COMCAST CORPORATION | Report on retirement plan option alignment with climate policy at Comcast Corporation

Status
5.95% votes in favour
AGM date
Previous AGM date
Proposal number
8
Resolution details
Company ticker
CMCSA
Lead filer
As You Sow
Resolution ask
Report on or disclose
ESG theme
  • Environment
ESG sub-theme
  • Climate change
Type of vote
Shareholder proposal
Filer type
Shareholder
Company sector
Consumer Discretionary
Company HQ country
United States
Resolved clause
Shareholders applaud Comcast for adopting ambitious operational climate goals:
• Recently setting the ambitious goal of being carbon neutral by 2035 in Scope 1 and 2 emissions across entire global operations.
• Committing to purchasing 100% renewable energy for cable facilities and network operations in Houston, Texas.
• Installing fuel efficiency software in 17,500 of cable vans and trucks between 2016 and 2018.
While the Company has made significant efforts to address climate change across its operations, data from Securities and Exchange Commission (SEC) filings demonstrates misalignment between the Company’s sustainability goals and investment options offered through the Comcast Corporation Retirement-Investment Plan.
Every investment fund offered by the Comcast retirement plan, including the default option (holding 52% of employee investments), contains major oil and gas, fossil-fired utilities, coal, pipelines, oil field services, or companies in the agribusiness sector with deforestation risk.
A recent scorecard, produced by investor representative As You Sow, shows that the Comcast retirement plan default option is rated poor due to significant investments in fossil fuel companies and companies with deforestation risk.
Comcast’s retirement plan currently offers no diversified equity funds that are low carbon, defined as intentionally avoiding investments in fossil fuels companies, companies with deforestation risk, and companies with high carbon emissions. It offers zero funds screened for environmental/social impact.
As a result of these limited options, the vast majority of the $15.1 billion employee retirement dollars invested through the Comcast Corporation Employee Savings Plans Master Trust as of December 2020 was invested in funds rated poorly on carbon emissions.
Comcast’s investment in high carbon companies through its retirement plan choices directly contradicts the climate reduction actions it has committed to take in its operations, creating cognitive dissonance and reputational risk. This may also make it more difficult to retain employees who are increasingly concerned about catastrophic climate impacts. The climate impact of continuing to choose high carbon retirement plan investments options over low carbon choices raises red flags for the Company’s reputation.
Whereas clause
Shareholders request the Board, at reasonable expense and excluding proprietary information, prepare a report reviewing the Company’s retirement plan options with the board’s assessment of how the Company’s current retirement plan options align with its climate action goals.
Supporting statement
Proponent suggests the report include, at Board discretion:
• How Comcast could provide employees with more sustainable investment options such as a default option that is better aligned with global and Company climate goals;
• If the Board does not intend to include additional low carbon investment options in its employee retirement plan, a statement of the basis for its decision.

How other organisations have declared their voting intentions

Organisation name Declared voting intentions Rationale
Kutxabank Gestion SGIIC SAU. For
LocalTapiola Asset Management Ltd For A vote FOR this resolution is warranted. While the company may not be responsible for its employees' investment decisions, it is unclear how well employees understand the retirement plans available to them. The information requested in the report would not only complement and enhance the company's existing commitments regarding climate change, but also allow shareholders to better evaluate the company's strategies and management of related risks.
KBI Global Investors For The information requested would not only complement and enhance the company's existing commitments regarding
climate change, but also allow shareholders to better evaluate the company's strategies and management of related risks.

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