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Public Policy and Position Statements

Wespath Benefits and Investments, on behalf of itself and its subsidiaries, including Wespath Institutional Investments, periodically writes letters to U.S. regulatory agencies and cosigns letters and position statements with other investors seeking to influence global public policy leaders.

2019

October 31, 2019Letter to Securities and Exchange Commission Addressing Proxy Adviser Regulation and Opposing Potential Changes to Rule 14a-2(b)

September 23, 2019Global Investor Statement to Governments on Climate Change

September 18, 2019Securities and Exchange Commission Letter on Potential Changes to Rule 14a-8 9 (filing and/or rebubmission of shareholder proposals)

2018

November 15, 2018Comment Letter to SEC in Support of U.S. Proxy Process and Shareholder Rights

October 30, 2018Wespath’s Letter Opposing the Replacement of the Clean Power Plan

October 23, 2018Letter to EPA and NHTSA Opposing an Easing of Auto Fuel Economy and Emissions Targets

2017

November 3, 2017Joint UMC Letter to World Leaders at COP23 Urging Strengthening Commitment to Paris Agreement

August 8, 2017Comment Letter to the EPA on Proposed Rule: Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources

May 1, 2017Letter opposing Financial CHOICE Act of 2017 for potential to erode shareholder rights

January 10, 2017Wespath joins the call for continued low-carbon investments and policies in the U.S.

2016

September 19, 2016Letter Opposing Proposed Proxy Advisory Reform Bill (HR 5311)

July 21, 2016Letter to the Securities and Exchange Commission about Regulation S-K Concept Release, File Number S7-06-16

June 13, 2016Letter to the House Committee on Financial Services opposing a proposed bill (HR 5311) to tighten regulation of proxy advisory firms, which could weaken public company corporate governance and shareholder rights

2015

November 16, 2015A Letter from General Agencies of The United Methodist Church to COP21

September 8, 2015Letter to the Premier of Alberta, Canada, supporting renewal and strengthening of Alberta’s climate change policy

July 31, 2015Letter to twenty-nine state governors supporting implementation of EPA's Carbon Pollution Standards

July 6, 2015Letter to SEC Regarding Staff Review of Rule 14a-8(i)(9)

May 25, 2015CEO Letter to G7 Finance Ministers Requesting Action on Climate Change

2014 and Prior

September 18, 2014—Global Investor Statement on Climate Change, Delivered to Heads of State at the UN Climate Summit

September 20, 2013Wespath Supports Power Plant Performance Standards

June 19, 2013Letter to U.S. Secretary of State John Kerry regarding the Accord on Fire and Building Safety in Bangladesh

May 7, 2013Letter in support of Dodd-Frank Section 1502, Rule 13p-1

September 15, 2009Regarding the proposed “Proxy Disclosure and Solicitation Enhancements” rule

September 4, 2009Regarding the proposed “Shareholder Approval of Executive Compensation of TARP Recipients” rule

August 11, 2009Regarding the “Social Investment Forum Proposal Dated July 20, 2009” on mandatory corporate reporting on environmental, social and governance information

Position Statements

Wespath must occasionally take positions on issues of importance to the Church that have an effect on our work in service to plan participants. We also publish statements to clarify misunderstandings when they surface regarding the nature and purpose of our retirement, health and welfare plans and programs.

Addressing Human Rights—Israel and the Palestinian Territories

Dialogue and Resolutions

A vitally important element of our investment strategy is our proactive and ongoing corporate engagement activities. This differentiates Wespath from other managers that claim that they are socially responsible and who rely exclusively on screening to avoid investments in companies that manufacture, distribute, or sell products and/or services that conflict with their clients’ values.

Our advocacy efforts, by contrast, complement the investment selection process. Guided by the Social Principles of The United Methodist Church, we believe that we can positively influence corporate business practices. We regularly review our investment portfolio to identify companies that could benefit from improved environmental, social or governance policies and procedures.

Wespaths advocacy program is an extension of our managers’ security selection efforts that include consideration of a company’s ESG policies. Working alongside like-minded investors to promote change, the ultimate goal of Wespath’s advocacy program is to promote long-term sustainable business practices that eventually results in greater shareholder value.

Along with other investors who share our values-driven approach, we employ a structured process to corporate engagement that starts with careful research of ESG issues and their implications for long-term corporate sustainability. We then develop a specific goal for the engagement and begin our advocacy effort. We are able to leverage the significant investments held by Wespath and other investors as management views the collective efforts of Wespath and its partners as an important source of information regarding best practices for establishing and monitoring policies related to ESG issues. Many of the conversations continue over several years and result in changes to corporate policy and business practices– clear evidence that advocacy can have a real impact on investment performance.

If attempts at direct dialogue are not productive, Wespath or its partners will file a public shareholder resolution to encourage action by the company. We use these resolutions as a way to elevate important issues before management, directors and other shareholders at the company’s annual meeting. A significant vote in favor of a resolution may prompt management to adopt new policies and/or improve current practices.