The rapid adoption of AI is intensifying investor scrutiny of human rights risks, particularly when AI-enabled technologies are used for surveillance or other high-risk applications with heightened human rights implications. As governments increasingly procure AI-powered products and services, investors are seeking greater transparency into how companies identify, manage, and escalate human rights risks associated with those relationships.

In the first half of 2026, we held dialogues with Verizon and Salesforce, both of which have significant government contracts that present heightened human rights considerations. We sought to understand how each company applies its human rights policies to government customers, how it evaluates high-risk use cases, and what escalation mechanisms are available when customer use cases may conflict with the company’s human rights commitments or acceptable use policies.

We also co-filed shareholder proposals with Alphabet and The Home Depot, urging both companies to publish reports detailing how they assess and manage risks associated with products, infrastructure, services, and third-party vendors that could facilitate surveillance, censorship, profiling, or targeting, exposing companies to reputational, legal, or business risks.

These engagements reflect our broader expectation that companies strengthen governance, improve transparency, and demonstrate how human rights considerations are integrated into AI-related decision-making.

Verizon: Digital Human Rights

We met with Verizon in April to discuss how the company assesses government-related business for alignment with its responsible AI program and human rights impact assessments.[1] [2]

Verizon has integrated privacy and anti-discrimination considerations into its responsible AI governance and issues a semiannual transparency report. The company also participates in collaborative initiatives, such as the Global Network Initiative, to advance industry approaches to digital rights and responsible data governance.

We identified opportunities to improve disclosure of government-related human rights risks, particularly when contracts involve heightened privacy concerns. Specifically, we encouraged Verizon to:

• Enhance transparency regarding the nature and volume of administrative subpoenas disclosed in its transparency report.[3]
• Continue collaborating through initiatives such as the Global Network Initiative to strengthen industry standards for customer privacy and human rights.
• Provide greater clarity on the governance, accountability, and escalation processes for handling human rights concerns arising from government customers or other high-risk use cases.

Alphabet: Human Rights Governance

Boston Common co-filed a shareholder proposal asking Alphabet to evaluate whether its governance and risk management processes adequately address risks associated with products, infrastructure, and cloud services that could enable surveillance, censorship, profiling, or targeting in contexts with heightened human rights risks.

The proposal—backed by a coalition of more than 40 investors representing approximately $1.15 trillion in assets—followed an earlier investor letter seeking dialogue on these issues.[4]

Although it received 6.03% support overall, support rose to 16.1% among non-insider shareholders, reflecting the influence of Alphabet’s dual-class share structure on shareholder voting outcomes.

We will continue to engage collaboratively with the company to promote stronger governance, greater transparency, and more robust oversight of products and services that may pose heightened human rights and business risks.

The Home Depot: Surveillance Governance

Boston Common co-filed a shareholder proposal asking The Home Depot to clarify its governance and oversight of third-party surveillance technologies used in its stores and to assess the potential business risks associated with customer privacy, data security, and surveillance-related incidents. The proposal was presented at the company’s annual general meeting in May and received support from 8.8% of shares voted, a notable level of support for an emerging governance issue.

We will continue to participate in this collaborative engagement, encouraging The Home Depot to strengthen oversight of surveillance technologies and improve disclosure of how associated privacy, reputational, and human rights risks are identified, assessed, and managed.

[1] Responsible AI Program | Verizon

[2] Strategic Human Rights Impact Assessments | Verizon

[3] Verizon Transparency Reports

[4] Alphabet investors push for safeguards on use of its cloud, AI tech | Reuters