CHEVRON CORPORATION | Report on voluntary carbon reduction risks at Chevron Corporation

1.53% votes in favour
AGM date
Previous AGM date
Proposal number
Resolution details
Company ticker
Resolution ask
Report on or disclose
ESG theme
  • Environment
ESG sub-theme
  • GHG targets / emissions
Type of vote
Shareholder proposal
Filer type
Company sector
Company HQ country
United States
Resolved clause
RESOLVED: Shareholders request the Company produce a report
analyzing the risks arising from voluntary carbon-reduction
Whereas clause
WHEREAS: Shareholders must protect our assets against
potentially unfulfillable Company ESG promises, including the
extent to which the Company can reduce Scope 1, 2, and 3
greenhouse gas (GHG) emissions.
The Securities and Exchange Commission (SEC) has taken
enforcement actions related to Environmental, Social, Governance
(ESG) issues or statements by companies who misrepresent or
engage in fraud related to ESG efforts.1
In 2021, the SEC created the Climate and ESG Task Force in its
Division of Enforcement.2 The focus of the Task Force is “to
identify any material gaps or misstatements” in disclosure of
climate risks and analyze “compliance issues relating to
investment advisers’ and funds’ ESG strategies.”3
The Task Force has taken numerous enforcement actions
including charging Goldman Sachs for policies and procedures
failures related to ESG investments, resulting in a $4 million
penalty,4 and charging DWS Investment Management Americas
Inc. in part for misstatements regarding its ESG investment
process that resulted in an overall $25 million in penalties.5
The SEC has proposed to require companies to disclose
information about their Scope 1 and 2 emissions, and to require
them to disclose Scope 3 emissions “if material or if the registrant
has set a GHG emissions target or goal that includes Scope 3
The Environmental Protection Agency defines Scope 3 emissions
as, “the result of activities from assets not owned or controlled by
the reporting organization, but that the organization indirectly
affects in its value chain.”7 Put differently, “Scope 3 emissions for
one organization are the scope 1 and 2 emissions of another
organization.”8 This means that Scope 3 emissions are already
counted as another entity’s emissions, and are external to the
reporting company, such as product use and how employees
Voluntary carbon-reduction commitments create risk of SEC
enforcement without providing clear benefit to the climate or
other values.
In August 2023, the Global Climate Intelligence Group asserted,
“There is no climate emergency.”10 The declaration includes 1,609
signatories and “oppose[s] the harmful and unrealistic net-zero
CO2 policy proposed for 2050.”11
A June 2023 study by the Energy Policy Research Foundation
found that net zero advocates have misconstrued the
International Energy Agency’s position on new oil and gas
investment and that it has made questionable assumptions and
milestones for NZE about government policies, energy and carbon
prices, behavioral changes, economic growth, and technology
Supporting statement
SUPPORTING STATEMENT: Chevron has made Scope 3 emissions
reduction commitments despite its acknowledgement of that “the
NZE Scenario is remote and highly unlikely....”13 Given the SEC’s
climate and ESG enforcement actions, the Company must
exercise caution and provide transparency about the feasibility of
such commitments to avoid financial and reputational risk.


How other organisations have declared their voting intentions

Organisation name Declared voting intentions Rationale
Kutxabank Gestion SGIIC SAU. Against
Legal & General Investment Management (Holdings) Against A detailed explanation for our vote intention can be found on the LGIM Blog:
Rothschild & co Asset Management Against

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