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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.

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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