Active Shareowner Update
Fourth Quarter 2025
Boston Common’s shareholder stewardship and engagement with portfolio companies represent a core component of our comprehensive approach to serving values-aligned investors. Each quarter, our Active Shareowner Update reports on our shareholder advocacy work in progress. The insights generated by these efforts inform our approach, deepening our understanding of how companies assess, address, and mitigate sustainability risks.
Advancing Sustainability in Japan
From Siloed Actions to Strategic Imperatives
By: Lauren Compere, Head of Stewardship & Engagement
For over fifteen years, we’ve engaged Japanese regulators to promote governance reform and sustainability. When engaging with Japanese companies, we emphasize policies, targets, and transparency.
In 2025, we prioritized ESG governance, board oversight, ESG KPIs linked to compensation, and board training—key areas for Japanese companies. We engaged with key Japanese holdings like Ajinomoto, Hoya, Keyence, Kyowa Kirin, MUFG, Orix, and TDK. Some companies made progress in advancing women, investing in human capital, and strengthening sustainability oversight. We also noted improvements in biodiversity, human rights, and renewable energy.
Evolving SEC Stance on Shareholder Resolutions
Boston Common’s Approach
By: Amy Orr, Director of US Shareholder Engagement
On November 17, 2025, the U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance announced that for the 2025-2026 proxy season, it would no longer review or provide substantive staff responses to most no-action requests.
This change could make exclusions easier in practice and reduce the SEC’s traditional role as a neutral arbiter for companies registered in the United States. The SEC’s issuance of unqualified “no objection” letters, rather than formal “no-action” letters with reasoning, stands to weaken shareholder protections and reduce shareholder influence, risking the reliability of longstanding rights and processes.
Responsible AI Insights & Impact
A Roadmap for Future Engagement
By Lauren Compere, Head of Stewardship & Engagement
In December, the World Benchmark Alliance (WBA) released its second Progress Report, “Plugging the AI Transparency Gap.” The report, which includes a BCAM-contributed case study on social media platforms, summarizes three years of collaborative action and highlights the need for ongoing efforts to bridge the gap between AI principles and their practical application.
Although AI principles are more common, genuine and transparent implementation remains limited, with few companies conducting human rights impact assessments (HRIs) or sharing operational details. Recognizing this, Boston Common’s engagement efforts focus on:
- Robust governance and oversight across the AI lifecycle.
- Moving from policy to practice; demonstrating implementation effectiveness.
- Embedding human rights due diligence and impact assessment in AI risk management.
- Enhancing risk management for sensitive and high-risk use cases.
Read on for a summary of the collective findings from the WBA report on investor dialogue and responsible AI adoption over the past 3 years.
Stewardship Leadership Awards
In December, the WBA Ethical AI initiative released its second Progress Report, “Plugging the AI Transparency Gap.” The report captures three years of collaborative action advancing responsible AI principles. Boston Common co-leads and is a founding investor in the AI Collective Impact Coalition alongside Fidelity International, Candriam, and Amundi.
In the second half of 2025, our efforts were recognized with two awards – the PRI Human Rights Award and the International Corporate Governance Network (ICGN) Excellence in Stewardship Award.
Plastic Waste, Natural Capital, and Global Commitment 2030
Update for the Fourth Quarter of 2025
Plastic waste is harming planetary health, the oceans, and natural ecosystems at an alarming rate while putting economically valuable natural assets at risk. These natural assets can be described in terms of natural capital, which refers to the stock of natural assets that generate ecosystem services—think food, clean water, climate regulation, flood protection, pollination, and cultural value. When plastic waste accumulates, it degrades both the assets and the services they provide, making plastic waste problematic for human, environmental, and economic health.
In this sense, plastic waste is not just pollution. It is asset impairment. Plastic waste converts long-lived natural assets into depreciating ones. This can show up as:
- Higher costs to replace ecosystem services with built infrastructure
- Reduced long-term returns from fisheries, agriculture, and tourism
- Increased systemic risk tied to climate, food security, and health
Preventing plastic pollution, especially single-use and virgin fossil-based plastics, is therefore an environmental conservation and capital preservation strategy. Boston Common is thus encouraging corporate actors to take steps toward eliminating plastic waste from their value chains.
2025* UN PRI Summary Scorecard
In our latest PRI assessment, we achieved high marks in the following areas:
Policy, Governance, and Strategy: Evaluated our sustainability-integrated investment policy and corporate governance structure. Four Stars (89%)
Active Fundamental: Evaluated the scope and depth of our sustainability-integrated research process and robust stewardship and engagement approach. Five Stars (92%)
Confidence Building Measures: Evaluated our internal and external assessment of ESG processes and ESG data. Four Stars (80%)
*for period 1/1-12/31/24
This piece is intended as an editorial review of a survey of risk considerations and does not constitute investment advice, a solicitation, or an offer to buy or sell any security. Past performance does not guarantee future results. All investments involve risk, including the risk of loss of principal.
Company developments described in this report occurred during the period of our engagement but should not be assumed to have resulted from Boston Common’s activities. Where we believe our engagement contributed to a development, we describe the basis for that assessment.
References to third-party research, publications, and data sources are provided for informational purposes only. Boston Common Asset Management does not warrant the accuracy or completeness of third-party information cited herein. Readers should consult original sources and qualified professional advisors before making any investment decision.
