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NYS Comptroller


Engagement Policies and Strategies

Climate ChangeClimate Change

A company should evaluate and adapt its business strategy to meet the impacts of climate change, whether they be environmental (loss of infrastructure and resources) or regulatory (new restrictions on carbon emissions).


Companies Have
Improved Their Policies
Since 2013


Actions and Strategies

Reduce Carbon Emissions

  • We joined the Carbon Asset Risk Initiative—a group of 70 global investors—asking 45 of the world’s top energy companies to assess the financial risks that climate change poses to their business plans.
  • We filed seven resolutions with companies asking what they could do to help meet President Obama’s goal of reducing carbon emissions by 80% by 2050.

Palm Oil and Deforestation

  • Rainforest deforestation has been cited as a major contributor to climate change. Production of soy and palm oil is a leading driver of rainforest destruction in South America and Southeast Asia.
  • We filed two resolutions with companies who are major users of palm tree oil calling on them to avoid purchases of palm oil from endangered forest eco-systems and to seek out sustainable alternate sources.

Political SpendingPolitical Spending

A company should fully disclose its corporate spending for political purposes so its shareholders can determine whether such spending furthers the company’s long-term financial goals.


Companies Have
Improved Their Policies
Since 2010


Actions and Strategies

Full Disclosure of Political Spending

  • In 2016, we filed 15 shareholder resolutions seeking full disclosure of direct and indirect political spending, including lobbying and contributions to independent committees, as well as that portion of trade association dues that may be used for political purposes.
  • Of these 15 resolutions, six were withdrawn prior to annual meetings after we reached agreements with the companies.
  • For 2017, we filed requests for disclosure of corporate political spending at 14 companies.

Books and Records Requests

  • Under Delaware Law, shareholders have the right, under certain circumstances, to examine a company’s books and records.
  • We have used this provision to obtain disclosure of corporate political spending from several of our portfolio companies that are incorporated in Delaware. As a result some companies even adopted new disclosure policies on political spending.

Diversity and Non-Discrimination Diversity and Non-Discrimination

A company should seek out diversity within its leadership and workforce and prevent discrimination based on non-job related criteria. Diversity enables the company to draw on a broad pool of talent and a wide range of viewpoints, backgrounds, skills and experience, all of which can strengthen a company’s competitive position.


Companies Have
Improved Their Policies
Since 2010


Actions and Strategies

Board Membership Diversity

  • Portfolio companies whose current boards lack meaningful diversity of women and minorities may employ corporate governance practices that are barriers to renewing the board of directors at these companies.
  • We have reached precedent-setting agreements with companies to formally include sexual orientation and gender identity in their considerations when seeking diverse board candidates. One company is believed to be the first U.S. corporation to include such provisions in its board nominating charter.

Non-Discrimination Policies

  • There are states and cities in which it is not illegal for companies to discriminate based on sexual orientation and gender identity. In 2010, the Comptroller wrote to over 100 portfolio companies that did not have written policies banning such discrimination urging their adoption.
  • In 2014, the Comptroller—joined by NYC Comptroller Stringer—wrote letters to 18 portfolio companies asking them how they apply their non-discrimination policies in countries with anti-gay laws. They also wrote to portfolio companies that were sponsors of the Russian Olympics in Sochi, asking them to speak out against a recent Russian anti-gay law.