{"id":23718,"date":"2025-12-09T13:42:00","date_gmt":"2025-12-09T12:42:00","guid":{"rendered":"https:\/\/www.labrador-transparency.com\/?p=23718"},"modified":"2026-06-05T05:35:10","modified_gmt":"2026-06-05T04:35:10","slug":"esg-disclosures","status":"publish","type":"post","link":"https:\/\/www.labrador-transparency.com\/en\/blog\/esg-disclosures\/","title":{"rendered":"ESG Disclosures"},"content":{"rendered":"\t\t
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Companies are also reviewing the ESG content in their proxy statements<\/strong> since those compliance documents have increasingly included a description of a company\u2019s ESG priorities and accomplishments. Consequently, the 2025 proxy season provides a unique glimpse into how companies are navigating the evolving landscape.<\/p>

This Thought Piece explores some of the approaches taken and considerations for companies to consider as they prepare for the next annual meeting season. <\/em><\/p>

Note that practices and disclosures related to human capital management, especially diversity, equity and inclusion (DEI), received the most attention and are not the subject of this Thought Piece. For preliminary observations on how companies pivoted with their DEI disclosures in 2025, see the Labrador Thought Piece on DEI here<\/a>. <\/em><\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t

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  1. The terms ESG and sustainability are used interchangeably throughout this Thought Piece. Note, though, that there has been a general trend of moving away from ESG terminology.<\/li><\/ol>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t
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    State of Play Before the 2025 Proxy Season<\/h2>\t\t\t\t<\/div>\n\t\t\t\t
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    Disclosures about corporate sustainability topics, and Board oversight of related risks and opportunities in proxy statements increased as companies expanded their definition of performance and value creation for a broader group of stakeholders.<\/strong><\/p>

    This was in part driven by investor voting practices<\/strong> as they expressed a willingness to vote against directors and\/or support sustainability-related proposals if they found disclosures lacking. In addition to including a Board oversight section<\/strong>, which describes how sustainability-related oversight responsibilities are allocated, many companies included select ESG highlights<\/strong> from the preceding year. They often also included an express commitment to transparency<\/strong>, highlighting the company\u2019s current reporting practices and naming any recognized frameworks that<\/strong> the company reports in accordance with or is working toward.<\/p>

    Based on Labrador\u2019s recent benchmark of 115 proxy statements, approximately 50% of companies included a sustainability\/ESG highlights section in their 2025 proxy statement.<\/strong> Discussion of a company\u2019s material sustainability-related topics allowed shareholders to evaluate whether these considerations were appropriately integrated into key processes and decisions.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t

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    \n\t\t\t\t\t\tincludes an ESG highlights\/summary section\t\t\t\t\t<\/p>\n\t\t\t\t\n\t\t\t<\/div>\n\t\t\t\n\t\t<\/div>\n\t\t\t\t\t\t<\/div>\n\t\t\t\t

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    \n\t\t\t\t\t\tincludes an overview of ESG focus areas\/prioritized topics\t\t\t\t\t<\/p>\n\t\t\t\t\n\t\t\t<\/div>\n\t\t\t\n\t\t<\/div>\n\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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    What Investors Want Now<\/h2>\t\t\t\t<\/div>\n\t\t\t\t
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    ESG in institutional investors\u2019 voting guidelines<\/h3>\t\t\t\t<\/div>\n\t\t\t\t
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    Even with the increased scrutiny of a corporation\u2019s role in environmental and social matters, recent surveys show that investors are still focused on the ESG issues that have clear financial implications, like climate risk, human capital and cybersecurity2<\/sup><\/strong>. Likewise, the EY Center for Board Matters found that climate change and environmental stewardship is still a top three priority for investors3<\/sup>. The 2025 proxy voting guidelines for three of the largest institutional investors expressly seek disclosures related to these topics.<\/strong><\/p>

    Excerpts from the 2025 proxy voting guidelines of the three largest institutional investors:<\/strong><\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t

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    BlackRock<\/strong><\/p>

    Proxy voting guidelines for Benchmark Policies \u2013 U.S. securities<\/p>

    Effective January 20254<\/sup><\/p>

    We find it helpful when companies\u2019 disclosures demonstrate that they have a resilient business model that integrates material sustainability-related risks<\/strong> and opportunities into their strategy, risk management, and metrics and targets.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t

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    [W]e encourage [companies] to produce sustainability-related disclosures sufficiently in advance of their annual meeting<\/strong>, to the best of their abilities to provide investors with the time to assess the data and make informed decisions.<\/p>

    In our experience, disclosure consistent with the ISSB standards or the TCFD framework can help investors assess company-specific climate-related risks and opportunities and inform investment decisions.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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    State Street<\/strong><\/p>

    Global Proxy Voting and Engagement Policy<\/p>

    Effective March 20255<\/sup><\/p>

    We look to companies to provide disclosure on sustainability-related risks and opportunities relevant to their businesses<\/strong> in line with applicable local regulatory requirements and any voluntary standards and frameworks adopted by the company.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t

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    We believe that managing climate-related risks and opportunities is a key element<\/strong> in maximizing long-term risk-adjusted returns for our clients.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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    Vanguard<\/strong><\/p>

    Proxy voting policy for U.S. portfolio companies<\/p>

    Effective February 20256<\/sup><\/p>

    [A] company\u2019s board has responsibility for providing effective oversight of strategy and risk management. This oversight includes material sector- and company-specific sustainability risks and opportunities<\/strong> that have the potential to affect long-term shareholder returns.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t

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    [W]e believe that a company\u2019s fulsome disclosure of material risks to its long-term shareholder returns<\/strong> is beneficial to the public markets to inform the company\u2019s valuation.<\/p>

    [T]o assess a climate risk oversight failure<\/strong>, factors for the funds to consider include: the materiality of the risk as identified by the company; the effectiveness of disclosures to enable the market to understand and price the risk; whether the company has disclosed plans to mitigate material risks in the context of regulatory requirements and consideration for company-specific context, market regulations, and market practices.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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    1. Global Institutional Investor Survey 2024 Report<\/span><\/a><\/p><\/li>

    2. No-Regret Moves for Boards in a Turbulent Proxy Season<\/span><\/a><\/p><\/li>

    3. BlackRock Investment Stewardship<\/span><\/a><\/p><\/li>

    4. Global Proxy Voting and Engagement Policy<\/a><\/p><\/li>

    5. Proxy voting policy for U.S. portfolio companies<\/a><\/p><\/li><\/ol>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t

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      ESG in shareholders\u2019 proposals<\/h3>\t\t\t\t<\/div>\n\t\t\t\t
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      In addition to institutional investor voting guidelines, it is also important to look at the shareholder proposal landscape in 2025.<\/p>

      In Georgeson\u2019s annual publication titled \u201cAn Early Look at the 2025 Proxy Season,\u201d<\/a> a few shareholder proposal trends are noted. The publication covered proxy voting results from Russell 3000 companies that had annual general meetings between July 1, 2024, and May 16, 2025.<\/p>

      Some of the trends noted by Georgeson included:<\/p>