Communication Log

During our research and selection process, there are opportunities to share our concerns with companies and the public.

We believe investors can play an important role in raising awareness of environmental concerns through direct dialogue with companies as well as government and community stakeholders. Following is a list of communications recently undertaken.

Letter to President Obama in support for Carbon Pollution Standards

posted October 23, 2013

Portfolio 21 originally submitted comments to the Environmental Protection Agency (EPA) in May 2013 on the proposed Carbon Pollution Standard for New Power Plants.  Now, in collaboration with other investors with combined assets under management of $900 billion, we urge President Obama to finalize the EPA’s rule for a national carbon pollution standard for electric power plants.  Moreover, we encourage the President to proceed with a program to reduce carbon pollution.  Currently electric power plants are the largest individual source of carbon pollution in the United States, and there are no federal limits on the amount of carbon pollution these plants can emit.  Portfolio 21 would prefer to see comprehensive legislative action rather than EPA regulations to govern this area but so far legislation has not been forthcoming.

Letter to Apple regarding supply chain

posted October 23, 2013

Portfolio 21 wrote to Apple after the publication of a recent report by China Labor Watch that highlights numerous violations by the Pegatron Group, one of Apple’s major suppliers.  Based on the organization’s findings, the supplier appears to be violating a number of Chinese laws as well as Apple’s Supplier Code of Conduct.  We wrote to Apple to ask about the company’s Code as it relates to varying rules in different countries and to understand its auditing, verification, and corrective action processes.

APPLE RESPONDS:  According to Apple, the China Labor Watch report makes new claims not captured by Apple’s own audits.  The company says it will investigate these issues immediately, take corrective actions where needed, and report any violations to its Code of Conduct.

Tier 3 Motor Vehicle Emission & Fuel Standards

posted August 2, 2013

As a member of the Investor Network on Climate Risk, Portfolio 21 joined investors in writing to the EPA to demonstrate our strong support for the proposed Tier 2 Motor Vehicle Emission and Fuel Standards.

Letter to Secretary of State Kerry

posted August 2, 2013

In response to the tragic incident at Rana Plaza in Bangladesh that took the lives of more than 1250 garment workers, Portfolio 21 joined other concerned stakeholders in writing Secretary of State John Kerry to urge support of the Accord on Fire and Building Safety in Bangladesh. The Accord is a legally binding agreement that includes all of the components essential to be effective: independent safety inspections with public reports, mandatory factory building renovations, the obligation by brands and retailers to underwrite the cost of repairs, and a vital role for workers and their unions in protecting their own safety.

Letter to Samsung regarding chemical management and worker safety

posted August 2, 2013

Portfolio 21 wrote to Samsung regarding two recent releases of hydrofluoric acid gas, which killed one worker and injured others. In addition, the company has come under general criticism for its chemical management and potential health impacts of factory workers. Portfolio 21 has written to Samsung to seek better understanding of the company’s health and safety policies and chemical management practices and procedures.

Letter to Google requesting increased political transparency

posted August 2, 2013

Google is a product innovator and one of the world’s most well-known companies. Yet, the company lags in terms of its political spending disclosures. We believe that opacity in political spending can mask conflicts of interest and policy conflicts as companies find themselves funding opposite sides of the same campaign, or the same issue. Consequently, we believe that investors should be provided access to this information. We would like Google to end its membership from the U.S. Chamber of Commerce as this organization provides financial support for a host of regressive policies that seemingly do not align with Google’s innovative and progressive brand image.

Signatory to Climate Declaration

posted August 2, 2013

Portfolio 21 is an official signatory of the Climate Declaration.  The Climate Declaration brings together companies and individuals to demonstrate support for a national strategy to tackle climate change.  The Declaration is framed around a single statement: “Tackling climate change is one of America’s greatest economic opportunities of the 21st century.”  To add your support, visit and Sign the Climate Declaration.

Letter to Unilever regarding working conditions in Vietnam

posted April 24, 2013

In February 2013 Oxfam published a report on labor rights in Unilever’s supply chain, focusing on a factory in Vietnam. The results showed labor rights violations, low pay, and hazardous working conditions. We support Unilever’s decision to partner with Oxfam to evaluate its factory conditions and have the results be made public. However, Portfolio 21 has written Unilever to inquire about what specific next steps will be taken to improve the working conditions in its factories globally.

30% Coalition Letter

posted April 24, 2013

Portfolio 21 and other institutional investors representing over $1.3 trillion in assets, in addition to many of the nation’s leading women’s organizations, joined together to send a letter to the 41 companies within the S & P 500 that have no women on their boards. Together we urged these companies to take steps to embrace gender diversity.

The S&P 500 Index is a broad-based unmanaged index of 500 stocks, which is widely recognized as representative of the U.S. equity market.  It is not possible to invest directly in an index.

Letter to Governor and Legislators regarding the Oregon Clean Fuels Program

posted April 24, 2013

Portfolio 21 wrote to the state legislators and Governor Kitzhaber to express our support for the Oregon Clean Fuels Program (CFP) and to advocate lifting the existing 2015 sunset provision. As an Oregon-based investment company and active member in the business community, we view the CFP as a significant opportunity for statewide economic growth. The CFP advances Oregon’s economic and environmental interests by encouraging investment in clean fuel technology. We view this program as an important tool in minimizing the risks of climate change.

Letter to President Obama urging Climate Summit 2013

posted April 24, 2013

On January 21, 2013 President Obama was inaugurated for his second term. During his address, the President noted that climate change is a top priority. To encourage the President to move quickly on this pressing matter, Portfolio 21 supports the Climate Summit 2013 Coalition.

Letter to President Obama on Climate Summit

posted January 8, 2013

Portfolio 21 Investments joins other business leaders, religious groups, non profits, and foundations in encouraging President Obama to host a national summit on climate disruption within the first 100 days of his new administration. As signatories, we believe that the President’s commitment to create “a conversation across the county” is essential and timely.  The goal of the summit would be to prepare for and build resilience to climate impacts.

Inquiry on Apple’s Sourcing of Indonesian Tin

posted January 8, 2013

Friends of the Earth (FOE) recently launched a “Make It Better” campaign targeting Apple and Samsung.  The goal of this campaign is to bring transparency to the sourcing of tin and to protect the remaining natural resources of Bangka, which is primarily responsible for making Indonesia the world’s largest exporter of tin.  According to FOE’s report, there is about two grams of tin in every phone.  Although Apple is not solely responsible for the environmental degradation in Bangka caused by tin mining, as the world’s largest company in terms of market cap Apple has the ability to move the sector forward.  Portfolio 21 has requested Apple provide information on how it is working to bring transparency to all of its procurement practices, and Indonesian tin in particular.

Letter to UNFI on unfair labor practices

posted January 8, 2013

United Natural Foods has an established set of six core values that include integrity and respect in all of its actions, trust and accountability in all relationships, and open and honest communication with its employees.  However, the does not appear to be abiding by its core values.  Unlawful and unfair labor practices, specifically at the company’s Auburn, WA plant have resulted in a worker’s strike.  This strike commenced on Tuesday, December 11, 2012.  In response, Teamsters Local 117 organized a conference call, in which Portfolio 21 took part, to educate stakeholders on myriad workers’ rights abuses.   Portfolio 21 wrote the company to share our discontent and urge the company to engage in correspondence with the labor unions.

UPDATE: On December 13, 2012 Teamsters Local 117 voted to end its strike. However, when 72 warehouse workers who were prepared to return to work after the three day strike were permanently replaced, the strike resumed. 

Forest Footprint Disclosure

posted October 22, 2012

As a signatory of the United Nations Principles for Responsible Investment, Portfolio 21 Investments joined with other institutional investors to encourage companies with exposure to five key commodities (palm oil, beef, soy, timber, and biofuels) to disclose their current forest footprint to the Forest Footprint Disclosure project.


Study Mining Impacts on Salmon Ecosystems of Bristol Bay

posted October 22, 2012

Portfolio 21 Investments encourages the Environmental Protection Agency (EPA) to initiate a Clean Water Act Section 404(c) review process for Alaska’s Bristol Bay region.  The Bristol Bay watershed is the center of a $2.2 billion regional fishing industry and is an essential part of many companies’ supply chains.  Large scale mining is placing this watershed at risk.  Section 404(c) of the Clean Water Act provides a scientifically sound way to address these concerns. Under established precedents, practices and policies within the Clean Water Act 404(c) program, the EPA may prohibit or restrict the disposal of mine waste if it determines that it will have an “unacceptable adverse effect” on municipal water supplies, shellfish beds and fishery areas, wildlife, and recreational areas.

Petition on Climate Emergency

posted October 22, 2012

Portfolio 21 Investments joined other citizens and organizations across the country in signing a petition asking President Obama and Governor Romney to tell the American people what their positions are on climate change.  The petition seeks to make climate disruption a central issue in this year’s Presidential election. Moreover, the signatories have requested that the next president hold a national summit on climate disruption within their first 100 days in office.

Campaign for Extended Producer Responsibility

posted October 22, 2012

Portfolio 21 Investments supports As You Sow’s campaign and shareholder proposal urging Proctor & Gamble to expand its packaging initiatives to include Extended Producer Responsibility (EPR).  EPR is a corporate and public policy that shifts accountability for financing the collection and recycling of materials from taxpayers and governments to producers.  EPR increases the volume of collected materials so that closed loop recycling is more commercially feasible. EPR systems can create new markets for post-consumer packaging.

Improve Environmental Reporting in Small Cap Companies

posted October 22, 2012

Portfolio 21 engaged with four of its small cap holdings, Generac, Tennant, Ameresco, and Ormat, to encourage action on initiating environmental reporting,.  Portfolio 21 has found that many smaller companies do not track environmental key performance indicators, or they may track some data but not make it publicly available. By engaging with the companies and demonstrating interest in this information we expect that as companies grow they will more readily develop sustainability programs and adopt guidelines to report on progress.

Update, 9/30/12 – Tennant responded that the company is utilizing Global Reporting Initiative guidelines for its upcoming corporate sustainability report.  It will also be reporting on its LEED (Leadership in Energy and Environmental Design) initiatives and how it is reducing its environmental footprint across its product portfolio.

Support for Alien Tort Statute in Shell Case

posted October 22, 2012

The U.S. Alien Tort Statute (ATS) was part of the Judiciary Act of 1789; ATS was revived in 1980 and has become an essential statute in protecting human rights committed by both individuals and corporations.  ATS currently allows foreign individuals to bring civil suits in U.S. courts for violations of the law of nations and U.S. treaty obligations; however, this law is being contested before the U.S. Supreme Court in Kiobel v. Royal Dutch Petroleum (Shell).  The plaintiffs are suing Shell for allegedly aiding and abetting the rape, torture, and extrajudicial killings of Nigerian environmental activists. Shell’s expected response is that it should not be liable under the ATS because the U.S. is not its country of domicile. Portfolio 21 joins with other investors to demonstrate our support for international legal frameworks, such as ATS, as it is an important tool in encouraging standardized expectations for corporate behavior related to human rights.

Increase Gender Diversity on Company Boards

posted October 22, 2012

Portfolio 21 joined with other industry leaders including business executives, elected officials, labor unions, and board members in a new initiative called the Thirty Percent Coalition.  The coalition was founded to urge companies to increase the gender diversity of their boards of directors to 30% of board seats across public companies by the end of 2015.  According to Catalyst’s 2011 census of Fortune 500 companies, women held just 16.1% of board seats in 2011 compared with 15.7% in 2010.  Portfolio 21 believes that diversity will contribute to more positive public image and improved corporate reputation.

Diversification does not assure a profit nor protect against loss in a declining market.


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