Shareholder Advocacy for the 2025 Proxy Season
Bank of America (BAC) – Animal Welfare Oversight
– ON BALLOT
After our experience addressing Citigroup on the matter of animal welfare, we have extended our inquiry into the existence and level of Board oversight on the risks associated with animal welfare to Bank of America.
We spoke with staff at BAC and they expressed the company did not have plans to enhance their oversight on animal welfare, thus no agreement was reached. The proposal is included n the company’s 2025 proxy materials.
• Date for Bank of America’s 2025 Annual Meeting of Shareholders: April 22, 2025
Citigroup (C) – Report on Animal Welfare Oversight
– ON BALLOT
HII was pleased with the support gleaned from Citigroup shareholders in 2024. The proposal captured a modest 7.7%, but it afforded us to continue our pursuit towards greater accountability and disclosure from the bank. We resubmitted our proposal for 2025, which requests that Citigroup publish a report disclosing whether and how the Board of Directors exercises oversight regarding material risks associated with animal welfare.
We engaged with staff at Citi who did not feel that the company needs further additions to their polices or procedures to address the material risks to the company related to animal welfare. Our resolution appears in Citigroup’s 2025 proxy materials.
• Date for Citigroup’s 2025 Annual Meeting of Shareholders: April 29, 2025
JPMorgan Chase (JPM) – Transition Finance Impact Report
– ON BALLOT
HII is grateful for the opportunity to co-file this proposal, submitted by lead-filer Paul Rissman, Sierra Club Foundation board member. The resolution requests that JPM produce a report regarding the company’s transition finance efforts, detailing the potential risks and opportunities, particularly relating to the social impact of these efforts.
A discussion between the lead proponent (Rissman) and corporate staff at JPM was held in late December of 2024.
JPM challenged the proposal thanks to the recent SEC Staff Legal Bulletin, issued in mid-February, which provided updated guidance on shareholder proposals under Rule 14a-8, particularly regarding the scope and applications of the rule’s “economic relevance” and “ordinary business” exclusions. JPM’s attorneys attempted to argue that the issues addressed in the resolution were neither economically significant, nor significantly related to the company’s business, but were unsuccessful as the SEC did not concur. The proposal is included in JPM’s 2025 proxy materials.
Date for JPMorgan Chase’s 2025 Annual Meeting of Shareholders: TBA
Wells Fargo (WFC) – Contribution Congruency Report
– ON BALLOT
2025 marks the third year our proposal has been submitted to WFC, addressing the company’s lack of congruency between corporate political contributions and stated values. In 2024, the proposal received over 25% support from shareholders.
Accompanied by our allies at Corporate Accountability and the Black Collective, we held a teleconference meeting with staff at WFC to — once again — discuss the issues raised in the resolution. Unsurprisingly, staff still failed to provide any answers to questions from our colleague, Ann-Michelle Roberts (the Black Collective). She has been pressing for a response to relevant issues she has raised about WFC’s history of racist and discriminatory activities. Not unexpectedly, nothing further was achieved through our dialogue. WFC initially sent us a notice of their intent to include the resolution in the 2025 proxy materials, along with a copy of the company’s statement in opposition to our proposal. However, a short time later we received a No-Action Request (NAR) announcing they sought to omit the proposal based on updated guidance from the SEC. As mentioned above regarding JPM’s challenge, WFC referred to the very recent SEC Staff Legal Bulletin issued in February, in regards to the “economic relevance” and “ordinary business” exclusions. Like JPM, WFC’s attorneys claimed the topic of the resolution was neither significant to the company nor economically significant. Thankfully, the SEC disagreed with WFC and did not permit the company to exclude our proposal. The resolution is included in WFC’s 2025 proxy material.
• Date for Wells Fargo’s 2025 Annual Meeting of Shareholders: April 29, 2025