Disney has made material commitments to engage in reduction of its greenhouse gas emissions in recent years. Targets include a reduction of absolute emissions by 46.2% by 2030 and 100% net zero direct emissions by 2035. However, not enough has been done to assure investors that such a drastic realignment of Disney towards renewable energy sources is in the best financial interest of shareholders.
McKinsey Sustainability estimates that a global transition to net zero emissions (NZE) would require $9.2 trillion dollars annually in global spending until 2050. This raises serious questions about the costs of achieving Disney’s related goals, but Disney has apparently not disclosed how much money it is spending on its green transition, much less how its investments in NZE are providing a positive return on investment for shareholders. Even investors committed to sustainable investing likely need accurate related cost information for proper share price valuation, which would include costs and financial metrics. Seeing as this transition is apparently a material investment presented by Disney without soluble financial metrics to judge it by, its NZE transition program may be a compelling target for anti-greenwashing action by the SEC or another interested body. The SEC has historically targeted companies engaging in forms of greenwashing with considerable financial penalties. For example, Goldman Sachs Asset Management was fined $4 million for policy and procedural failures related to ESG investments, and DWS Investment Management Americas Inc. was charged $25 million in part for misstatements regarding its ESG investment processes. Should Disney be implicated in greenwashing, the impact on shareholders could
be considerable, as company valuation and investor confidence plummets. Concerns regarding the non-monetary benefits of a NZE policy are only magnified by the extent and extremes of relevant opinions on climate change and netzero commitments. While some organizations’ projections are almost apocalyptic in scale, others indicate that climate change will be a slower process lacking an identifiable date by which it should be considered an emergency. Additionally, the U.S. Secretary of Energy recently argued that net zero policies “raise energy costs … threaten the reliability of our energy system, and undermine our … security” while having achieved “little in reducing global greenhouse gas emissions.” The EPA also recently proposed rescinding the 2009 Endangerment Finding that greenhouse gases are pollutants, which “Could Be a Dagger in the Heart of Net Zero.” While it is possible that Disney is managing this transition at a profit, shareholders lack material data upon which to make that assessment. The requested report would provide the much-needed transparency that shareholders need to make informed decisions about their assets while safeguarding Disney against hostile greenwashing claims.

1 https://impact.disney.com/environmental-sustainability/environmental-goals/
2 https://www.mckinsey.com/capabilities/sustainability/our-insights/the-net-zero-transition-what-it-would-cost-what-it-could-bring#/
3 https://clsbluesky.law.columbia.edu/2024/10/18/disclosure-greenwashing-and-the-future-of-esg-litigation/
4 https://www.sec.gov/news/press-release/2022-209
5 https://www.sec.gov/news/press-release/2023-194
6 https://news.un.org/en/story/2023/03/1134942
7 https://thebreakthrough.org/journal/climate-change-banned-words/climate-tipping-point-real
8 https://www.energy.gov/articles/secretary-wright-acts-unleash-golden-era-american-energy-dominance
9 https://www.epa.gov/newsreleases/epa-releases-proposal-rescind-obama-era-endangerment-finding-regulations-paved-way
10 https://www.heritage.org/government-regulation/commentary/americas-trillion-dollar-deregulation-could-be-dagger-the-heart