Investor Statement on Corporate Neutrality, Governance, and Long-Term Shareholder ValueWe are investors, investment advisors, fiduciaries, and proxy voting and corporate engagement professionals whose clients and constituents collectively account for more than $XYZ billion in assets under management. We are committed to promoting sound corporate governance and long-term shareholder value. We believe companies perform best when they focus on delivering excellent products and services, treat employees fairly under the law, and maintain a posture of neutrality on contested social and political issues.
In late 2024, our coalition issued an investor letter to Fortune 1000 companies addressing risks associated with Diversity, Equity, and Inclusion (DEI) programs and alignment with external advocacy scoring systems. We encouraged boards and management teams to evaluate whether such frameworks advance durable shareholder value or introduce legal, reputational, and operational risk.
Since that time, the landscape has shifted meaningfully.
Recent analysis of SEC filings shows the majority of S&P 500 companies have revised or removed DEI-related disclosures, and corporate participation in external advocacy scoring frameworks is likewise declining, including an approximate
65 percent drop in Fortune 500 participation in the Corporate Equality Index. Furthermore, the HRC, who reports on the index,
has lost 38% of its corporate sponsors over the last year Federal enforcement activity has also intensified scrutiny of workplace practices tied to identity-based programs. The Equal Employment Opportunity Commission (EEOC) recently filed a sex discrimination
lawsuit against a Coca-Cola bottling company and a subpoena
enforcement action against Nike related to diversity initiatives. And the Department of Justice’s Office of Legal Counsel has issued an opinion largely backing EEOC’s interpretations and applications of Title VII's disparate impact provisions.
Continued Governance Review Is Warranted While these developments are encouraging and reflect a broader return toward corporate neutrality, further progress is needed. A meaningful number of public companies remain closely aligned with external advocacy frameworks, underscoring the importance of continued transparency and engagement. To support this effort, our coalition has assembled The Corporate Activism 240+, a dataset identifying publicly traded companies that currently maintain a verified score of 100 on the Corporate Equality Index.
A CEI score of 100 is not merely symbolic. It indicates that a company has adopted policies and external affiliations aligned with the framework’s criteria, internal programming and training structures, benefit design decisions, and public support of related advocacy initiatives. In practice, achieving a top score often entails endorsing or institutionalizing controversial and highly politicized positions on contested social issues, creating material legal, reputational, and operational risks, including potential customer backlash, that may ultimately erode shareholder value and warrant thorough board review.
Companies are increasingly recognizing the risks associated with sponsoring the Human Rights Campaign (HRC), as the organization’s advocacy and political activity create potential reputational and stakeholder concerns. Because
HRC engages in lobbying, electoral advocacy, and policy campaigns on contested social issues, corporate sponsorship can be perceived by stakeholders as alignment with particular political or ideological positions. At the same time,
HRC’s involvement in highly contested policy debates, such as transgender healthcare and sports participation, has drawn activist pressure, media scrutiny, and shareholder criticism, prompting some companies to reconsider their affiliation.
Healthcare benefits design is one area where the legal and policy landscape continues to evolve. The
American Society of Plastic Surgeons has recommended delaying gender-related surgeries for minors, citing insufficient long-term evidence regarding risks and benefits. And reporting on the
American Medical Association similarly notes that evidence for surgical interventions in minors remains limited and emphasizes clinical judgment and evidence-based standards.
In addition,
a coalition of 20 state attorneys general recently sent a letter to the American Medical Association raising concerns about the scientific evidence, long-term outcomes, and policy implications associated with pediatric gender-transition interventions. The correspondence reflects ongoing legal and regulatory scrutiny of medical guidance in this area and underscores the importance of careful governance oversight by corporate boards and management teams.
These developments increase the importance of rigorous board oversight, comprehensive risk assessment, and transparency regarding healthcare benefit policies in an area subject to rapidly evolving medical evidence, regulatory scrutiny, and legal uncertainty.
Shareholders are Demanding Transparency Shareholder scrutiny of these issues has also increased significantly during the 2025-2026 proxy season. De-transitioners including
Soren Aldaco,
Chloe Cole, and Camille Kiefel presented testimony at annual meetings of companies including American Express, Home Depot, IBM, and Merck. Their presentations highlighted concerns regarding informed consent, long-term health outcomes, and the irreversible nature of certain medical interventions performed on minors. The emergence of these voices in shareholder forums reflects growing investor interest in the legal, reputational, medical, and governance risks associated with corporate healthcare benefit policies in this area.
Some companies have already begun adopting more cautious approaches. For example, Walmart, the largest employer in the US, includes a clear carve-out prohibiting health plan administrators from providing transgender medical interventions to minors in its
Associate Benefits Guide. While companies may reach different conclusions regarding benefit design, Walmart's policy demonstrates that it is possible to maintain competitive employee benefits while limiting exposure to an area of growing medical, legal, and public controversy.
These concerns are occurring alongside a rapidly evolving statutory landscape. As of 2026, more than two dozen states have enacted laws restricting or prohibiting gender-related surgeries for minors, reflecting significant legal divergence across jurisdictions and increasing compliance complexity for multi-state employers. This patchwork regulatory environment, combined with growing shareholder scrutiny and public testimony from de-transitioners during the 2026 proxy season, further underscores the importance of careful legal review and board oversight of healthcare benefit policies.
Call to Action
In light of these developments, we urge companies to take the following actions:
• End participation in external advocacy surveys such as the Corporate Equality Index
• Review and discontinue sponsorships or affiliations with advocacy organizations that are not aligned with a posture of corporate neutrality
• Conduct a comprehensive review of employee healthcare plans to assess legal and regulatory exposure and, at a minimum, adopt a clear carve out on coverage of gender-related interventions for minors
• Adopt a clear posture of neutrality on contested social and political issues
Our coalition remains committed to constructive engagement with boards and management teams. We welcome dialogue with companies seeking to address these issues. Companies that remain closely aligned with external advocacy frameworks should expect continued shareholder scrutiny, including engagement, proxy voting initiatives, and shareholder proposals where appropriate. We believe companies create the greatest long-term value when they focus on business performance, respect diverse viewpoints among stakeholders, and maintain neutrality on contested social and political issues.
Companies may contact Tim Schwarzenberger, CFA, at
engagement@inspireinvesting.com.
