Supporting Statement: Exxon is implementing a new retail voting program (the ‘Program’) that is intended to increase retail investor participation a goal we support. The current Program, however, raises significant governance concerns, as Exxon has effectively created a process for robo-voting in line with board recommendations. Notably, the Program is also inconsistent with Exxon’s own stated position. In connection with the SEC’s 2019 Roundtable on the U.S. Proxy Process, Exxon argued that ‘the current practice of automatic voting of shares with predetermined voting policies immediately following issuance of a proxy advisor’s voting recommendations should be prohibited.’1 Yet Exxon now proposes its own predetermined policy-not an investor-developed voting policy, but a board-created predetermined policy. Moreover, the ‘predetermined voting policies,’ which Exxon criticized, are what is generally known as ‘custom policies.’ These custom policies are developed independently by investors after analyzing relevant topics and are based on their own voting guidelines. Custom policies may also be reviewed and revised by investors as issues and markets evolve. Exxon’s Program, by contrast, only offers investors the board’s self-interested option that may make board entrenchment more likely. Retail investors will be asked to sign onto this Program before a proxy statement is even published. This is particularly troubling because Exxon has a history of being unresponsive to shareholders and has even attempted to limit their right to advance shareholder proposals. Prior to 2017, Exxon’s independent board members had a practice of not engaging with shareholders (even large asset managers such as BlackRock.2) In 2021, Exxon lost a proxy contest to Engine No. 1, who nominated directors that shareholders preferred over those designated.3 In 2024, Exxon took the unprecedented step of suing its own investors who submitted shareholder proposals for ‘abuse’ of the shareholder proposal process - continuing the litigation even after the proposal was withdrawn.4 In providing multiple, independent options for retail investors, Exxon could build a more impactful retail voting platform. Although historically, many retail investors may have voted in line with board recommendations, Broadridge has noted that in 2025, support for environmental and social shareholder proposals was higher for retail investors than institutional investors.5 Exxon’s Program presupposes that retail investors who opt in to the Program agree with board’s recommendation on every ballot item. The New York City Comptroller’s Office requests that you vote FOR this proposal to ensure retail investors have options other than robo-voting in line with board recommendations.