Boston Common is a leading and founding investor of the World Benchmarking Alliance Ethical AI Collective Impact Coalition (AI CIC), supported by 64 investors representing $11.3 trillion in AUM, and together engaging a total of 80 companies. In 2025, the AI CIC was honored with the PRI Human Rights Award and the ICGN Excellence in Stewardship Award.
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.
Below is a summary of the collective findings from the WBA report on investor dialogue and responsible AI adoption across sectors over the past 3 years. This largely reflects our experience in individual engagements as well:
- Semiconductors and Electronics: Mixed progress, with some companies (Samsung) exhibiting strong governance, while others (Nvidia and Apple) are unresponsive.
- Telecom Providers: High responsiveness to investor outreach, but significant gaps in operational transparency and safeguards for AI deployment.
- Platform Companies: Fluctuating interest in dialogue, with Microsoft standing out for constructive engagement. US-based hyperscalers (Alphabet, Amazon, Apple, and Meta) remain largely unresponsive.
Company Engagement: Focus & Insights (2023-2025)
Over the past three years, Boston Common has engaged under the CIC and individually across sectors, including co-leading outreach efforts and supporting initiatives with several notable companies. We engaged companies ranked in the 2025 Ranking Digital Rights Index, which addresses issues related to privacy, freedom of expression, governance, and transparency. Company-level updates are detailed below.
Global e-commerce, cloud computing, logistics, and digital services platform operator based in China.
We discussed investor expectations related to WBA Ethical AI (2022) and Ranking Digital Rights (2021), as well as ongoing dialogue with the AI governance team. Alibaba has shown progress, especially in AI governance disclosure, and was the most improved Big Tech company in the 2025 Ranking Digital Rights Index, particularly in algorithmic transparency. We urged Alibaba to formalize its algorithmic approach, clarify governance, and support transparency in content moderation and human rights
Global digital platform operator in search, advertising, cloud, and AI based in U.S.
Alphabet has notable practices; however, it has not engaged in substantive investor outreach over the past three years. We have escalated shareholder resolutions focused on high-risk use cases, including child online safety (2023-2025) and downstream AI risk assessment (2026).
Alphabet’s Responsible AI Progress Report (February 2025) showcases the company’s AI risk assessment framework and lifecycle approach, based on the NIST Risk Management Framework (govern, map, measure, and manage).
U.S.-based semiconductor and infrastructure software designer for global tech.
We held a dialogue with Broadcom in 2024 regarding its AI governance and oversight; it has failed to adopt or implement any substantive policies or disclosures at this stage.
Global telecom, mobile, broadband, and digital network services provider based in Germany.
Since 2022, we’ve worked with investors to engage Deutsche Telekom (DT), ranked 4th in the 2022 Ranking Digital Rights Index. DT has had Ethical AI principles since 2018, adopted Green AI in 2024, and is investing in Generative AI. It has robust risk management, including training and human rights assessments. In 2025, we urged DT to improve governance, engagement, and human rights impact processes.
Note: Green AI describes an approach to developing and using artificial intelligence that prioritizes environmental sustainability by reducing energy consumption, carbon footprint, and resource use, both by making AI itself more efficient (Green in AI) and by applying AI to solve environmental problems (Green by AI).
U.S.-based, worldwide software, cloud platforms, devices, and AI services developer.
Microsoft stands out among US hyperscalers, engaging in substantive dialogue on AI responsibility year after year, including with the participation of its Chief Responsible AI Officer in 2025. It is one of the few to issue a standalone Responsible AI report. Microsoft is among a small group of companies that both issued a public human rights impact report and aligned with best practices, such as:
- Using an external expert consultant
- Issuing a broad and detailed assessment (56 pages)
- Detailing its scope, methodology, and findings.
- Issuing a clear set of 23 recommendations
As an advanced practitioner, we expect Microsoft to evolve its reporting on implementation effectiveness in its annual AI report. This, along with the expansion of AI human rights impact assessments, was a focus of our Q4 dialogue.
Global cloud-based CRM, analytics, and enterprise software services provider based in U.S.
We engaged Salesforce collaboratively in 2023 on customer AI due diligence and risk assessment. In February 2025, Salesforce published “Trusted AI” principles, which link to the company’s AI Acceptable Use Policy and include a proactive approach to disclosing prohibited use cases that carry heightened human rights risks (e.g., character-based screening or the use of facial recognition technology). Mindful of the risks associated with biometric use, we urged Salesforce to enhance its disclosures regarding risk monitoring, client engagement, and oversight, particularly in relation to its Responsible AI and Human Rights Policy.
Samsung plans to expand AI deployment, focusing on Responsible AI governance and oversight. In 2025, it strengthened AI governance via its AI Safety Framework, AI Safety & Red Teaming, and AI Strategy Team oversight. By 2026, we will continue to engage Samsung on implementing these policies and its AI approach.
Note: Red Teaming describes a process where a group (the “red team”) simulates real-world adversarial attacks against an organization’s systems, people, and processes to find vulnerabilities before malicious actors do
South Korean manufacturer of memory semiconductors for global computing and data-center markets.
In 2022, we introduced the core investor AI expectations in Seoul and continue to advocate for them to align with our semiconductors, leveraging the experience of SK Telecom.
South Korean mobile, broadband, AI, and digital services provider.
In 2022 we introduced the core investor WBA Ethical AI investor expectations in Seoul and have continued to engaged over the past 3 years. At that time, they had just released a public AI framework in Korean. We advocated they disclose in English as a stand-alone policy and begin to disclose implementation which they have done. More recently given the company’s AI Pyramid Strategy 2.0 — prioritizing AI infrastructure, enterprise AI, and consumer AI — we continued to engage on AI governance and oversight including human rights. In October 2025, SKT presented to the UN its AI framework which emphasizes human-centric AI governance aligned with global human-rights priorities. In 2026, we will continue to engage on their AI human rights implementation alongside how they are managing energy and water use with expanded AI footprint.
Singaporean telecom, digital, and enterprise service provider across Asia-Pacific.
In 2025, we addressed data privacy, Responsible AI, and data center energy efficiency with Singtel. The company has a Responsible AI Framework and Policy. In June, we met with management, including CEO Mr. Yuen Kuan Moon, focusing on green energy sourcing for its expanding data centers. We noted governance development related to AI roles. We advised Singtel to enhance its public disclosures, particularly regarding Responsible AI, given its active AI policies and the use of Generative AI.
Global social media, gaming, fintech, and cloud platforms operator based in China.
We discussed investor expectations for WBA (2022) and Ranking Digital Rights (2021) during annual meetings. Tencent welcomed our recommendations and has adopted a Responsible AI framework, a topic we discussed during our initial engagement. We focused on AI governance, including user rights such as privacy, child safety, and content moderation. Tencent improved governance disclosures in the 2025 RDR benchmark. In 2025, we emphasized digital rights, content moderation, and algorithmic transparency. As a UN Global Compact member, we urged Tencent to develop a comprehensive AI human rights due diligence and impact assessment.
Applying Our Findings
In our company engagements, we received meaningful responses on Responsible AI expectations. Some companies, such as Broadcom and SK Hynix, decline to adopt public AI policies due to their specific use cases or position in the AI ecosystem. Still, we continue to advocate for SK Hynix to adopt a public Responsible AI policy, citing SK Group, including SK Telecom, for guidance.
Looking ahead, with AI’s exponential growth and our investments in the AI value chain, we are focused on high-profile risks, including those related to agentic AI, high-risk applications, and sensitive use cases involving discrimination (common in healthcare and finance). We are also considering environmental impacts from energy use (data centers) and water use, especially in high-risk areas.
Our 2024 and 2025 integrated engagement focus with AI hyperscalers, semiconductor companies, and telecom companies on responsible AI and energy/water risks exemplifies our comprehensive approach to engaging on risks and opportunities. We will continue to support this integrated approach in 2026 and expand our fundamental asks in non-tech sectors regarding responsible AI.
