CCRcorp Sites  

The CCRcorp Network unlocks access to a world of insights, research, guides and information in a range of specialty areas.

Our Sites

TheCorporateCounsel

TheCorporateCounsel.net

A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.

DealLawyers

DealLawyers.com

An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.

CompensationStandards

CompensationStandards.com

The “one stop” resource for information about responsible executive compensation practices & disclosure.

Section16.net

Section16.net

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.

PracticalESG

PracticalESG.com

Keeping you in-the-know on environmental, social and governance developments

We wrote recently about shareholder proposals filed with Mondelez and JP Morgan Chase seeking the companies to undertake various efforts related to CAHRAs (Conflict-Affected and High Risk Areas) – a term out of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas. The results are in, and they are quite different. According to JPMorgan Chase’s 8-K, only 7.28% of shareholders voted to support the CAHRA proposal. Other ESG proposals that failed to gain a majority of shareholder support were :

  • publishing a report on the effectiveness of company policies, practices, and performance indicators on Indigenous Peoples’ rights in corporate and project financing (30.41%) and
  • conducting an audit on impacts of JPM’s climate transition policies on economic and humanitarian effects in emerging nations which rely heavily on – but have limited access to – fossil fuels and other non-‘renewable’ sources of power (1.04%).

Mondelez’s shareholders were more supportive of a proposal for an independent third‐party report assessing the effectiveness of the company’s implementation of its Human Rights Policy (HRP) for operations in CAHRAs, including Russia/Ukraine. Bloomberg pegged the support at 30% – about 23% higher than the support for JPM’s similar proposal.

There are at least two plausible explanations for the large gap:

  • The universe of shareholders – and their priorities/concerns – differ meaningfully between the two companies.
  • Shareholders see a difference in the relevance of CAHRAs to a manufacturing supply chain versus relevance to financing.

This could be a learning opportunity for other companies in terms of understanding shareholder makeup and priorities. It is also yet another data point about why CSOs/sustainability staff in operating companies shouldn’t look to investor actions or demands to justify their place or funding.

If you aren’t already subscribed to our complimentary ESG blog, sign up here: https://practicalesg.com/subscribe/ for daily updates delivered right to you.

Back to all blogs

The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile