’s Climate Change Plan, which limits carbon pollution from existing and new power plants, establishes stringent fuel efficiency standards for heavy duty trucks and appliances, sets ambitious goals for energy efficiency and renewable energy generation on public lands and by federal agencies, and prepares communities for the impacts of climate change that are already occurring;
  • the global integrated corporate sustainable reporting framework under development by the International Integrated Reporting Committee (IIRC)

Natural Investments supported various corporate engagement and policy initiatives in 2013:

  • Dialogue with companies
    •  Costco sustainable seafood initiative
  • Letter-writing, email campaigns, and lobbying
    •  Successfully pressured the SEC to issue a forthcoming rule requiring that corporations
    disclose all political spending
    •  Successfully pressure the SEC to issue a forthcoming rule requiring disclosure of the
    ratio of CEO to worker pay
  • Letter to U.S. clothing manufacturers and retailers demanding they:
    •  Sign the Benghazi Accord on Fire and Building Safety;
    •  Commit to strengthening local trade unions and to ensuring a living wage for all
    workers;
    •  Publicly disclose all their suppliers including those from Bangladesh, the programs they
    have in place to ensure the safety and health of all their workers and their performance
    against these goals including any corrective action; and
    •  Ensure that appropriate grievance mechanisms and effective remedies for affected
    workers and families, including compensation, are in place.
  • Letter to Senator Johnson, Chair of the Senate Banking Committee, defining the criteria by which USSIF believes two new SEC Commissioners should be appointed
  • Letter asking Google for political transparency, and to leave the U.S. Chamber of Commerce due to its political activities
  • Letter to Congress in support of the Holding Individuals Accountable and Deterring Money Laundering Act, which requires bank executives and directors to approve and monitor their institutions’ anti-money-laundering policies and procedures, and strengthen the legal and regulatory framework for holding executives and other bank employees individually liable for money laundering violations.
  • Letter to Congress in support of the Incorporation Transparency and Law Enforcement Assistance Act that disclose information on the owners of corporations
  • Successfully persuaded the government of Alberta to implement an effective environmental monitoring program for the oil tar sands activities overseen by a science-based, independent agency paid for by industry at $50 million/year
  • Letter to Congress and corporations to put immigration reform on the top of the legislative agenda and provide a pathway for undocumented immigrants to earn legal status as an economic, business and human rights imperative
  • Lobbied in support of H.R. 1278 – Non-Disparagement of American Indians in Trademark Registrations Act of 2013 to encourage FedEx and Bank of America to change the name of the disparaging Washington Redskins name
  • Letter to Walmart, Target, Costco, Kroger, Walgreens, Home Depot, CVS, Lowe’s, Best Buy, and Safeway requesting that they minimize the presence of toxic chemicals in products sold on company store shelves

Advocacy in 2012

  • Lobbied Congress in support of the Federal Employees Responsible Investment Act, which would make sustainable and responsible investments available to 4.4 million federal employees in their $270 billion retirement plan.
  • Lobbied Congress for the reauthorization of the $221 million Community Development Financial Institutions fund, which supports core CDFI lending and technical assistance as well as the extension of the New Markets Tax Credits.
  • Lobbied Congress to uphold the December 2011 Utility Mercury & Air Toxic Standard for fossil fuel plants, which was scheduled for reconsideration in 2012. Additional lobbying was conducted to encourage maintenance of the EPA’s $8.3 billion budget that House Republicans reduced by 17%.
  • Letter to Congress urging the passage of immigration reform legislation that would allow undocumented immigrants, who represent over 5% of the American workforce, a pathway to legal status.
  • Letter to the SEC urging the issuance of a final rule on Conflict Minerals Due Diligence and Reporting under Section 1502 of the Wall Street Reform and Consumer Protection Act. (succeeded)
  • Letter to Congress in support of the Wall Street Trading and Speculators Tax Act, which levies three basis points on most non-consumer financial trading, including stocks, bonds, all derivative contracts, options, puts, forward contracts, swaps and other complex instruments.
  • Investor statement to the SEC and Department of Justice in support of the U.S. Foreign Corrupt Practices Act and its continued vigorous enforcement to reign in the bribery and corruption used by American corporations with foreign governments that compromise shareholder value by altering procurement, product quality and safety standards for financial gain.
  • Letter to management of 40 companies that are members of American Legislative Exchange Council and the Heartland Insititute asking them to reconsider membership in these advocacy groups given the reputational risks to the companies via association with the groups’ positions on Stand Your Ground laws, anti-immigration legislation, denial of climate change, and an aggressive attack on the Environmental Protection Agency. (succeeded)
  • Letter to SEC demanding that rules requiring disclosure of corporate political spending be established; a record 178,000 comments were submitted on this topic to the SEC.
  • Letter to Congress in support of the DISCLOSE Act that establishes new campaign finance disclosure requirements and make public the names of super PAC contibutors.

Advocacy in 2011

  • Letter to President Obama and the leaders of Congress to form the Consumer Financial Protection Bureau (CFPB) and appoint as its’ director Elizabeth Warren.
  • Provide adequate funding for the Commodities Futures Trading Commission and Securities and Exchange Commission to not only get back to 2006 funding levels but to be able to implement all the new requirements of the Dodd-Frank legislation, such as re-establishing the Investor Advisory Committee and the Office of Investor Advocate, issue 41 new rules (of which 7 have been issued in final form to date), complete 20 requested studies (of which 7 have already been completed), oversee 100 new regulations, establish five new offices (to regulate derivatives, register hedge and private equity funds, monitor credit rating agencies, investigate the claims of whistleblowers, and oversee advisors in the municipals field).
  • Establish SRI option for federal employees. HR 2130 was introduced in May, 2011, and would provide SRI funds in federal employee retirement plans.
  • Provide adequate FY2012 funding for the Community Development Financial Institution Fund.
  • Prohibit the passage of legislation to prevent the EPA from regulating greenhouse gas emissions and creating new legislation that addresses the risks and opportunities presented by climate change.
  • Letter in support of Dodd-Frank Act provisions which mandate that: institutional investment managers report on an annual basis their votes on any non-binding shareholder advisory votes on executive compensation and on golden parachute compensation resolutions; corporate issuers place on the ballot three compensation-related votes: advisory votes on compensation (Say on Pay), shareholder votes on golden parachutes in merger and acquisition transactions; and the SEC issue rules providing for shareholders to elect directors to corporate board.
  • Letter to SEC re: Conflict Minerals Disclosure for Companies in Congo.
  • Letter to Senate re: Acting on Climate Change Legislation, specifically to block any moves to strip authority to regulate greenhouse gas emissions from the Environmental Protection Agency (EPA). Separate letter to Congressional leaders on this topic.
  • Letter to House of Representatives in support of legislation that pierces the veil shrouding the financial activites of corrupt foreign politicians who enrich themselves at the expense of their own citizens and increases the transparency of revenue flows into developing nations with significant natural resource wealth to ensure those extractive industries’ revenues are used for the benefit of the people of those countries.
  • Shareholder engagement with Costco resulting in establishment of the company’s first sustainable seafood policy.
  • Letters to prominent US Chamber companies (Alcoa, AEP, Boeing, ConocoPhillips, Cummins, Deere & Co., Dell, Dow, Duke Energy, DuPont, Exelon, Ford, FPL Group, General Electric, GM, IBM, Intel, Johnson & Johnson, Merck, Microsoft, PepsiCo, Timberland, Weyerhaeuser, Whirlpool Corporation, and Zerox) regarding their membership in the U.S. Chamber of Commerce given its’ backwards position on climate change.
  • Letter to Russell 1000 companies encouraging them to establish and disclose comprehensive, sustainable business strategies and to consider the Ceres Roadmap as an implementation tool.
  • Formal endorsement of the report, An Agenda to Strengthen Our Right to Know: Empowering Citizens with Environmental, Health, and Safety Information, which includes recommendations to the President on improving access to key environment, health, and safety information, protecting minority and low-income communities from environmental harm than other communities and tracking and communicatiing the health risks from chemicals to the public (particularly vulnerable populations such as pregnant women and children).
  • Signed the 2011 Global Investor Statement on Climate Change of the Institutional Investors Group on Climate Change, the Investor Network on Climate Risk, the Investor Group on Climate Change, the UNEP Finance Initiative, and the UN Principles of Responsible Investment.
  • Letter to the governments of Canada and Alberta for committing to the creation of a world-class monitoring system for the oil sands region of Alberta.

Advocacy in 2010

  • Letter in support of Dodd-Frank Act provisions which mandate that institutional investment managers report on an annual basis their votes on any non-binding shareholder advisory votes on executive compensation and on golden parachute compensation resolutions; corporate issuers place on the ballot three compensation-related votes: advisory votes on compensation (Say on Pay), shareholder votes on golden parachutes in merger & acquisition transactions; and the SEC issue rules providing for shareholders to elect directors to corporate boards.
  • Letter to Congress in support of the Restoring American Financial Stability Act of 2009.
  • Letter to SEC re: Conflict Minerals Disclosure for Companies in Congo
  • Letter to Senate re: Acting on Climate Change Legislation, block any moves to strip authority to regulate greenhouse gas emmissions from the Environmental Protection Agency (EPA).
  • Letter to House in support of legislation that pierces the veil shrouding the financial activities of corrupt foreign politicians who enrich themselves at the expense of their own citizens and increases the transparency of revenue flows into developing nations with significant natural resource wealth to ensure those extractive industries’ revenues are used for the benefit of the people of the countries.
  • Shareholder engagement with Costco re: sustainable seafood policy.
  • Letters to prominent US Chamber companies (Alcoa, AEP, Boeing, ConocoPhillips, Cummins, Deere & Co., Dell, Dow, Duke Energy, Dupont, Exelon, Ford, FPL Group, General Electric, GM, IBM, Intel, Johnson & Johnson, Merck, Microsoft, PepsiCo, Timberland, Weyerhaeuser, Whirlpool Corporation, and Xerox) regarding their membership in the U.S. Chamber of Commerce given its’ backwards position on climate change.