Shareholder Advocacy Review – Summer 2022

Government Advocacy

Our engagements with lawmakers this quarter focused on deforestation, climate change risk, and workers’ rights. We signed a collaborative investor letter facilitated by Domini Investments in support of the Fostering Overseas Rule of Law and Environmentally Sound Trade (FOREST) Act, which prohibits access to U.S. markets for commodities that originate from illegally deforested land. The bill criminalizes illegal deforestation, increases transparency in reporting companies’ international supply chains, and provides a federal government purchasing preference for deforestation-free products.

We submitted a comment letter responding to the U.S. Department of Labor’s Request for Information on climate risks in retirement and pension plans. We noted that since climate-change risk is material
to the financial profitability of companies, DOL should, by rule, allow for ESG integration in how pensions are managed, and require money managers to vote proxies in accordance with ESG criteria:

“All federal regulatory agencies should be focused now on decarbonizing the economy given the threat not doing so poses to humanity. This approach is in the long-term financial interests of plan participants and retirees. We therefore encourage you to address systemic climate change risk and racial and economic inequality by allowing fiduciaries to consider ESG factors, not merely climate change, as material, and allow ESG-mandated funds to be available to plan participants. Humanity’s use of natural resources has major ecological impacts on food, water, air, forests, and land, all of which affects investment profitability.”

We also recommended that the relationship between racial and economic inequality, climate change, and all forms of climate-related risk be examined and mitigated by the Thrift Savings Plan’s investment offerings. This way, plan participants can remove major carbon-emitters from their pensions and instead support funds managed by individuals of diverse backgrounds, including race, ethnicity, gender identity, sexual orientation, and socioeconomic status.

We signed an endorsement of the “Stop Silencing Survivors Act”, legislation in New York that would allow workers to speak freely about their experiences in the workplace by barring employers from including a non-disclosure agreement and/or non-disparagement agreement in a waiver, settlement, agreement, or other resolution to an alleged violation of the human rights law or labor law. This law would prohibit the masking of harassment and discrimination at a company, similar to those enacted in California, Washington, and New Jersey.

COTTON BOYCOTT LIFTED The Cotton Campaign, which we have supported for many years through company advocacy, announced the end of a 12-year boycott of Uzbekistan cotton now that government-imposed forced labor has finally been eliminated. This is an excellent example of how the combination of diplomatic engagement and economic pressure by investors, apparel manufacturers, and local and global human rights groups can inspire government action on widespread labor exploitation.

Company Advocacy

Highlights of our corporate engagements this quarter include:

Coca-Cola: We signed a global political disclosure letter coordinated by our colleagues at Harrington Investments to Coca-Cola requesting that it produce an annual Global Transparency Report on the company’s global spending to influence public policy in the realms of political donations, lobbying, funding junk science, and charitable donations. Only 13% of shareholders voted for the proposal.

Wells Fargo: We signed a letter coordinated by the AFL-CIO to Wells Fargo that urges the company to disclose the full results of its recently completed Human Rights Impact Assessment, which aimed to align Wells Fargo’s management of human rights with leading practices focusing on diversity, equity and inclusion. Wells Fargo published a summary of recommendations from this Assessment, but the company has yet to disclose the full results that were prepared by a third-party law firm.

McDonald’s: We signed a letter coordinated by the Interfaith Center for Corporate Responsibility to McDonald’s calling on the company to fulfill its 2018 promise to set targets for reducing the use of medically important antibiotics throughout its global beef supply chain and to set a global antibiotic use policy for pork.

Tyson, Sanderson Farms, JBS, et al: We signed a letter coordinated by FAIRR (Farm Animal Investment Risk and Return) to Tyson and other major meat producers to address unfair working conditions across the sector in the areas of health and safety, sick leave, grievance procedures, and worker representation in decision-making.

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Michael Kramer

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