Author:Dr. William Cox | Opinion  Updated: April 14  Published April 14

• JPMorgan sought to exclude our GFI-related proposal, but it lost its appeal to the SEC.
• For 2018, we submitted a differently worded proposal, focusing on JPMorgan’s resistance to genocide-free investing despite its published corporate values that suggest that JPMorgan wants to do the right thing. It’s titled “Proposal to Report on Investments Tied to Genocide.”
• Read the text of the 2018 proposal that will be presented at JPMorgan annual meeting on May 15, 2018.
• Read Eric Cohen’s presentation of the 2018 proposal at the May 15 annual meeting.
• Read the 2018 JPMorgan proxy statement.
• Read the whitepaper on Genocide-free Investing: How and why investment firms should avoid ties to genocide.

The 2018 proposal states:

Shareholders request that the Board of Directors report to shareholders, at reasonable expense and excluding confidential information, an analysis of how JPMorgan’s published corporate values align with its policies regarding investments in companies tied to genocide or crimes against humanity, and specifically explain how its investments in CNPC/PetroChina are consistent with its published corporate values.

Proxy voting in 2013

Genocide-free investing received 9.55% in favor at JPMorgan Chase’s annual meeting on May 21, 2013

• The 2013 vote result was slightly lower than the 2012 result. IAG objected in writing to JPMorgan, on April 19, 2013, just after they published the 2013 proxy, that the wording of the short description for the proposal on the JPMorgan ballot for 2013 served to diminish support for the genocide-free investing proposal because it labeled the proposal as “Adopt procedures to avoid holding or recommending investments that contribute to human rights violations” rather than using the title of the proposal as done for the 2012 ballot as “Genocide-free investing.” That change alone could be responsible for the the voting result being slightly lower than 2012.
• Read Eric Cohen’s presentation of the genocide-free investing proposal at the May 21, 2013, annual shareholder meeting for JPMorgan.
• Read the whitepaper on Genocide-free Investing: 2013 Proxy Votes at JPMorgan Chase and Franklin Resources.

The proposal stated:

Shareholders request that the Board institute transparent procedures to avoid holding or recommending investments in companies that, in management’s judgment, substantially contribute to genocide or crimes against humanity, the most egregious violations of human rights. Such procedures may include time-limited engagement with problem companies if management believes that their behavior can be changed. In the rare case that the company’s duties as an advisor require holding these investments, the procedures should provide for prominent disclosure to help shareholders avoid unintentionally holding such investments.

Proxy voting in 2012

Genocide-free investing received 10.74% in favor at JPMorgan Chase’s annual meeting on May 15, 2012

• Read William Rosenfeld’s JPMorgan 2012 Shareholder Meeting Presentation at the JPMorgan Chase annual meeting.
• Download 2012 Proxy Vote on Genocide-free Investing at JPMorgan Chase for a detailed analysis of the proposal.
• Contact us for a private discussion of the merits of the proposal.
• JPMorgan faces backlash over ties to Sudan, CNN Money, May 11, 2012
• Genocide-free Investment Proposal Gains Traction, Despite Opposition from JPMorgan, Enough Project, May 17, 2012

Ad in Pensions & Investments – April 2, 2012

• IAG ran an ad in Pensions & Investments in advance of the voting on genocide-free investing on the proxy ballot at JPMorgan Chase’s annual meeting.
• Click on the image on the right to see the full-page ad in Pensions & Investments from April 2, 2012.
• IAG is very grateful for the support and generosity of the donor who made this ad possible.

Should institutional investors support investments tied to genocide? Research shows that the vast majority of Americans want to avoid investments tied to genocide.  Even so, many financial institutions invest in a handful of companies, such as PetroChina, that help to fund the government of Sudan’s deadly campaign of violence against millions of its citizens.  With a billion-dollar stake as of September 2011, JPMorgan Chase is one of PetroChina’s largest investors. This proxy season, JPMorgan Chase shareholders can vote to tell the company to avoid investments tied to genocide.  Last year, institutions voting for the genocide-free investing shareholder proposal included T. Rowe Price, AFSCME Employees Pension Plan, Christian Brothers and many others. How will you vote? Will you draw the line at genocide? Vote your proxy.  Tell JPMorgan Chase to avoid investments tied to genocide.

February 09, 2018

GENOCIDE IN SUDAN: YOU’RE MAKING A KILLING WITH YOUR FIDELITY 401(K)

Eric Cohen, Founder of Investors Against Genocide, explains the historical origins of the multiple genocides that have been raging in Sudan since 1989. He elaborates upon the ruling regimen’s reliance on oil revenue to fund their genocidal campaigns, how PetroChina is the largest purchaser of that oil, and how many Americans have invested their savings in mutual funds with large brokerage houses that significantly invest in PetroChina through the Hong Kong Stock Exchange.

Vanguard marshals the resistance

Nov 23rd 2017| SCOTTSDALE, ARIZONA

VANGUARD, an American fund-management giant, promises “the highest standards of ethical behaviour”. Its low fees, helpful call centres and lack of scandal give the claim credence. It is by far the largest mutual-fund group, with $4.8trn under management. It receives more than half of all the new money going into American mutual funds. Most ends up in its passively managed offerings that track indices.

So you might think its shareholder meetings would be pious celebrations. Instead, Vanguard tries to avoid them. On November 15th it held its first since 2009, to satisfy a legal requirement that two-thirds of fund directors are elected rather than appointed. It held the meeting near its Arizona satellite office, far from its Philadelphia-area headquarters. Only 200 of its 20m clients showed up, trudging through metal detectors and tight security.

Vanguard may have been pleased by the small turnout. Among those dogged 200 who attended were representatives of an activist group, Investors Against Genocide. It had submitted a motion asking Vanguard to avoid investing in companies that, “in management’s judgment, substantially contribute to genocide or crimes against humanity”. The motion cited numbers from Vanguard’s financial disclosures in April showing $1.9bn held in companies that the group said were complicit in genocidal actions by doing business in Syria, Myanmar and Sudan: China Petroleum, Kunlun (an affiliate), PetroChina, Sinopec and Petronas (from Malaysia).

Vanguard’s management opposed the motion, arguing against prescriptive constraints on a fund’s investible universe—especially index funds, which are mandated to purchase shares in every company that makes up an index. In a brief statement, the company’s outgoing chief executive, William McNabb, said there were better avenues than fund companies to pursue the ethical concerns at stake, such as diplomacy. If individuals did not like this, they need not buy a global index that included the controversial companies.

Eric Cohen of Investors Against Genocide was unswayed. He argued that Vanguard could certainly have accepted the motion for its actively managed funds; and that though it is hard to exclude a company from a narrow index, it is feasible and legal to omit a few from those, like most of Vanguard’s, with a broad mandate. Two big American investment managers, TIAA and T. Rowe Price, have begun to implement his group’s ideas, as has American Funds, a vast active manager. His arguments have also made some headway with Vanguard’s shareholders, who voted in higher proportion for the motion than in 2009.

Vanguard’s main concern may be that one shareholder motion will lead to a deluge of them. Ever more interest groups oppose different industries for different moral reasons. Vanguard has created a team to raise issues of concern with companies and to direct its votes on shareholder proposals. But that is a far cry from shunning particular shares. If it were forced to do so, the risk is that so many issues become cause for divestment that ethical concerns pose a threat to Vanguard’s business.

Updated: NOVEMBER 15, 2017 — 5:35 PM EST

by Erin Arvedlund, Inquirer Staff Writer  @erinarvedlund |  EArvedlund@phillynews.com

Vanguard Group shareholders voted Wednesday to approve a board of trustees for all its U.S.-based funds, while an activist shareholder group lost on a ballot question proposing that Vanguard divest from PetroChina and Sinopec, two Chinese energy firms doing business in Sudan and allegedly engaging in genocide.

The votes came at a special shareholders meeting in Scottsdale, Ariz., the company said Wednesday afternoon.

Vanguard chairman William “Bill” McNabb and new president Mortimer “Tim” Buckley were elected as two “interested” nominees, as were eight current independent trustees: Mark Loughridge, lead independent trustee, and retired president and chief operating officer of Cummins Inc.; Amy Gutmann, president of the University of Pennsylvania; Emerson U. Fullwood; JoAnn Heffernan Heisen; F. Joseph Loughrey; Scott C. Malpass; André F. Perold; and Peter F. Volanakis.

Two new independent trustees also were elected: Sarah Bloom Raskin, former deputy secretary of the U.S. Treasury, who joined the board in 2017 and is one of the first ex-government officials to join Vanguard; and Deanna Mulligan, president and CEO of Guardian Life Insurance Co. of America. (More details about the full board are available at Vanguard’s website: https://about.vanguard.com/who-we-are/our-leaders. Click “Board of directors.”)

All Vanguard funds are overseen by the board of trustees. Generally, the same people serve on the Vanguard board of directors and the trustees board. Buckley, Mulligan, and Bloom Raskin stood for election Wednesday to both boards.

Vanguard had recommended that its shareholders vote “against” the divestment proposal put forth by activist group Investors Against Genocide, which read: “Proposal 7— A shareholder proposal to institute transparent procedures to avoid holding investments in companies that, in management’s judgment, substantially contribute to genocide or crimes against humanity, the most egregious violations of human rights. Such procedures may include time-limited engagement with problem companies if management believes that their behavior can be changed.”

Eric Cohen, co-founder of Investors Against Genocide, traveled to Arizona to address the shareholders meeting and urge that they vote for divestment.

“The more ordinary people bother to take a look at the ballot, the more they ask: `How could Vanguard be opposing this?’ ” said Cohen, a retired IT professional from Boston. He said Fidelity has divested from PetroChina and Sinopec, as has Warren Buffett’s company, Berkshire Hathaway.

“I’m not surprised that Vanguard’s board is fighting these proposals. I don’t believe that socially responsible or ESG [environmental, social and governance] investing is necessarily a road to higher returns,” said Daniel Wiener, editor of the Independent Adviser for Vanguard Investors, a monthly newsletter.

“However,” Wiener said, “I also don’t believe that Vanguard’s proxy-voting record suggests a concern with the issues at hand. As one of the largest share-owners in the world, I believe it’s Vanguard’s duty to put more of its votes to work turning corporations into good citizens through its direct engagement but, more importantly, through its voting. Vanguard doesn’t do that.”

Cohen said he was pleased that an average 20 percent of Vanguard’s 28 million customers voted for divestment, ranging from 6 percent of shareholders in one fund to 39 percent in the socially responsible fund. Investors Against Genocide presented a similar ballot question at Franklin Templeton’s special shareholder meeting Oct. 30 in San Mateo, Calif., and will put one forth at JPMorgan next year.

“I’m quite satisfied with these results; something like an average 20 percent of shareholders indicated this is something that concerns them,” Cohen said. He is expecting to speak to and meet with representatives from Vanguard’s Investment Stewardship group about the divestment issue.

Vanguard Shareholders Vote on Genocide-Free Investing in Mutual Funds

Today Vanguard is holding a Joint Special Meeting of Shareholders in Scottsdale, Arizona. Shareholders have been asked to vote on board of trustees nominations and on several fund proposals that will harmonize policies across Vanguard’s US-based funds. In addition, Vanguard shareholders have had the opportunity to vote on a proposal spearheaded by Investors Against Genocide (IAG), a citizen-led initiative dedicated to convincing mutual funds and other investment firms to make an ongoing commitment to genocide-free investing. The proposal calls upon Vanguard to institute transparent procedures to avoid holding investments in companies that, in management’s judgement, substantially contribute to genocide or crimes against humanity, the most egregious violations of human rights. While its sentiment extends beyond Sudan, IAG is advocating in particular for targeted divestiture from companies that support government sponsored genocide in Sudan, specifically identifying four foreign oil companies, including one with two publicly traded subsidiaries and two with ADRs listed in the US, that are the largest business partners with the government of Sudan. These firms, five in total, each of which is domiciled in a developing market, are: China Petroleum & Chemical Corporation/Sinopec and PetroChina/CNP, both China based, ONGC of India and Malaysia-based Petroliam Nasional Berhad (PETRONAS) via its two publicly listed subsidiaries. The resolution, as it relates to Sudan, is not likely to have an impact on Vanguard’s funds with a US focus. Affected mutual funds are more likely to be actively managed equity and bond funds as well as index funds with a global mandate that include developing markets, emerging markets and Asia-Pacific region, in particular, as well as global bond funds. That said, passage is unlikely. Vanguard acknowledges that the humanitarian issues on which this proposal is ultimately focused are of consequence and deep concern, however, Vanguard opposes the resolution for at least four reasons.

Vanguard is the second largest asset management firm in the world with about $4 trillion in assets under management, offering 180 funds and serving over 20 million investors worldwide. It stands to reason that a large number of investors in some of Vanguard’s index funds are likely to be impacted but concerned investors always have the option to vote with their feet, if they wish, by exiting from funds that currently hold such securities and/or funds that have the guidelines flexibility to do so currently or in the future. That said, there are limited alternative investment options within Vanguard itself as the management company only offers one US focused sustainable investment fund[1]. On the other hand, investors with flexibility to invest outside of Vanguard’s universe of 180 investment funds can pivot into mutual funds with similar investment objectives but which, at the same time, explicitly integrate environmental, social and governance (ESG) strategies that are more likely to exclude firms engaged in genocide or do business in the Sudan. Some funds in this category, but not all, also specifically exclude funds doing business in Sudan. There are at least 10 actively managed equity funds and two actively managed bond funds as well as just two index mutual funds, all outside of the Vanguard complex, available as potential investment options for investors[2]. While these are listed below, investors should be cautioned that, as is the case before investing in funds more generally, due diligence should be conducted to ensure that, at minimum, these funds satisfy basic requirements, including qualifications and skills to combine financial and sustainability characteristics, a demonstrated, established and consistent performance track record over time, properly sized funds for scale and liquidity and effectively priced fund offerings. In a future article, these funds will be more formally evaluated.

Sudan’s Genocide Has Been Going On for Decades

In one of the worst campaigns of violence and mass slaughter since World War II, it has been reported that more than 2.5 million civilians have been killed in Sudan over decades of brutal conflict between north and south, in Darfur in the west, and in other regions of Sudan. Since the 1950s, the Arab-dominated government of Sudan, centered in the capital Khartoum and led by President Omar al-Bashir since his appointment as President in 1993, tried to impose its control on the country’s African minorities living along the nation’s periphery. The result has been a deadly mix of ethnic, religious, politically motivated and, since the discovery of oil in the South in 1973, financially fueled conflicts. Though the north-south civil war ended in 2005 when, under heavy international influence, a Comprehensive Peace Agreement was signed and South Sudan gained its independence in July 2011, systematic violence has continued.

In 2003, the Sudan government responded with crushing brutality to a rebellion in the Darfur region of Sudan, beginning a genocidal campaign against civilians that resulted in the deaths of nearly 400,000 people, the systematic raping of women, the burning of villages, the poisoning of wells and the displacement of millions of people that by some estimates exceed three million. Both the African Union and the United Nations introduced forces to stop the violence and assist the internally and externally displaced refugees.

The situation in Sudan is not disputed. The United States, under President Clinton, first imposed sanctions on Sudan in 1997, including a trade embargo and blocking government assets, in response to the Sudan’s government support of international terrorism, ongoing efforts to destabilize neighboring governments, and the prevalence of human rights violations, including slavery and the denial of religious freedom. Additional sanctions were added in 2006 in response to the persistence of violence in Sudan’s Darfur region, particularly “against civilians and including sexual violence against women and girls, and by the deterioration of the security situation and its negative impact on humanitarian assistance efforts.[3]”

Even before its embargo extension, the United States government in 2004 recognized the actions of the Sudanese government as genocide under the United Nations (UN) Genocide Convention.

Shortly thereafter, in March 2005, the UN Security Council referred the case of Darfur to the International Criminal Court (ICC). On March 4, 2009, the ICC announced a historic decision to issue an arrest warrant charging Sudanese President Bashir with five counts of crimes against humanity and two counts of war crimes for his leadership role in orchestrating the conflict in Darfur.  Despite his indictment, President Bashir remains in office and travels abroad with impunity, as do other Sudanese leaders charged with war crimes and crimes against humanity.

While the conflict has faded from the spotlight, ongoing violence continues to displace, injure, and kill people today.  According to the Human Rights Watch 2017 World Report, Sudan’s human rights record remains abysmal in 2016, with continuing attacks on civilians by government forces in Darfur, Southern Kordofan, and Blue Nile states; repression of civil society groups and independent media; and widespread arbitrary detentions of activists, students, and protesters. The ruling National Congress Party proceeded with a national dialogue process to pave the way for a new constitution and government, following the independence of South Sudan, despite a boycott by several opposition parties.

Still, after temporarily easing sanctions in January of this year, the US last month permanently lifted a raft of sanctions on Sudan, saying the African nation had begun addressing concerns about terrorism as well as human rights abuses against civilians in the country’s Darfur region. The decision to lift the sanctions and end an economic embargo comes after the Trump administration last month removed Sudan from the list of countries whose citizens are subject to travel restrictions. Sudan was the only country that was removed.

Following the civil war, the genocide and the 1997 imposition of a comprehensive trade embargo by the US against Sudan, US companies and many international petroleum companies withdrew from the Sudanese market, but some foreign companies continue to do business in Sudan.

The Investors Against Genocide (IAG) Case

Investors Against Genocide was founded in 2006 to advocate for targeted disinvestment from companies that supported the genocidal regime in Sudan. While US companies and many international companies had exited the Sudanese market following the imposition in 1997 of a comprehensive trade embargo against the Sudanese government, IAG advocates for investment firms to avoid or divest their holdings in four foreign oil companies that are significant business partners with the Government of Sudan.  These companies are large energy companies headquartered in the emerging markets of China, India and Malaysia, including PetroChina/CNP, China Petroleum & Chemical Corporation/Sinopec, ONGC and PETRONAS via two publicly listed subsidiaries.

In addition to advocating for genocide-free investing on humanitarian and legal grounds, IAG believes that it is consistent with the objectives and spirit of the US economic sanctions (now lifted) in Sudan and stated values and commitments of investment firms. A further strong argument in favor of the resolution made by IAG is that there is broad-based support for genocide-free investing, as validated according to research conducted by KRC (a unit of the publicly traded Interpublic Group of Companies (IPG)) in 2007 and 2010 showing that 88% of respondents want their mutual funds to be genocide-free.  Recent shareholder proposals and proxy votes that have earned strong shareholder endorsements along with actions by firms such as T. Rowe Price and TIAA-CREF to implement policies on investments tied to genocide also offer support for IAG’s position.

Five Companies Have Been Identified: China Petroleum & Chemical Corporation (SINOPEC). PetroChina Company Limited, Oil and Natural Gas Corporation Limited (ONGC) and Petroliam Nasional Berhad (PETRONAS), Including Petronas Chemicals and Petronas Gas Berhad

The companies listed below have been identified by Investors Against Genocide for their operations in the Sudan and significant business partnerships with the Government of Sudan. These are listed companies, in part or in whole, with stocks that trade in local markets and in some cases in the form of ADRs listed for trading on NYSE. These firms have also issued bonds. Their stocks and bonds are most likely to be held in actively managed equity and bond funds as well as index funds with a global mandate that includes developing markets, emerging markets and Asia-Pacific region, in particular, as well as global bond funds. For example, the stock of all five companies was held in the Vanguard Emerging Markets Stock Index Fund as of September 30, 2017.

China Petroleum & Chemical Corporation (SINOPEC). A subsidiary of China Petrochemical Corporation, Beijing-based SINOPEC is an energy and chemicals company engaged in oil, gas and chemicals operations, including the exploration for and development of oil fields, production and sales of crude oil and natural gas, to mention just a few of its operations.

SINOPEC is the third-largest company of China by revenue, recording $255.7 billion in sales and assets in the amount of $216.7 billion. SINOPEC is listed in Hong Kong and also trades in Shanghai and New York on the NYSE in the form of ADRs (NYSE: SNP).

PetroChina Company Limited. A Chinese oil and gas company engaged in a range of activities that include the refining, exploration, development, production, marketing of crude oil and

natural gas as well as transmission and sale of natural gas, crude oil, and refined products. The company operates as a subsidiary of state-owned China National Petroleum Corporation, headquartered in Dongcheng District, Beijing. PetroChina is China’s biggest oil producer and the world’s fourth-largest oil and gas company by revenues, generating $214.8 billion in sales with assets in the amount of 344.9 billion. PetroChina Company Limited ADRs are listed on the NYSE (NYSE: PTR).

Oil and Natural Gas Corporation Limited (ONGC). An India-based publicly listed global energy holding company whose shares are largely owned by the Government of India (68.94%) with the remaining shares held by institutional and retail investors. Its $19.9 billion in revenue and $57.7 billion in assets sourced to the company’s activities in the exploration, development and production of crude oil and natural gas within and outside India. It is the largest crude oil and natural gas producer in India.

 Petroliam Nasional Berhad (PETRONAS). PETRONAS is Malaysia’s fully integrated oil and gas multinational that is largely owned by the Malaysian Government. The firm’s business activities include but are not limited to the exploration, development and production of crude oil and natural gas in Malaysia and overseas, the liquefaction, sale and transportation of Liquefied Natural Gas (LNG), the processing and transmission of natural gas and the sale of natural gas products and the refining and marketing of petroleum products.

While PETRONAS is privately held, two of its subsidiary companies, both majority owned by PETRONAS, Petronas Chemicals (PGC), which generated $3.3 billion in revenues and reported assets of $14 billion, and Petronas Gas Berhad (PGB), with revenues of $1.1 billion and assets in the amount of $8.8 billion, are listed for trading on the Malaysian Stock Exchange. PETRONAS owns 64.35% of PGC and 60.63% of PGB while the remaining 35.6% and 39.37% are held by financial institutions and retail shareholders.

Interestingly, both publicly listed firms are constituent members of the FTSE4Good Bursa Malaysia Index which is designed to highlight companies that demonstrate a leading approach to addressing environmental, social and governance risks[4].

Vanguard Opposes the Genocide-Free Investing Resolution for Various Reasons

The trustees of the named Vanguard funds recommend that shareholders vote against this proposal. According to Vanguard’s detailed response, the humanitarian issues on which this proposal is ultimately focused are of consequence and deep concern. At the same time, meaningful long-term solutions to these issues require diplomatic and political resources to come together to implement change. Vanguard notes that its funds are compliant with all applicable US laws on this matter. In addition, the proposal would interfere with the advisors’ fiduciary duty to manage funds in line with their investment objectives and strategies. Finally, Vanguard adds that it believes that the divestment contemplated by the proposal would be an ineffective means to implement the social change it seeks. Refer to Vanguard’s detailed response in the accompanying box.

Vanguard’s Detailed Response to IAG’s Resolution

 Investment Options for Concerned Genocide-Free Investors

Should the resolution be rejected by Vanguard’s shareholders as expected, investors concerned about the possibility of inadvertently investing in any of the companies noted above can conduct their own due diligence research into the securities holdings of funds that are most likely to hold shares or bonds in any of the identified firms and/or have the flexibility to invest in such firms currently or in the future[5]. Although securities listed and traded in the US in the form of ADRs could technically be included in US focused funds, this not probable. Rather, these securities are most likely to be held in actively managed equity and bond funds as well as index funds with a global mandate that include developing markets, emerging and Asia-Pacific focused markets, in particular, as well as global bond funds.

More generally, however, investors who wish to implement a genocide-free investment strategy should consider the option of pivoting to mutual funds that explicitly integrate environmental, social and governance factors into their investment strategy and decision making. Rather than relying exclusively on strategies based on negative screens, such firms employ industry and company-specific positive selection criteria to identify potentially positive investment opportunities or achieve risk reduction. Such a strategy may also encapsulate shareholder advocacy and active proxy voting. Funds in this category, even in the absence of specific exclusionary criteria for genocide or related controversies, are more likely to exclude firms engaged in genocide for governance and social reasons and also to limit exposure to fossil fuel companies due to environmental concerns.

The accompanying Table 1 reflects the results of screening and analysis conducted for the purpose of identifying actively managed funds and index funds pursuing a global mandate that includes developing markets, emerging markets and the Asia-Pacific region, in particular, as well as global bond funds. Excluded from the list are thematic funds, or funds that focus strictly on environmental issues, alternative energy, low-carbon strategies funds that invest strictly in green bonds as well as funds whose prospectus benchmark is inconsistent with a strategy of investing in developing markets, emerging markets and the Asia-Pacific region. The listing of funds has been compiled by focusing strictly on funds that employ company-specific positive ESG selection criteria that may be combined with company engagement and active proxy voting practices rather than funds that have implemented broad-based negative screens in assessing ESG practices. The list therefore is more restricted as it also excludes faith-based funds, or funds that screen and exclude investments based largely on one or more exclusionary practices. Further, the list does not include ETFs that may offer concerned investors yet another option.

Table 1: ESG Funds with Global Investment Mandates, Including Developing Markets, Emerging Markets and Asia-Pacific Region (Listed in Alphabetical Order within Fund Type)

In a future article, these funds will be more formally evaluated along with ETF options. In the meantime, investors should be cautioned that, as is the case before investing in funds more generally, due diligence should be conducted to ensure that, at minimum, these funds satisfy basic requirements, including qualifications and skills to combine financial and sustainability characteristics, a demonstrated, established and consistent performance track record over time, and properly sized for scale and liquidity and effectively priced fund offerings. In any case, investors have to be clear about their sustainability objectives to ensure that these are properly aligned with their portfolio profiles.  

[1] The Vanguard FTSE Social Index Fund.

[2] ETFs offer investors another option and this will be covered in a subsequent article.

[3] Executive Order 13400 as of April 26, 2006, as reported in the Federal Register, Vol. 71, No. 83.

[4] Both PGC and PGB are constituent member companies of the index as of 10/31/2017.

[5] Fund holdings are posted on Vanguard’s website along with fund prospectuses.