June 16, 2021

Dear Corporate Director:

As institutional investors, State Treasurers, or as elected and appointed fiduciaries and trustees of public funds and retirement savings with assets under management of approximately $1.5 trillion, we are concerned with the erosion of political stability in the United States. A functioning democracy is foundational to a stable economy and sustainable long-term value creation. We believe that the events of January 6, 2021 and the subsequent state-level efforts to undermine voting rights and access add greater urgency to concerns and expectations regarding corporate political spending and lobbying transparency and practices. In light of reports that our company has recently been a contributor to elected officials that opposed the certification of the electoral college results, state-level elected officials supporting restrictions on voting rights, or both, we request immediate disclosure of whether and how you will be updating our company’s political spending policies to preclude any corporate political donations to legislators that back such efforts.

We are facing an existential threat to the election system in the U.S. which poses substantial systemic risk to long-term investors’ portfolios. This is not a question of partisan politics -- many Democrats and Republicans have opposed contemporary attacks on the functioning of American democracy -- but of ensuring voter participation and enfranchisement. The question for corporations is whether to continue operating under “business as usual” assumptions or recognize this threat and take action.

The nonpartisan Brennan Center for Justice has identified 361 bills in 47 states that contain provisions to restrict the right to vote as of March 24, 2021. These bills limit absentee and early voting, seek stricter voter ID requirements, make voter registration more difficult, and undermine the power of local officials to fairly administer elections. Similarly, the Voting Rights Lab, also a nonpartisan organization, has identified 405 bills in 45 states that it considers to have “anti-voter” provisions, including restrictions on absentee and early voting, voter registration, and strict voter ID laws.

Many of these voting restrictions would disproportionately affect Black voters and other communities of color, adding another chapter to a long history of voter disenfranchisement in the U.S. As long-term investors, we recognize that systemic racism creates material portfolio-wide and company-specific risks for investors. Analysis from Citigroup shows that failure to address racial wealth gaps in wages, housing, and investment cost the U.S. economy $16 trillion over the last 20 years.

We are further concerned with the substantial reputational risks companies face through their political spending policies and practices. In the wake of the murder of George Floyd last year, many companies made public statements affirming the view that Black Lives Matter and acknowledging the existence of systemic racism and pledging to address it. Company actions that contradict stated positions create substantial risks and raise concerns about the adequacy of governance and oversight of these issues. Alienating a significant portion of the company’s employees and consumer base by supporting elected officials driving legislation that would lead to mass disenfranchisement of voters of color is not a sound or sustainable business strategy.

In recent months, many companies have made public statements in support of voting rights. However, such statements alone will not mitigate the harm of voter disenfranchisement legislation or the reputational risks to the company arising from these contradictions between a company’s stated positions and its political spending practices. Civil rights and racial justice activists are increasingly calling on corporations to cease support for elected officials promoting voter suppression. In an open letter to asset managers in the Financial Times, more than 140 racial justice leaders and allies called on shareholders to fundamentally overhaul their stewardship of companies to challenge systemic racism and white supremacy in corporate governance and behavior, including in relation to political spending.

As Chair of the relevant Committee of the board, you are responsible for ensuring oversight of our company’s policy influence activities. To mitigate the systemic risks of these anti-democratic efforts and the company-specific risks of continuing to support restrictions on the right to vote, we are calling on you to, at a minimum:

  1. Amend our company’s political contributions policy to preclude any direct or indirect contributions from the company, its subsidiaries, or affiliated Political Action Committees to any candidates, or campaign committees that support such candidates, that have attempted to restrict the right, impede access to vote, or otherwise disenfranchise or limit the civil rights of communities of color, including:

    a. Federal elected officials that voted to object to the certification of the electoral college results on January 6, 2021; and

    b. Sponsors and authors of legislation at the state level that seek to restrict voting rights or access, as identified by the Brennan Center for Justice or Voting Rights Lab.

  1. Provide full public disclosure of the recipient and amount of all direct and indirect election-related spending using corporate or treasury funds, or by corporate PACs, including donations to candidates and party committees at the state and local level, contributions to 527 political committees, ballot measure committees, independent expenditures, and payments to politically-active trade associations and politically-active tax-exempt organizations, including 501c4s.

The onus is now on the board to comprehensively reassess our company’s corporate-directed political spending policies, practices and risks. Given our concerns about the risks for our company detailed in this correspondence and our fiduciary responsibility, we are expecting to see an immediate response. Should you wish to discuss the actions you are taking with us, please contact Renaye Manley (renaye.manley@seiu.org) or Lisa Lindsley (lisa@majorityact.org).

We look forward to receiving your response.

Sincerely,

Signers

  • Renee Morgan, Adasina Social Capital

  • Fabian Willskytt, Align Impact

  • Ambassador Doug Hickey, Hickey Gryphon Equity Partners*

  • Jeffrey Haggray, American Baptist Home Mission Society

  • Patricia Bauman, Bauman Foundation

  • Lauren Compere, Boston Common Asset Management

  • Betty Francisco, Boston Impact Initiative Fund

  • State Controller, Betty Yee, California State Controller’s Office

  • Ramon Rubalcava, CalPERS*

  • Theresa Taylor, CalPERS*

  • Dorrit Lowsen, Change Finance

  • Dan Kirslis, Chicory Wealth

  • Gary Kidwell, Christian Church Foundation

  • Molly Betournay, Clean Yield Asset Management

  • Dave Young, Colorado State Treasurer*

  • Michaela Cocchi, Comitato Lady Lawyer Village

  • Rob Fohr, Committee on Mission Responsibility Through Investment of the Presbyterian Church

  • Shawn Wooden, Connecticut State Treasurer 

  • James McRitchie, CorpGov.net

  • Robert Wotypka, Corporate Responsibility Agent, Province of Saint Joseph of the Capuchin Order

  • Sister Teresa George, Daughters of Charity Ministries, Inc.

  • Colleen Davis, Delaware State Treasurer*

  • Corey Klemmer, Domini Impact Investments 

  • Mary Brigid Clingman, Dominican Sisters of Grand Rapids, MI

  • Eileen Gannon, Dominican Sisters of Sparkill, NY

  • Steve Zielinski, Dominican Sisters of Springfield, IL

  • Sarah Green, Farm Girl Capital, LLC

  • Lisette Cooper, Fiduciary Trust International*

  • Ahmed Aljuboori, Figure 8 Investment strategies

  • Sister Gloria Oehl, Franciscan Sisters of Allegany, NY

  • Sue Ernster, Franciscan Sisters of Perpetual Adoration*

  • Riley Talford, Fresno County Employees Retirement Association*

  • Amy Carr, Friends Fiduciary Corporation

  • Keith Beverly, GRID 202 Partners

  • John Harrington, Harrington Investments, Inc.

  • Theodosia Hamilton Ferguson, Healing Living Systems, Inc.

  • Gregory Simpson, Hudson River Presbytery*

  • Susan Ozawa Perez, Impact Investors

  • Joseph Keefe, Impax Asset Management, LLC

  • Josh Zinner, Interfaith Center on Corporate Responsibility

  • Mary Beth Gallagher, Investor Advocates for Social Justice

  • Samer Yousif, Investors of Color Network

  • Janet Peterworth, Ursuline Sisters of Louisville, KY*

  • Mary Baudouin, Jesuits of the US Central and Southern Province

  • Julie Hammerman, JLens

  • Andrew Shapiro, Lawndale Capital Management

  • Margaret Chapman, Leadership Council of IHM Sisters

  • Elizabeth Greenwood, Los Angeles County Employees Retirement Association (LACERA)*

  • Vivian Gray, Los Angeles County Employees Retirement Association (LACERA)*

  • David Green, Los Angeles County Employees Retirement Association (LACERA)*

  • Herman Santos, Los Angeles County Employees Retirement Association (LACERA)*

  • Henry Beck, Maine State Treasurer*

  • Carmen Rojas, Marguerite Casey Foundation

  • Reverend Joseph La Mar, Maryknoll Fathers and Brothers

  • Cathy Rowan, Maryknoll Sisters

  • Douglas Prouty, Maryland State Retirement and Pension System*

  • Theresa McGoldrick, Mass PRIM*

  • Luan Jenifer, Miller/Howard Investments, Inc.

  • Susanna Gibbons, Minnesota State Board of Investment*

  • Seamus Finn, Missionary Oblates/OIP TRUST

  • Verna Thompson, Municipal Employees' Annuity and Benefit Fund of Chicago*

  • Laura Campos, Nathan Cummings Foundation

  • Michael Kramer, Natural Investments

  • Michaela Gregory, NEI Investments

  • Bruce Herbert, Newground Social Investment

  • Mari Schwartzer, NorthStar Asset Management, Inc.

  • Judy Byron, Northwest Coalition for Responsible Investment

  • Carole Nugent, Nugent Properties*

  • Michael Kraft, NYC Board of Education Retirement Systems (BERS)*

  • ThomasSheppard, NYC Board of Education Retirement Systems (BERS)*

  • John Russell, Oregon Investment Council*

  • Irit Tamir, Oxfam America

  • Reverend Dr. Todd Adams, Pension Fund of the Christian Church

  • Michael Passoff, Proxy Impact

  • Michael Kimmel, Reform Pension Board

  • Jo Marie Chrosniak, Region VI Coalition for Responsible Investment

  • Maria Egan, Reynders, McVeigh Capital Management LLC

  • Seth Magaziner, Rhode Island State Treasury

  • Sancia Dalley, Robert F. Kennedy Human Rights

  • Lorin Silverman, SC Group

  • Ethel Howley, School Sisters of Notre Dame Cooperative Investment Fund

  • Tim Dewane, School Sisters of Notre Dame of Central Pacific Province

  • David Huerta, SEIU National Industry Pension Plan*

  • Mark Sharwood, SEIU National Industry Pension Plan*

  • T. Steven Jones, Seva Foundation

  • Anthony Schein, SHARE

  • Richard Togerson, SharePower Responsible Investing

  • Christopher Soulios, Signet Strategic Wealth

  • Mary Dugan, Sisters of Charity of Cincinnati, OH*

  • Sister Barbara Aires, Sisters of Charity of Saint Elizabeth, NJ

  • Ann Kasperek, Sisters of Mary Reparatrix

  • Sister Colleen Dauerbach, Sisters of Saint Joseph of Chestnut Hill, PA

  • Mary Ann Weyker, Sisters of St. Dominic*

  • Sister Joan Agro, Sisters of St. Dominic of Blauvelt, NY

  • Sister Patricia Daly, Sisters of St. Dominic of Caldwell, NJ

  • Nora Nash, Sisters of St. Francis of Philadelphia, PA

  • Betty Cawley, Sisters of St. Joseph of Boston, MA

  • Denise Granger, Sisters of St. Joseph of Springfield, MA

  • Veronique Wiedower, Sisters of the Holy Cross

  • Toby Lardie, Sisters of the Humility of Mary

  • Linda Pleiman, Sisters of the Precious Blood

  • Sister Pegge Boehm, Sisters of the Presentation of the BVM of Aberdeen SD

  • Claire Deroche, Social Justice Committee, Unitarian Universalist Congregation at Shelter Rock

  • Anna Falkenberg, Socially Responsible Investment Coalition*

  • Molly Gochman, Stardust

  • Deborah Perry Piscione, Sterling Ventures

  • Julie Skye, Sustainable Advisors Alliance LLC

  • Regan Pritzker, Tao Capital*

  • Ruth Shaber, Tara Health Foundation

  • Kurt Barnes, The Episcopal Church (DFMS)

  • Crystal Hayling, The Libra Foundation

  • Richard Walters, The Pension Boards, UCC, Inc.

  • Allan Moskowitz, Transformative Wealth Management, LLC

  • Jonas Kron, Trillium Asset Management

  • Cathy Rowan, Trinity Health

  • Andrew McGeorge, Unitarian Universalist Association

  • Matthew Illian, United Church Funds

  • Sister Sandra Sherman, Ursuline Convent of the Sacred Heart

  • Janet Peterworth, Ursuline Sisters of Louisville, KY*

  • Stephanie Cohn Rupp, Veris Wealth Partners

  • Elizabeth Pearce, Vermont Pension Investment Committee and Vermont State Treasurer*

  • Ellen Dorsey, Wallace Global Fund

  • Lauren Martin, Wealthspire Advisors*

  • Ian Fuller, WestFuller Advisors

  • David Addams, William Caspar Graustein Memorial Fund

  • Marcela Pinilla, Zevin Asset Management

*Fund listed for identification purposes only.

Corporate Donors to Voter Suppression Efforts that received investor coalition letter

  • Abbott Laboratories

  • Aflac Incorporated

  • Allstate Corporation

  • Alphabet Inc.

  • Altria Group, Inc.

  • Amazon.com, Inc.

  • Ameren Corporation

  • American Electric Power

  • Anthem, Inc.

  • AT&T Inc.

  • Berkshire Hathaway Inc.

  • Boeing Company

  • Bristol-Myers Squibb Company

  • Capital One Financial Corporation

  • Carmax, Inc.

  • Caterpillar Inc.

  • Centene Corporation

  • CenterPoint Energy, Inc.

  • Charter Communications, Inc.

  • Chevron Corporation

  • Cigna Corporation

  • Citigroup Inc.

  • CMS Energy Corporation

  • Coca-Cola Company

  • Comcast Corporation

  • Comerica Incorporated

  • CSX Corporation

  • CVS Health Corporation

  • Deere & Company

  • Delta Air Lines, Inc.

  • Dominion Energy, Inc.

  • DTE Energy Company

  • Duke Energy Corporation

  • Eli Lilly and Company

  • Exelon Corporation

  • Exxon Mobil Corporation

  • Facebook, Inc.

  • Fedex Corporation

  • Ford Motor Company

  • Freeport-McMoRan Inc.

  • General Dynamics Corporation

  • General Electric Company

  • General Motors Company

  • GEO Group, Inc.

  • HCA Healthcare, Inc.

  • Home Depot, Inc.

  • Honeywell International Inc.

  • Humana Inc.

  • International Paper Company

  • Intuit Inc.

  • Johnson & Johnson

  • Lockheed Martin Corporation

  • Lowe's Companies, Inc.

  • Lumen Technologies, Inc.

  • Marathon Petroleum Corporation

  • Merck & Co., Inc.

  • Micron Technology, Inc.

  • Microsoft Corporation

  • Morgan Stanley

  • NiSource Inc.

  • Norfolk Southern Corporation

  • Northrop Grumman Corporation

  • Pfizer Inc.

  • Pinnacle West Capital Corporation

  • Prudential Financial, Inc.

  • Raytheon Technologies Corporation

  • Republic Services, Inc.

  • Southern Company

  • Sysco Corporation

  • T-Mobile US, Inc.

  • Truist Financial Corporation

  • Union Pacific Corporation

  • United Airlines Holdings, Inc.

  • United Parcel Service, Inc.

  • UnitedHealth Group Incorporated

  • Valero Energy Corporation

  • Verizon Communications Inc.

  • Walgreens Boots Alliance, Inc.

  • Walmart Inc.

  • Walt Disney Company

  • Waste Management, Inc.

  • Wells Fargo & Company