2026 Q3 Advocacy Impact Report

This quarter, Trillium advanced shareholder engagements on labor relations, workforce disclosure, and worker safety; encouraged portfolio companies to support voting rights and workplace inclusion; and joined policy letters on climate resilience, employment data, and surveillance pricing. Across this work, our approach remained consistent: we ground each engagement in careful research, credible data, and a clear view of the risks at stake, and we stay true to the values that have guided Trillium for four decades. We believe fair treatment of workers, strong democratic institutions, and transparent disclosure are matters of principle and also foundations of long-term value creation. As we head into the fall, the research and conversations that we have been conducting over the past months will be put into action.

Protecting Workers from Heat Injury and Illness

In July, Trillium proudly partnered with the Natural Resources Defense Council (NRDC) to publish Rising Temperatures, Rising Risks: An Investor Guide to Heat Hazards and Worker Safety. As climate change drives more frequent and intense heat events, millions of workers (an estimated 70% of the global workforce) are increasingly exposed to dangerous conditions that can lead to heat exhaustion, heat stroke, injury, illness, and even death. While heat risks are often associated with outdoor work, workers in warehouses, factories, kitchens, and other indoor environments can also face significant exposure. The report highlights why occupational heat is both a worker safety issue and a growing business risk, with implications for productivity, workforce stability, operations, and long-term shareholder value.

The guide is designed to help investors better understand and evaluate how companies are managing this emerging challenge. Drawing on research from labor, public health, and business experts, it provides a practical framework for assessing company oversight, worker protections, heat-risk management practices, supply-chain expectations, and public disclosure. The report also highlights the growing evidence that proactive investments in worker safety can help companies reduce injuries, strengthen resilience, and better navigate the physical impacts of a warming climate. 

Following the report's release, Trillium started outreach to a range of portfolio companies whose workers or supply chains may face elevated heat exposure. Our engagements focused on understanding how companies assess heat-related risks, what safeguards they have in place to protect workers, how they address heat risks in their supply chains, and whether senior leaders and boards are overseeing these issues. By encouraging companies to identify and address heat hazards before workers are harmed, we seek to advance both worker well-being and long-term business resilience.

Heat is no longer only an outdoor hazard or a distant climate scenario. It's a daily reality for workers in fields, warehouses, factories, and kitchens, and a growing business risk for the companies that employ them.

Democracy

Ahead of the November 2026 midterm elections, we wrote this summer to approximately thirty portfolio companies with headquarters or operations in key states. We shared our perspective on corporate support for democracy and voting rights, one of Trillium's core values, and encouraged the companies to deepen their commitments. The midterms will shape policy at every level of government; practices adopted now can be tested and made visible to employees and customers before the 2028 general election cycle begins in earnest. Our letters acknowledged work already underway while arguing that two consequential election cycles warrant additional effort.

We framed this as a business concern and a matter of Trillium’s values. Robust democratic institutions maintain the rule of law, uphold contractual obligations, and nurture competitive fairness, which are the pillars of a well-functioning economy. Drawing on the framework we built in 2024, we asked companies to adopt paid time off to vote, cease partisan 527 contributions and move toward no political spending, support voter registration legislation, and share voter information with their stakeholders.

Supporting democracy and voting rights is one of Trillium's core values. With two major election cycles ahead, we're asking companies to build on the work they've already started.

Starbucks – Labor Relations

Over the summer, the New York State Common Retirement Fund, the New York City Comptroller, and Trillium filed a shareholder proposal at Starbucks Corporation asking the Board to re-establish the Environmental, Partner, and Community Impact Committee, a standing committee of independent directors created in November 2023 whose first listed responsibility was to oversee policies and practices related to labor relations.

In November 2025, the Board dissolved that committee, spread its duties across other committees, and returned primary responsibility for labor matters to the full Board, chaired by Chairman and CEO Brian Niccol. As we explained in the proposal, that shift, coupled with a combined CEO-Chair role, risks diluting the depth, continuity, and independence of oversight in one of the Company's most persistent risk areas – labor rights. Starbucks' 2025 Annual Report calls labor relations a material risk to operations, sales, reputation, and brand. And since 2021, baristas at roughly 700 stores have voted to unionize without a finalized contract, nearly 600 unfair labor practice charges remain open, and lawmakers and United Nations human rights experts have raised concerns.

Racial & Gender Equity – EEO-1 Rulemaking Comment Letter to the Equal Employment Opportunity Commission (EEOC)

In August, Trillium submitted a public comment letter urging the EEOC to preserve EEO-1 reporting and related federal employment data collection requirements, which the agency has proposed to rescind. The proposed rescission of these rules is troubling – for 60 years, they have enabled the EEOC to protect American workers from discrimination. The EEO-1 report has additionally supported investor understanding of a company’s workforce and talent management strategy. 

Trillium has sought improved workforce disclosure from portfolio companies since 1999, when we filed our first shareholder proposal at The Home Depot, Inc. on equal employment data. What makes the EEO-1 valuable is its standardization: it is the most widely available standardized human capital dataset in the market, enabling consistent, replicable, and comparable analysis across a company's own history, its peer set, and the broader market. Paired with narrative corporate reporting on policies and programs, it gives us a two-pronged way to test whether a company's stated inclusion strategy is actually working.

We believe rescission would be economically counterproductive, not just inconvenient for investors. Discrimination functions as a market failure: it prevents labor from being allocated to its highest and best use and creates costs borne by workers, communities, taxpayers, and investors. Federal Reserve research estimates that closing race and gender labor-market gaps would have added trillions of dollars to U.S. output. For diversified long-term investors, those costs are systemic and cannot be diversified away. 

Since our founding, Trillium has stood for equal opportunity regardless of race, color, religion, sex, national origin, disability, or age, and we oppose the rollback of a long-standing civil rights mandate. 

Discrimination is a market failure. It keeps talent from its best use and creates costs that long-term, diversified investors can't diversify away. Keeping EEO-1 reporting in place is good economics as well as a civil rights commitment.

Workforce Data Disclosures – Tetra Tech, Inc. 

In September, Trillium filed a shareholder proposal at Tetra Tech, Inc. asking the company to report publicly on the efficacy of its equal opportunity efforts and workforce management strategy. The proposal suggests EEO-1 or equivalent workforce data, recruitment, retention, and promotion rates, and pay gap analyses – all important in the mosaic necessary to understand a company’s inclusion strategy. Tetra Tech employs more than 25,000 people but the company’s human capital disclosures are currently limited to aggregated figures. We believe this is insufficient for investors to judge whether the company is producing consistent recruitment, advancement, and compensation outcomes, or how it is performing over time.

Employee sentiment data adds a reason to look more closely: on Glassdoor, women rated their experience at Tetra Tech 16% lower than men, and employees with disabilities rated their experience 14% lower than employees without disabilities. For Trillium, this is where the values and the business case converge. We believe workers deserve fair and equal treatment, and we also believe the ability to measure workforce outcomes is material to valuation — a review of EEO-1 data from 1,482 companies between 2016 and 2024 found manager diversity was positively and significantly associated with after-tax income, five- and ten-year revenue growth, return on equity, return on invested capital, free cash flow per share, and share price appreciation.

LGBTQ+ Inclusion – Corporate Equality Index Participation 

Trillium wrote to thirteen portfolio companies in August including nVent Electric plc; The Progressive Corporation; Trane Technologies plc; Palo Alto Networks, Inc.; The New York Times Company; Netflix, Inc.; McCormick & Company, Incorporated; IQVIA Holdings Inc.; International Flavors & Fragrances Inc.; Eli Lilly and Company; Aflac Incorporated; AstraZeneca PLC; and AutoZone, Inc., encouraging them to participate in the Human Rights Campaign's Corporate Equality Index (CEI) for 2027. We have long used the CEI to benchmark portfolio companies on LGBTQ+ workplace inclusion, and we believe the survey serves two audiences at once. One, it gives companies a consistent disclosure framework, actionable insight, and technical support as they refine their inclusion practices. The CEI also gives investors a comparable measure of inclusion policies and practices. Amid the broader DEI backlash, CEI participation among Fortune 500 companies fell 65 percent this year. Therefore, we believe it is important to encourage companies to either participate again or begin reporting for the first time.

Strength in Numbers

Trillium believes in the importance of standing alongside other organizations by lending its name to joint letters and collaborative efforts. Achieving meaningful change often requires a chorus of voices that demonstrate both breadth and depth of investor support. This quarter, we signed on as signatories to letters engaging companies, local legislators, and federal regulators:

Massachusetts Environmental Policy

Trillium supported two letters by the Environmental League of Massachusetts to the Massachusetts Legislature's Conference Committee, which highlighted important aspects of state-level climate policy. One voiced support for the MassSave program, encouraging cost-effective clean energy, and advocating on behalf of ratepayers. The other promoted policy centered on environmental resilience in Massachusetts communities, in the face of climate, drought, and air quality challenges.

Workforce Diversity Data

Trillium amplified our efforts on collecting and reporting Workforce Diversity Data through a sign-on letter from the Interfaith Center for Corporate Responsibility (ICCR). This ICCR letter explains to companies the importance of the EEO-1 reporting requirement, which is under threat from the current administration's Equal Employment Opportunity Commission (EEOC).

Surveillance Pricing

We signed onto OpenMIC's comment letter to the Federal Trade Commission (FTC) opposing personalized pricing, also described as surveillance pricing. The letter argues that setting individual prices using personalized data raises concerns about transparency, higher prices, competition, and the collection of highly individualized data. It recommends using the term 'surveillance pricing,' withdrawing the proposed FTC rule, prohibiting the mechanism underlying the practice, and requiring substantiation of prices.

About Trillium Asset Management

Trillium Asset Management offers investment strategies and services that advance humankind towards a global sustainable economy, a just society, and a better world. For over 40 years, the firm has been at the forefront of ESG thought leadership and draws from decades of experience focused exclusively on responsible investing. Trillium uses a holistic, fully integrated fundamental investment process to uncover compelling long-term investment opportunities. Devoted to aligning stakeholders’ values and objectives, Trillium combines impactful investment solutions with active ownership. The firm delivers equity, fixed income, and alternative investments to institutions, intermediaries, high net worth individuals, and other charitable and non-profit organizations with the goal to provide positive impact, long-term value, and 'social dividends.'

Important Information: The views and opinions above are as of March 2026 and are subject to change. There is no assurance that impact or investment objectives will be achieved. This is not a recommendation to buy or sell any of the securities mentioned. It should not be assumed that investments in such securities have been or will be profitable. The specific securities were selected on an objective basis and do not represent all of the securities held purchased, sold or recommended for advisory clients.

For marketing and information purposes. For global professional / qualified / accredited / institutional clients and investors.