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 supporting the Design for the Environment Program

posted January 6, 2015

The Environmental Protection Agency’s Design for the Environment (DfE) program is under threat of major alteration with a policy rider in the House of Representatives version of the Interior Appropriations bill. Portfolio 21 believes the DfE program should remain intact as it encourages businesses to develop safer products and chemicals. We wrote the House of Representatives to express our opposition to any legislative riders that would dismantle the DfE program.

Request to Ebay to end its affiliation with ALEC

posted January 6, 2015

Portfolio 21 has maintained a position in Ebay since 2010. As a concerned investor we wrote the company to request that it end its affiliation with the American Legislative Exchange Council, also known as ALEC. Microsoft, Google, Facebook, and Yahoo! have ended their ALEC membership because of concerns about the harmful role ALEC plays in our democratic process. This includes concerns with ALEC’s policy stands, its secretive practices, and its effort to treat what most people consider a lobbying operation as “charitable” activity.

NOTE: On December 18, eBay announced it ended its membership in ALEC.

Seeking international progress on ESG disclosure

posted October 8, 2014

In conjunction with other investors, Portfolio 21 requested that The International Organization of Securities Commissions work more closely with regulators, stock exchanges, and other related parties to improve the disclosure of material environmental, social and governance information.

Urge members of Palm Oil Manifesto Group to improve palm oil practices

posted October 8, 2014

Palm oil is an issue with which Portfolio 21 is very engaged. In an effort to educate and encourage industry best practices, Portfolio 21 and other investors collectively engaged members of the Palm Oil Manifesto Group, including Kuala Lumpur Kepong (KLK), Sime Darby, IOI Group and Asian Agri Resources, to request an immediate moratorium on clearance of any potential high carbon stock and peat land areas. The group also urged members to adopt a time bound plan by which to receive third party certifications for all of the palm oil produced.

Letter to Environmental Protection Agency re: Bristol Bay mining

posted October 8, 2014

For several years, Portfolio 21 has joined other investors in providing comments to the Environmental Protection Agency (EPA) expressing concerns about large-scale mining in the Bristol Bay region of Alaska. With the proposed determination released, we wrote urging the EPA to issue a final determination that provides long-term protections for this natural area. Additionally, the final determination would help remove regulatory risk and uncertainty surrounding mining in the region.

2014 Investor Statement on Climate Change

posted October 8, 2014

Portfolio 21 is one of many signatories to the Investor Statement on Climate Change, which was prepared by a coalition of institutional investors seeking to expand opportunities for low carbon and climate resilient investments. Ways in which institutional investors can contribute include: working with policy makers, identifying and evaluating low carbon investment opportunities, developing capacities to assess risks and opportunities, and company engagement and increased transparency. For more information on the Investor Statement on Climate Change, visit

Climate Disclosure Standards Board Statement

posted October 8, 2014

Recognizing the challenge that climate change will have on economic activity, Portfolio 21 joined other investors and corporations to collectively voice our concern through the Climate Disclosure Standards Board on the lack of “comprehensive and comparable” climate related information in mainstream corporate reports. To address this gap, the Climate Change Reporting Framework has been developed. Together we urge companies and organizations to utilize this framework “as a practical step enabling positive change in economic and financial market activity at scale.”

Letter to Environmental Protection Agency re: methane regulation

posted October 8, 2014

Methane is a highly potent greenhouse gas 84 times more powerful than carbon dioxide over a 20 year time period. The oil and gas industry is the largest emitter of methane in the U.S.1 Due to methane’s significant contribution to global climate change, Portfolio 21 joined with other investors to urge the EPA to regulate methane emissions from the oil and gas industry.

  1. IPCC, Climate Change 2013: The Physical Science Basis, Fifth Assessment Report, Chapter 8 (Table 8.A.1) []

Advocating for Carbon Pollution Standards

posted July 11, 2014

According to the Environmental Protection Agency, electric power plants are the single largest source of carbon pollution in the United States. Despite this impact, there are currently no federal limits on the amount of carbon pollution power plants can emit. Portfolio 21, in conjunction with other concerned investors, wrote President Barack Obama to share our strong support for the creation of carbon pollution standards for new and existing power plants.  The Carbon Pollution Standards will be key to reducing this significant source of emissions.

2014 Solar Scorecard Survey

posted July 11, 2014

Solar power generates clean electricity without the toxic pollution or global warming consequences created by fossil fuels, however, solar power still creates an environmental impact. Potential impacts include land use and habitat loss, water use, and the use of hazardous materials in manufacturing. For this reason, Portfolio 21 joined other investors to show our support of the Silicon Valley Toxics Coalition’s research and survey. We encourage solar companies to participate in this project to improve transparency and best practices.

Encouraging environmental leadership at Apple

posted July 11, 2014

The appointment of Lisa Jackson, former Administrator of the U.S. Environmental Protection Agency, to Vice President of Environmental Initiatives at Apple, Inc. was strong signal from Apple that it is taking its environmental responsibility more seriously.  Recognizing Ms. Jackson’s educational background as a chemical engineer as well as a senior manager at Apple; Portfolio 21 joined other investors in encouraging Ms. Jackson to influence Apple “to be the first major electronics brand to disclose and eliminate the most dangerous chemicals from [its] manufacturing processes and ensure better protections for workers who are exposed to chemicals.”

Letter to L’Oreal Concerning Child Labor in Supply Chain

posted May 13, 2014

On March 20, Danish nongovernmental organization, DanWatch released a report that stated most of the mica used by global cosmetics companies originates from illegal mines in India where child labor is commonly used. More specifically, this report identified two of L’Oréal’s suppliers. Portfolio 21 has written L’Oreal requesting the company’s response. Moreover, we inquired how these suppliers were evaluated against L’Oréal’s Code of Business Ethics, its “Buy & Care” program, and its social audits.

Support for Oregon Clean Fuels Program

posted May 13, 2014

Portfolio 21 engaged Oregon’s Senators and Representatives to express our strong support for the Oregon Clean Fuels Program (CFP) and to advocate lifting the existing 2015 sunset provision. We believe that the CFP advances Oregon’s economic and environmental interests by encouraging investment in clean fuel technology. Independent economic analysis has shown that the CFP should significantly benefit Oregon’s economy, Oregon’s fuel cost savings, employment rate, personal income and gross state product.1

  1. Jack Faucett Associates, “Economic Impact Analysis of the Low-Carbon Fuel Standard Rule for the State of Oregon,” 2011. Accessed April 1, 2014. []

Bunge Investor Letter

posted May 13, 2014

In an effort to further promote the development and use of more sustainably produced palm oil, in conjunction with other concerned investors, engaged Bunge (not a Portfolio 21 holding) on our concerns regarding one of its main palm oil suppliers – Sarawak Oil Palms Berhad (SOP). SOP has been actively fighting recent industry initiatives to protect forests, peatlands and local communities. Portfolio 21 believes that sustainable palm oil is essential to the long term viability of this industry and recognizes that the suppliers are an essential component in achieving this goal. Given SOP’s lagging sustainability efforts we have asked Bunge to sever ties with SOP.

Investors Support Wilmar’s Palm Oil Policy

posted May 13, 2014

In an effort to further promote the development and use of more sustainably produced palm oil, Portfolio 21 joined other investors to applaud Wilmar, (not a Portfolio 21 holding) the world’s biggest palm oil trader, for its groundbreaking new forest conservation policy. If fully implemented, Wilmar’s policy would set a new standard for agricultural commodity production that protects forest and peatland ecosystems as well as local communities. Portfolio 21 encourages other companies to demonstrate their commitment to sustainable agricultural production and tackling climate change by adopting similar policies that pledge to eliminate deforestation from their supply chains.

Investor Letters on Palm Oil

posted May 13, 2014

As of September 2013, Portfolio 21 established a position in New Britain Palm Oil, a palm oil producer that we believe has shown leadership on environmental, social, and governance management. Our research into this industry strengthened our understanding of the ecological consequences unsustainable practices have on the ecosystems that support this commodity. To this end, Portfolio 21 signed an investor letter urging major stakeholders in the palm oil industry to adopt policies that would ensure palm oil development does not contribute to deforestation, development on peatlands, or human rights violations.

Letter to Google regarding ALEC

posted May 13, 2014

Google has been a holding in Portfolio 21’s Global Equity Strategy since 2008 and is currently our largest position. Recently Google has been criticized for its membership and participation in ALEC – the American Legislative Exchange Council. ALEC is an organization that has been thoroughly researched and documented by the Center for Media and Democracy and subsequently criticized by the Center for its “shameful assaults on democratic principles.” Portfolio 21 wrote to inquire why Google has chosen to establish membership in ALEC and participate on its Communications and Technology Task Force. Moreover, we want to know what specific actions ALEC supports that align with Google’s “Don’t be evil” business approach.

Note: As of March 31, 2014, Portfolio 21 has not garnered a response, despite sending a follow up correspondence on this matter.


Letter regarding "No on Prop 37"

posted May 13, 2014

As reflected in our Agricultural Biotechnology policy, Portfolio 21 perceives genetically modified organisms (GMOs) as high risk. Therefore, in conjunction with other concerned investors, we addressed the top 50 companies who had previously spent the most to defeat Prop 37, a California ballot measure that would have provided consumers with GMO labelling information. We urged these companies not to use treasury funds to oppose legislation that mandates labeling of foods containing GMOs.

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