Nonprofit As You Sow has told media representatives that both firms have submitted ‘no-action’ requests to the Securities and Exchange Commission (SEC) in the US, in relation to shareholder resolutions it has filed ahead of the upcoming Annual General Meeting season.
The resolutions called for both companies to set out how they are protecting employees from climate risk stemming from where they invest employees’ pensions.
As You Sow argues that, because high-carbon investments increase climate-related systemic risks over time, investing in this manner increases the likelihood of diminishing returns. Alternatively, if the global economy does move more rapidly than expected in the low-carbon transition, high-carbon investments can lead to diminished returns because they can become stranded assets.
In filing a ‘no-action’ request to the SEC, corporations seek to block a vote being held on shareholder proposals. Both Amazon and Comcast are arguing that shareholders do not have the right to information about climate risk stemming from their default 401(k) plans for staff. As You Sow is contesting the requests by submitting its own briefs to the SEC.
“Employees saving for their future continue to be denied the freedom to invest the way they want to invest,” said As You Sow’s chief executive Andrew Behar.
“It’s a matter of personal freedom, and these companies are denying that freedom by offering default investment options filled with fossil fuels, deforestation, private prisons and weapons companies.”
edie has reached out to both Amazon and Comcast for comment. A Comcast spokesperson said the firm will not be commenting further to the SEC filing. The filing “respectfully requests” that staff concur that information about the company’s ordinary business operations, including employee benefits and compensation, should not be made public.
Comcast’s filing also calls As You Sow’s wording “misguided in several respects”. It argues that the board does not hold responsibility for pension plans, for example.
2023 marks the second consecutive year that As You Sow has filed resolutions at Amazon and Comcast, asking both firms to disclose more information about climate risk management relating to pension investments. Last year, resolutions at both companies achieved a high enough shareholder vote to be refiled again this year.
At Comcast last year, as you sow asked the broadcasting giant to provide information on the degree to which carbon-intensive investments feature in its default investment option – Vanguard Target Retirement funds. It noted that these funds were ranked poorly on fossil fuels, deforestation and tobacco by Invest Your Values. Amazon, As You Sow noted in its 2022 filing, uses the same default investment option.
An Amazon spokesperson said the firm has not changed its position since last year. Last year, it stated: “Our 401(k) plan has for many years offered plan participants an ESG screened investment option. Further, the managers of most of the plan’s core investment options currently consider and integrate ESG factors in their stewardship or security selection processes.
“Also of note, the plan offers a self-directed brokerage option that gives plan participants the ability to invest some or all of their plan accounts in hundreds of ESG-friendly funds (in addition to thousands of other investment funds). The array of ESG-friendly investment opportunities means that plan participants already have the ability to invest their plan accounts according to their personal ESG strategies.“
Employee demands
As You Sow is arguing that, in failing to respond to the growing demand for “climate-safe, sustainable investment options” from workers, companies “are not only exposing their workers to climate-related financial risk, but also may have issues with hiring and employee retention”.
KPMG recently published research on what it is deeming “climate quitting” – a phenomenon involving employees either leaving jobs or turning down job offers because they are unimpressed by employers’ pledges and performance relating to environmental, social and governance (ESG) topics.
KPMG found that one-fifth of UK-based office workers would turn down a job on ESG grounds. It also found that almost one-third of people have researched a company’s ESG approach thoroughly before applying for a role there.
Last year, a survey from Censuswide on behalf of Arriva found that the majority of UK adults would consider leaving their current job in order to pursue a role they perceive as “greener”.
This trend can also be observed in the US. Former Unilever chief executive Paul Polman this week published his first Net-Positive Employee Barometer, tracking the attitudes of more than 4,000 workers in the US and UK. 68% of those polled said they were not satisfied with the ESG performance of their employers, and almost half (45%) said they would consider resigning from a position if their values were misaligned with their employers’.
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