Supporting Statement: Berkshire’s decentralized structure means subsidiaries often undertake climate investments without visible accountability to shareholders. Indeed, publicly available disclosures in several cases demonstrate material commitments, but lack any transparent expected value or ROI justification. For example, Berkshire Hathaway Energy states it has invested $40.7 billion in renewable generation and storage, with plans to invest an additional $4.5 billion through 2026, and is “striving to achieve New Zero Greenhouse Gas Emissions by 2050.”1 Yet the presentation includes no cash flow models, internal rate of return estimates, payback periods, or sensitivity analysis to assure that those investments produce net financial value rather than symbolic expense. Similarly, McLane Company is quoted in Sustainability at Berkshire Hathaway 2024 as having made “investment of over $230 million in energy-efficient automation and equipment.”2 However, the disclosure apparently does not provide estimates of energy or cost savings, hurdle return rates, or timelines of payback, leaving shareholders unable to assess financial benefit versus opportunity cost. Finally, Johns Manville, another Berkshire subsidiary, has announced ambitious sustainability goals—such as reducing Scope 1 and 2 greenhouse gas emissions by 40 percent by 2030 and “developing and selling products that increase the net positive benefit to our world by more than 10 percent by 2025.”3 However, the company provides no supporting analysis demonstrating that the associated investments yield positive financial returns. Its public materials contain no cashflow projections, internal-rate-of-return calculations, payback estimates, or sensitivity analyses, nor any statement that such capital expenditures are required to meet a positive net-present-value threshold. Without such information, shareholders 1 https://www.berkshirehathaway.com/bhenergy/BHE2024InvestPresent.pdf 2 https://brk-b.com/sustainability-at-berkshire-hathaway-2024_240205.html. See also https://www.mclaneco.com/about/community/sustainability/ 3 https://www.jm.com/en/sustainability/sustainability-goals/ Division of Corporation Finance cannot determine whether Johns Manville’s emissions-reduction and productreengineering commits are value-accretive or merely greenwashing. These cases illustrate that significant capital may be allocated to climate initiatives without transparent justification to investors. A report that reveals which projects were authorized on expected value calculations and maintained on the basis of ROI assessments enhances accountability without dictating policy. In addition, such a report allows shareholders to properly value their shares. The report could include: 1. All material commitments over the past three fiscal years (e.g., net-zero pledges, renewables buildouts, efficiency programs), including capital invested or committed, and projected cash flows. 2. Whether each commitment was preceded by formal discounted cash flow, internal rate of return, or comparable capital budgeting models— listing inputs, assumptions, and sensitivity analyses. 3. Projecting returns versus actual realized returns and explaining shortfalls. 4. Assessments of downside risk under alternate scenarios, as well as opportunity costs. 5. Recommendations for a governance mechanism so that future climate expenditures above a material threshold meet documented positive net present value before approval. We urge shareholders to support this measure for better oversight of climate investments