Boston Common values strong shareholder democracy and prioritizes sustained dialogue among the various shareholder engagement tools. We believe environmental and social improvement takes time, so we aim for incremental progress that results from relationship building through sustained dialogue. We use shareholder resolutions if dialogue progress stalls or proves ineffective, but these resolutions represent only a minor part of our overall approach. Boston Common filed nine proposals in 2023 and six proposals in 2024, representing 4.7% and 3.8% of total engagements , respectively.

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 weaken the shareholder proposal process by making exclusions easier in practice and reducing the SEC’s traditional role as a neutral arbiter for companies registered in the United States . The ability to call for a shareholder vote is crucial to shareholder democracy, as regulated by the SEC. The SEC’s issuance of unqualified “no objection” letters, rather than formal “no-action” letters with reasoning, stands to weaken shareholder protections, increase corporate power, and reduce shareholder influence, thereby risking the reliability of longstanding rights and processes.

This change also has the potential to hurt companies in two critical ways:

1. The SEC’s no objection process does not actually provide cover to companies. Even if companies omit a shareholder proposal, there are other ways for companies to raise concerns publicly, and companies will face reputational risk if issues are left unresolved.
2. Omitting the independent review of the SEC could encourage investors to use more disruptive tactics, including director “no confidence vote” campaigns or shareholder litigation.

Mindful of these potential impacts, we requested that Boston Common’s portfolio companies adhere to the existing shareholder proposal and no-action ruling process outlined in SEC Rule 14a-8 (a). We also continued to file shareholder proposals during the 2025/26 shareholder season, albeit with fewer proposals filed this year than in past years. In each proposal, we emphasized our belief that non-binding shareholder proposals enable shareholders to provide directional input to companies while allowing management and the board discretion over implementation.

• Alphabet: Boston Common co-filed this proposal, asking Alphabet to assess governance gaps linked to risk mitigation of products, infrastructure, or cloud services that could facilitate surveillance, censorship, profiling, and targeting in contexts of governmental overreach.
• The Home Depot: Boston Common co-filed a proposal asking Home Depot to clarify its governance and oversight of third-party surveillance technologies utilized in The Home Depot’s stores and further assess the risk of customer attrition that could result from security/surveillance data leaks.

In addition to these shareholder proposals, we reached out to select companies ahead of filing deadlines to notify them that we’d consider filing proposals if our engagement asks and prior withdrawal agreements were not honored. Two companies responded favorably to our outreach and expressed openness to dialogue. Notably, Salesforce agreed to a January dialogue to discuss human capital risks of agentic AI. The TJX Companies also agreed to an early 2026 dialogue to revisit the withdrawal criteria from our 2023 shareholder proposal, which requested additional climate disclosure and target setting. Ultimately, we decided not to refile shareholder proposals with these companies in 2025, considering their openness to engage in dialogue, which we believe signals respect for the shareholder democracy process. We look forward to following up with these engagements and reporting progress in 2026.