Back Litigation
Back Resolutions
Back Current Initiatives
Back Donate
Default image for pages

 <div class=”col-lg-9 content-page left-side”>
<section class=”section-a-single-resolutions resolutions-info top-content”>
<div class=”resolutions-contain”>
<div class=”top-content”>
<h4>Resolution Details</h4>
</div>
<div class=”bottom-content”>
<div class=”row-info”>
<strong>Company:</strong>
<p>Comcast Corp.</p>
</div>
<div class=”row-info”>
<strong>Year:</strong>
<p>2026 </p>
</div>
<div class=”row-info”>
<strong>Issue Area:</strong>
<p>Corporate Governance </p>
</div>

<div class=”row-info”>
<strong>Focus Area:</strong>
<p>Independent Board Chairs </p>
</div>
<div class=”row-info”>
<strong>Status:</strong>
<p>Filed</p>
</div>

<div class=”row-info”>

</a>
</div>
</div>
</div>
</section>

<section class=”section-b-single-resolutions content-blocks”>
<div class=”top-content editor-block”>
<div class=”content-block”>
<div class=”main-content”>
<h2>Resolution Text</h2>
<p><strong>RESOLVED</strong>: Shareholders request that the Board of Directors adopt an enduring policy, and amend the governing documents as necessary including the Corporate Governance Guidelines in order that 2 separate people hold the office of the Chairman and the office of the CEO as soon as possible.</p>
<p><strong>SUPPORTING STATEMENT</strong>:</p>
<p dir=”ltr”>The Chairman of the Board shall be an Independent Director. An independent Lead Director shall not be a substitute for an independent Board Chairman.<br>&nbsp;<br>The Board shall have the discretion to select an interim Chairman of the Board, who is not an Independent Director, to serve while the Board is required to seek an Independent Chairman of the Board on an accelerated basis. This policy could be phased in when there is a contract renewal for our current CEO or for the next CEO transition although it is better to adopt it now to obtain the maximum benefit.</p>
<p dir=”ltr”>An independent Board Chairman&nbsp;at all times improves corporate governance by bringing impartiality, objective oversight, and external expertise to board decisions, mitigating conflicts of interest, enhancing transparency, and boosting shareholder confidence.&nbsp;</p>
<p dir=”ltr”>This detached perspective allows the chairman to focus on&nbsp;shareholder interests,&nbsp;strengthen management accountability, and provide critical checks and balances, ultimately contributing to long-term sustainability and credibility.&nbsp;</p>
<p dir=”ltr”>This proposal topic won understated 26% support at the 2019 Comcast (CMCSA) annual meeting in spite of Mr. Brian Roberts’ stock voting against it. Mr. Roberts has 33% of the CMCSA voting power although Mr. Roberts’ money at risk is far les than 33%.&nbsp;</p>
<p dir=”ltr”>This 26%-support may have repressed more than 50%-support from the non-Roberts shares that have access to independent proxy voting advice. Shareholders who lack independent proxy voting advice tend to vote against shareholder proposals because they lack insight to both sides of an issue.</p>
<p dir=”ltr”>An independent Board Chairman could also help Comcast Corporation (CMCSA) deal with future headwinds like those that emerged in 2025:</p>
<p dir=”ltr”>CMCSA stock hit a 52-week low in October 2025, reflecting cautious market reaction and shareholder concerns over slowing broadband growth. Analysts and financial news sources also noted CMCSA carries a substantial amount of long-term debt, a whooping $93 billion in 2025.<br><br>CMCSA continued to lose a high number of customers throughout 2025. In Q3 2025 alone, CMCSA reported a loss of 257,000 TV customers and 104,000 broadband internet customers. These losses led to a decline in revenue and raised concerns among shareholders, causing CMCSA stock to hit its 52-week low in October.<br><br>A customer exodus followed CMCSA’s decision to increase prices for its Xfinity services and decrease the monthly autopay discount from $5 to $2 for those using credit or debit cards. This reportedly “angered customers.”<br><br>Analysts and customers alike pointed to long-standing issues with the CMCSA customer experience, price transparency, and a “lack of ease in simply doing business with the operator” as key reasons for high customer churn.&nbsp;</p>

</div>
</div>
</div>
<div class=”middle-content editor-block”>
<div class=”content-block”>
<div class=”main-content”>

</div>
</div>
</div>

</section>
</div>
<aside class=”col-xl-3 right-side”>
<div class=”column-contain”>

<div class=”position-groups”>
<div class=”row bs-1col node node–type-resolution node–view-mode-resolution-filers-only”>

<div class=”col-sm-12 col-md-8 bs-region bs-region–main”>
<div class=”views-element-container form-group”>
<div class=”view view-eva view-filers view-id-filers view-display-id-entity_view_3 js-view-dom-id-836d6f329b286720b010e9f807abb5dfe6f707a2ae64e03f23e4fc8a87f74dde”>

<div class=”view-content”>

<h3>Lead Filer</h3>
<div class=”views-row”>
<div class=”views-field views-field-nothing”><span class=”field-content”> John Chevedden</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Chevedden Corporate Governance</span></div>
</div>

</div>

</div>
</div>

</div>
</div>

</div>
</div>
</aside&gt 

 <div class=”col-lg-9 content-page left-side”>
<section class=”section-a-single-resolutions resolutions-info top-content”>
<div class=”resolutions-contain”>
<div class=”top-content”>
<h4>Resolution Details</h4>
</div>
<div class=”bottom-content”>
<div class=”row-info”>
<strong>Company:</strong>
<p>Comcast Corp.</p>
</div>
<div class=”row-info”>
<strong>Year:</strong>
<p>2025 </p>
</div>
<div class=”row-info”>
<strong>Issue Area:</strong>
<p>Corporate Governance </p>
</div>

<div class=”row-info”>
<strong>Focus Area:</strong>
<p>One Vote Per Share </p>
</div>
<div class=”row-info”>
<strong>Status:</strong>
<p>Challenged</p>
</div>

<div class=”row-info”>

</a>
</div>
</div>
</div>
</section>

<section class=”section-b-single-resolutions content-blocks”>
<div class=”top-content editor-block”>
<div class=”content-block”>
<div class=”main-content”>
<h2>Resolution Text</h2>
<p>Shareholders request that our Board take the necessary steps in the direction of transitioning so that all of our company’s outstanding stock has an equal one-vote per share in each voting situation. This would encompass all practicable steps including encouragement and negotiation with current and future shareholders, who have more than one vote per share, to request that they relinquish, for the common good of all shareholders, any preexisting rights, if necessary.</p>
<p>This proposal is not intended to unnecessarily limit our Board’s judgment in crafting the requested change in accordance with applicable laws and existing contracts. &nbsp;This proposal is important because certain insider&nbsp;Comcast shares have super-sized voting power. This proposal would even allow 7-years to transition to equal voting rights for each shareholder.</p>
<p>It was reported that each share of&nbsp;Comcast&nbsp;Class B Common stock had 15 votes. Meanwhile each share of Class A Common stock had only a fractional 0.1336 vote. In other words each Class B share has more than 100-times as many votes as one Class A share.&nbsp;Comcast thus has shares with&nbsp;100-to-One Voting Power.&nbsp;</p>
<p>This 100-to-One Voting structure may have led to poor performance by&nbsp;Comcast directors. For instance these directors received between 57 million and 91 million against votes each in spite of potentially obtaining all the for-votes from the insider&nbsp;Comcast&nbsp;shares:</p>
<p>Kenneth Bacon &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; 22-years excessive tenure&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;Governance Committee Chair<br>Jeffrey Honickman&nbsp;&nbsp;&nbsp;&nbsp; 19-years excessive tenure&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; Audit Committee Chair</p>
<p>Madeline Bell<br>Thomas Baltimore</p>
<p>For comparison 5 Comcast directors each received less than 9 million against votes each.</p>
<p>This proposal is more important at Comcast because the Board seems to have exercised poor judgment in naming Mr.&nbsp;Thomas Baltimore to the Comcast board in 2023. Mr.&nbsp;Baltimore was rejected by 33% of shares as a Prudential Financial director in 2019 and 2020 and then rejected by 30% of Prudential shares in 2022. Serious consideration should be given to keeping Mr.&nbsp;Baltimore off of any Comcast Board Committee. Mr.&nbsp;Baltimore was also rejected by 20% of shares as an&nbsp;American Express&nbsp;director in 2023.</p>
<p>A 5% rejection regarding a director is often the norm at well performing companies. It takes much more shareholder conviction to vote against a director than to automatically vote for a director.&nbsp;</p>

</div>
</div>
</div>
<div class=”middle-content editor-block”>
<div class=”content-block”>
<div class=”main-content”>

</div>
</div>
</div>

</section>
</div>
<aside class=”col-xl-3 right-side”>
<div class=”column-contain”>

<div class=”position-groups”>
<div class=”row bs-1col node node–type-resolution node–view-mode-resolution-filers-only”>

<div class=”col-sm-12 col-md-8 bs-region bs-region–main”>
<div class=”views-element-container form-group”>
<div class=”view view-eva view-filers view-id-filers view-display-id-entity_view_3 js-view-dom-id-0ff1d1d2d5bed59ac4f63c01f6e116749341dd5710fd8f69068f0631980735b3″>

<div class=”view-content”>

<h3>Lead Filer</h3>
<div class=”views-row”>
<div class=”views-field views-field-nothing”><span class=”field-content”> John Chevedden</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Chevedden Corporate Governance</span></div>
</div>

</div>

</div>
</div>

</div>
</div>

</div>
</div>
</aside&gt 

 <div class=”col-lg-9 content-page left-side”>
<section class=”section-a-single-resolutions resolutions-info top-content”>
<div class=”resolutions-contain”>
<div class=”top-content”>
<h4>Resolution Details</h4>
</div>
<div class=”bottom-content”>
<div class=”row-info”>
<strong>Company:</strong>
<p>Comcast Corp.</p>
</div>
<div class=”row-info”>
<strong>Year:</strong>
<p>2025 </p>
</div>
<div class=”row-info”>
<strong>Issue Area:</strong>
<p>Inclusiveness </p>
</div>

<div class=”row-info”>
<strong>Focus Area:</strong>
<p>Equal Employment Opportunity (EEO) </p>
</div>
<div class=”row-info”>
<strong>Status:</strong>
<p>Filed</p>
</div>

<div class=”row-info”>

</a>
</div>
</div>
</div>
</section>

<section class=”section-b-single-resolutions content-blocks”>
<div class=”top-content editor-block”>
<div class=”content-block”>
<div class=”main-content”>
<h2>Resolution Text</h2>
<p class=”p1″><strong>WHEREAS:&nbsp;</strong>Pay inequities persist across race and gender and pose substantial risks to companies and society. Black workers’ median annual earnings represent 81 percent of white wages in 2023. The median income for women working full time is 84 percent that of men. Intersecting race, Black women earn 73 percent and Latina women 65 percent.&nbsp; At the current rate, women will not reach pay equity until 2059, Black women in 2130, and Latina women in 2224.</p>
<p class=”p1″>Citigroup estimates closing minority and gender wage gaps 20 years ago could have generated 21.3 trillion dollars in additional national income. PwC estimates closing the gender pay gap could boost Organization for Economic Cooperation and Development (OECD) countries’ economies by 2 trillion dollars annually.</p>
<p class=”p1″>Actively managing pay equity is associated with improved representation. Diversity in leadership is linked to superior stock performance and return on equity. Minorities represent 46 percent of Comcast’s workforce and 26 percent of its vice presidents and above. Women represent 37 percent of the workforce and 45 percent of vice presidents and above.</p>
<p class=”p1″>Best practice pay equity reporting consists of two parts:</p>
<p class=”p1″>1. unadjusted median pay gaps, assessing equal opportunity to high paying roles,</p>
<p class=”p1″>2. statistically adjusted gaps, assessing whether minorities and non-minorities, men and women, are paid the same for similar roles.</p>
<p class=”p1″>Comcast does not report quantitative unadjusted or adjusted pay gaps. About 50 percent of the 100 largest U.S. employers currently report adjusted gaps, and an increasing number of companies disclose unadjusted gaps to address the structural bias women and minorities face regarding job opportunity and pay.</p>
<p class=”p1″>Racial and gender unadjusted median pay gaps are accepted as the valid way of measuring pay inequity by the United States Census Bureau, Department of Labor, OECD, and International Labor Organization. The United Kingdom and Ireland mandate disclosure of median gender pay gaps.</p>
<p class=”p1″><strong>RESOLVED:</strong>&nbsp;Shareholders request Comcast report on both unadjusted median and adjusted pay gaps across race and gender, including associated policy, reputational, competitive, and operational risks, and risks related to recruiting and retaining diverse talent. The report should be prepared at reasonable cost, omitting proprietary information, litigation strategy and legal compliance information.</p>
<p class=”p1″>Racial/gender pay gaps are defined as the difference between non-minority and minority/male and female median earnings expressed as a percentage of non-minority/male earnings (Wikipedia/OECD, respectively).</p>
<p class=”p1″><strong>SUPPORTING STATEMENT:</strong>&nbsp;A report adequate for investors to assess performance could, with board discretion, integrate base, bonus, and equity compensation to calculate:</p>
<p class=”p1″>· percentage median and adjusted gender pay gap, US and/or by country, where appropriate</p>
<p class=”p1″>· percentage median and adjusted racial/minority/ethnicity pay gap, US and/or by country, where appropriate</p>

</div>
</div>
</div>
<div class=”middle-content editor-block”>
<div class=”content-block”>
<div class=”main-content”>

</div>
</div>
</div>

</section>
</div>
<aside class=”col-xl-3 right-side”>
<div class=”column-contain”>

<div class=”position-groups”>
<div class=”row bs-1col node node–type-resolution node–view-mode-resolution-filers-only”>

<div class=”col-sm-12 col-md-8 bs-region bs-region–main”>
<div class=”views-element-container form-group”>
<div class=”view view-eva view-filers view-id-filers view-display-id-entity_view_3 js-view-dom-id-0c02ecb609145a43d5a67234a85d816c1328a966e564bff7154c2453e65b03d4″>

<div class=”view-content”>

<h3>Lead Filer</h3>
<div class=”views-row”>
<div class=”views-field views-field-nothing”><span class=”field-content”> Michael Passoff</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Proxy Impact</span></div>
</div>

</div>

</div>
</div>

</div>
</div>

</div>
</div>
</aside&gt 

 

Resolution Details

Company:

Comcast Corp.

Year:

2024

Issue Area:

Human Rights & Worker Rights

Focus Area:

AI / Artificial Intelligence

Status:

Filed

Resolution Text

RESOLVED: Shareholders request that Comcast Corporation (the “Company”) prepare and publicly disclose on the Company’s website a transparency report that explains the Company’s use of Artificial Intelligence (“AI”) in its business operations and the Board’s role in overseeing AI usage, and sets forth any ethical guidelines that the company has adopted regarding its use of AI. This report shall be prepared at a reasonable cost and omit information that is proprietary, privileged, or violative of contractual obligations.

Supporting Station

The use of AI by large corporations raises significant social policy concerns. These concerns include potential discrimination or bias in employment decisions, mass layoffs due to job automation, facility closures, the misuse and disclosure of private data, and the creation of “deep fake” media content that may result disseminate false information. These concerns pose a risk to the public and the Company’s reputation and financial position.

Transparency regarding the Company’s use of AI, and any ethical guidelines governing that use, will strengthen the Company. Transparency would address the public’s growing concerns and distrust about the indiscriminate use of AI, strengthening the Company’s position and reputation as a responsible, trustworthy, and sustainable leader in its industry. With a transparency report, the Company could establish that it uses AI in a safe, responsible, and ethical manner that complements the work of its employees and values the public.

The White House Office of Science and Technology Policy has developed ethical guidelines to help guide the design, use, and deployment of AI. These five principles for an AI Bill of Rights are 1) safe and effective systems, 2) algorithmic discrimination protections, 3) data privacy, 4) notice and explanation, and 5) human alternatives, consideration, and fallback. (White House Office of Science and Technology Policy, “Blueprint for an AI Bill of Rights: Making Automated Systems Work for the American People,” October 2022, available at https://www.whitehouse.gov/ostp/ai-bill-of-rights).

If the Company does not already have ethical guidelines for the use of AI, the adoption of ethical guidelines for the use of AI may improve the Company’s performance by avoiding costly labor disruptions and lawsuits related to the improper use of AI. The entertainment industry writer and performer strikes, sparked in part by AI concerns, and lawsuits related to the use of copyrighted works by AI engines have been prominent new stories throughout 2023 and may prove costly for companies that make use of AI.

We believe that issuing an AI transparency report is particularly important for companies such as ours in the entertainment industry that create artistic works that are the basis for our shared culture. In our view, AI systems should not be trained on copyrighted works, or the voices, likenesses and performances of professional performers, without transparency, consent and compensation to creators and rights holders. AI should also not be used to create literary material, to replace or supplant the creative work of professional writers.

For these reasons, we urge you to vote FOR this proposal.

 

 

Resolution Details

Company:

Comcast Corp.

Year:

2024

Issue Area:

Lobbying & Political Contributions

Focus Area:

Lobbying

Status:

Filed

Resolution Text

WHEREAS: Comcast Corporation (“Comcast”) is one of the nation’s largest corporate political spenders. In 2022, the Company contributed about 14 million dollars to lobbying, 9 million dollars to political contributions, and 14 million dollars to trade associations and nonprofit organizations.1

Comcast states that its PAC Board and Vice President of Political Affairs review political contributions against criterion listed in its Statement on Political and Trade Association Activity. The Company states its contributions are bipartisan, and that “no one criterion or public policy position determines whether a candidate receives a contribution.”2

Given the sheer volume of Comcast’s political spending and because spending decisions are not based solely on one public policy decision, it is crucial Comcast provides greater transparency into its political spending decision-making and regularly monitors for corporate values alignment. Especially in the current environment of increased political scrutiny, transparency into political spending alignment provides assurance the Company is adhering to its stated business interests and values.

Inconsistencies in Comcast’s stated political spending criterion and contributions may pose significant risks to the Company’s business and reputation. For example, Comcast states it supports candidates that “respect democracy and the rule of law.” Yet, Comcast supports politicians who advanced fictitious stolen 2020 election narratives. Continued support of these politicians may contribute to a denigration of the United States’s political stability, ultimately jeopardizing Comcast’s business interests.

Additionally, Comcast contributes to candidates who “support policies that make it easier to hire and retain a skilled workforce.” Yet, Comcast contributed 8 million to political recipients working to weaken reproductive health care, which undermines the Company’s ability to attract and retain female talent within restrictive states.

The Center for Political Accountability’s Model Code of Conduct advises companies to conduct a political spending misalignment review to mitigate reputational and business risks.3 Comcast should establish transparent reporting on political spending misalignment so shareholders have greater insight into how the Company balances competing interests when making political contributions.

RESOLVED: Shareholders request that Comcast publish an annual report, at reasonable expense, analyzing the congruence of the Company’s political and electioneering expenditures during the preceding year against publicly stated company values and policies, listing and explaining any trends of incongruent expenditures, and stating whether the Company has made, or plans to make, changes in contributions or communications to candidates as a result of identified incongruencies.

SUPPORTING STATEMENT: Proponents recommend, at management discretion, Comcast report metrics illuminating the degree to which political contributions align with stated values and policy priorities year over year, and present such metrics in the aggregate. Proponents recommend the report contain management’s analysis of risks to the Company’s brand or reputation associated with expenditures in conflict with publicly stated company values. “Electioneering expenditures” means spending, from the corporate treasury and from its PACs, during the year, directly or through third parties, which are reasonably susceptible to interpretation as being in support of or in opposition to a specific candidate.

1 https://corporate.comcast.com/impact/values-integrity/integrity/activity ; https://www.opensecrets.org/federal-lobbying/clients/summary?cycle=2022&id=D000000461 

2 https://update.comcast.com/wp-content/uploads/sites/33/dlm_uploads/2023/04/Statement-on-Political-and-Trade-Association-Activities-April-5-2023.pdf 

3 https://www.politicalaccountability.net/wp-content/uploads/2022/06/CPA-Zicklin-Model-Code-of-Conduct-for-Corporate-Political-Spending.pdf 

 

Resolution Details

Company:

Comcast Corp.

Year:

2023

Issue Area:

Lobbying & Political Contributions

Focus Area:

Political Contributions / Lobbying / Bribery

Status:

Vote

Vote Percentage:

19.00%

Resolution Text

WHEREAS: Comcast Corporation (“Comcast”) makes political contributions to numerous individual and organizational recipients from the corporate treasury and through political action committees (“PACs”). Comcast’s politically-focused expenditures appear to be misaligned with its public statements on Company values, views, and operational practices.

For example, Comcast has stated, “Voting is fundamental to our democracy. We believe that all Americans should enjoy equitable access to secure elections and we have long supported and promoted voter education, registration and participation campaigns across the country to achieve that goal. Efforts to limit or impede access to this vital constitutional right for any citizen are not consistent with our values.”1 Yet during the 2022 election cycle, Comcast contributed at least 447,500 dollars to members of Congress who opposed federal voting rights legislation.2

Comcast’s Statement on Political and Trade Association Activities says it seeks candidates who “respect democracy and the rule of law.”3 Yet in the 2022 election cycle, the Company contributed at least 107,000 dollars to members of Congress who rejected certification of the 2020 presidential election on January 6, 2021.4

Comcast promotes a number of initiatives designed to advance gender equity within the company, with a goal to have representation within every level of the company reach 50 percent for women. However, according to public records, the Proponent estimates since the beginning of the 2020 election cycle, Comcast has contributed at least 8 million dollars to political recipients working to weaken access to reproductive health care. Limiting access to reproductive health care is shown to reduce women’s retention in the workforce, an incongruency with Comcast’s representation goals.5

Comcast has committed to achieving carbon neutrality in its Scope 1 and 2 emissions across global operations by 2035. However, Comcast is a member of the U.S. Chamber of Commerce, which has long and consistently lobbied to constrain U.S. climate regulations.

RESOLVED: Shareholders request that Comcast publish a report, at reasonable expense, analyzing the congruence of the Company’s political and electioneering expenditures during the preceding year against publicly stated company values and policies, listing and explaining any instances of incongruent expenditures, and stating whether the Company has made, or plans to make, changes in contributions or communications to candidates as a result of identified incongruencies.

SUPPORTING STATEMENT: Proponents recommend, at Board and management discretion, that the report also include management’s analysis of risks to the Company brand, reputation, or shareholder value associated with expenditures in conflict with its publicly stated company values. Incongruent expenditures may include donations to political recipients working to reduce abortion access, eliminate climate regulations, or reduce voting rights, amongst others. “Electioneering expenditures” means spending, from the corporate treasury and from the PACs, directly or through a third party, at any time during the year, which are reasonably susceptible to interpretation as in support of or opposition to a specific candidate.

1 https://bit.ly/3uXTbEg
2 https://bit.ly/3BGR0J0
3 bit.ly/3W11WJo
4 https://bit.ly/3BGR0J0
5 https://rhiaventures.org/corporate-engagement/hidden-value-the-business-case-for-reproductive-health/

  

​ 

Resolution Details

Company:

Comcast Corp.

Year:

2023

Issue Area:

Climate Change

Focus Area:

Climate Change

Status:

Vote

Vote Percentage:

6.20%


Comcast Corp. Align Retirement Plan Options with Climate Action Goals – Proxy Memo


Resolution Text

WHEREAS:  Climate change poses growing, systemic risk to the economy. If global climate goals are not met, workers face the likelihood of significant negative impacts to their retirement portfolios. Swiss Re estimates a 4% decline in global GDP by 2050 if global temperature increases are kept below 2 degrees Celsius, but up to an 18% decline without effective mitigation.[1]

Comcast has taken certain actions to address climate change, for example, by committing to reach carbon neutrality for Scope 1 and 2 emissions, across its global operations, by 2035.[2] Yet, while decarbonizing part of its business, Comcast’s 401(k) retirement plan (“Plan”) continues to invest significantly in companies that contribute to climate change, jeopardizing workers’ life savings.

Our Company’s employee retirement funds are automatically invested in the Plan’s default investment option unless employees proactively choose different investments. Thus, the majority of the Comcast Plan’s $17.6 billion in assets are invested in its default option.[3]

Comcast has selected Vanguard Target Retirement funds as the Plan’s default offering. These funds invest significantly in fossil fuel companies and companies contributing to deforestation.[4] By investing employees’ retirement savings in companies with outsize contributions to climate change, Comcast is generating climate risk, including transition risk and long-term systemic risk, to workers’ portfolios.

Comcast’s default 401(k) choice risks compromising its obligation to select retirement plan investment options in the best interests of its plan participants, including those with retirement dates more than a decade out.

In the increasingly competitive employee recruitment and retention landscape, failing to minimize material climate risk in its 401(k) Plan default option may make it more difficult for Comcast to attract and retain top talent. Employee polling indicates that firms’ environmental records are an important consideration in choosing a job.[5] Employee polling also reveals increasing demand for climate-safe retirement plan options.[6]

Given the threat that climate change poses to employee’s life savings, our Company can help ensure employee loyalty and satisfaction, and demonstrate that it is actively safeguarding all employee retirement savings, no matter when they are set to retire, by minimizing climate risk in its Plan offerings, especially in its default option. The federal government recently clarified that fiduciaries may appropriately consider climate risk in the selection of plan offerings, including in the default option.[7]

BE IT RESOLVED:  Shareholders request that the Board publish a report, at reasonable expense and omitting confidential information, disclosing how the Company is protecting Plan beneficiaries with a longer investment time horizon from climate risk in the Company’s default retirement options.

SUPPORTING STATEMENT:  The report should include, at Board discretion, analysis of:

The degree to which carbon-intensive investments in the default investment option contribute to greater beneficiary risk and reduced Plan performance over time;
Whether carbon-intensive investments in the default investment option put younger beneficiaries’ savings at greater risk than participants closer to retirement.

[1] https://www.swissre.com/media/press-release/nr-20210422-economics-of-climate-change-risks.html

[2] https://update.comcast.com/wp-content/uploads/sites/33/dlm_uploads/2021/06/Comcast-Impact-Report-FIN3.pdf

[3] https://iyv-charts.s3.us-west-2.amazonaws.com/retirement-plans/comcast/comcast-corporation-employee-savings-plans-master-trust-form-5500-filing-and-attachment-2021.pdf

[4] https://investyourvalues.org/retirement-plans/comcast

[5] https://www.shrm.org/resourcesandtools/hr-topics/talent-acquisition/pages/climate-change-branding-can-lift-recruitment-and-retention.aspx

[6] https://www.cnbc.com/2019/04/09/workers-want-elusive-socially-responsible-investments-in-401k-survey.html

[7] https://www.federalregister.gov/documents/2022/12/01/2022-25783/prudence-and-loyalty-in-selecting-plan-investments-and-exercising-shareholder-rights

  

​ 

Resolution Details

Company:

Comcast Corp.

Year:

2023

Issue Area:

Inclusiveness

Focus Area:

Equal Employment Opportunity (EEO)

Status:

Vote

Vote Percentage:

10.80%


Comcast Corp. Racial Equity Audit – Proxy Exempt Solicitation


Resolution Text

RESOLVED that shareholders of Comcast Corporation (“Comcast”) urge the Board of Directors to oversee an independent racial equity audit analyzing Comcast’s adverse impacts on nonwhite stakeholders and communities of color and describing the steps, if any, Comcast plans to take to mitigate those impacts. Input from civil rights organizations, employees, and customers should be considered in determining the specific matters to be analyzed. A report on the audit, prepared at reasonable cost and omitting confidential and proprietary information, should be publicly disclosed on Comcast’s website.

SUPPORTING STATEMENT

High-profile police killings of Black people have galvanized the movement for racial justice. That movement, together with the disproportionate impacts of the COVID-19 pandemic, have focused the attention of the media, the public and policy makers on systemic racism, racialized violence and other inequities.

Several aspects of Comcast’s business and operations suggest that a racial equity audit would be useful. Although Comcast touts the fact that its diversity programs have resulted in the “most inclusive employee representation” since Comcast began reporting diversity data,1 representation in senior management continues to lag. According to EEO-1 data for 2021, only 6.6% of Comcast’s executives/senior officers are Black, compared to 18.1% of the workforce generally.2

In October 2020, Comcast entered into a conciliation agreement with the U.S. Labor Department to resolve allegations of pay discrimination against Black and Latino employees. Comcast denied the allegations, but agreed to back pay and interest plus salary adjustments.3

Comcast has sponsored the Philadelphia Police Foundation’s annual gala,4 though donor information is no longer provided on the organization’s web site. Police foundations bypass normal procurement processes to buy equipment for police departments, including surveillance technology used to target communities of color and nonviolent protestors.5

Despite claiming that “[e]fforts to limit or impede access to this vital constitutional [voting] right for any citizen are not consistent with our values,” Comcast donated to several state lawmakers who sponsored legislation restricting access to voting. Among those recipients was Florida state senator Dennis Baxley, the only sponsor of a bill, later signed into law, that criminalized providing water to voters in line and limited availability of drop boxes, among other measures.6 Voting restrictions have already exacerbated racial turnout gaps, and two states that adopted them are being sued for intentionally discriminating against nonwhite voters.7

  

​