1Q 2026 Impact by the numbers
American Water Works, recognized as the United States’ largest private water utility, has taken meaningful steps toward advancing environmental justice following several years of sustained engagement with Trillium focused on racial equity. In March 2024, American Water committed to a comprehensive assessment of its policies, practices, products, and services, specifically designed to examine the company’s operations through an environmental justice lens. Over the course of 2024 and 2025, the company selected an independent assessor and diligently completed the evaluation process. In early 2026, Trillium met with both the assessor and American Water leadership to review the assessment findings and discuss potential next steps. Particular attention was given to how the recent merger with Essential Utilities might influence the implementation of recommended changes.
In a February 2026 meeting, American Water acknowledged Trillium for its positive impact on sustainability and governance, attributing several improvements to Trillium’s engagement. The company confirmed it is actively considering the recommendations put forth by the assessment and has begun exploring ways to integrate these insights across the newly merged entity. As American Water transitions to executing these recommendations, Trillium will continue to closely monitor progress, ensuring that environmental justice remains a central focus throughout the integration and operational changes.
Over the past four months, Trillium intensified its engagement with Starbucks in response to growing concerns about labor relations oversight, stalled collective bargaining, and governance backsliding at the board level. In January 2026, Trillium joined other long-term investors in directly challenging Starbucks’ board after the quiet
dissolution of the Environmental, Partner, and Community Impact (EPCI) Committee, which had been established to oversee labor relations. Trillium coauthored and sent a letter to Lead Independent Director Jørgen Vig Knudstorp and Nominating and Corporate Governance Committee Chair Beth Ford, raising concerns about the lack of transparency around the Committee’s elimination and the reassignment of its responsibilities amid ongoing labor conflict.
In February 2026, we took additional steps by publicly initiating a “vote no” campaign against Directors Knudstorp and Ford. Alongside the NYC and NYS Comptrollers and other investors, Trillium issued a shareholder letter urging investors to oppose their reelection due to sustained labor oversight failures, renewed labor unrest, and the board’s retreat from independent Committee level oversight. This action generated significant media attention and placed labor governance squarely before shareholders ahead of the annual meeting.
In March 2026, Trillium continued direct engagement with the company and the board. Investors met with Starbucks leadership, including the Lead Independent Director. We are pleased that following the investor attention paid to how the company was approaching the collective bargaining process that the company and the union agreed to return the bargaining table.
Climate-driven events like droughts and storms are impacting agricultural supply chains, giving food retailers such as BJ’s Wholesale Club (BJ’s) a key role in reducing greenhouse gas (GHG) emissions. Retailers can help by sourcing renewable energy, improving energy efficiency, and preventing refrigerant leaks.
In 2021, Trillium urged BJ’s to set ambitious emissions goals. BJ’s agreed and in 2022 committed to the gold standard – a science-based emissions reduction target – but later withdrew its commitment. After BJ’s moved away from climate-focused practices reneging on its commitment, Trillium filed another proposal calling for decisive GHG reduction plans, which received strong shareholder support (30.4%) in 2025. However, BJ’s continues not to act, so Trillium refiled the proposal for 2026 and continues to push for credible climate action ahead of the company’s annual meeting in June.
In November 2025, under Chair Paul Atkins, the SEC announced a policy that substantially shifted power from shareholders to corporations. For companies seeking to exclude shareholder proposals during the 2025-2026 proxy season, the SEC indicated they would not substantively review most no-action requests, instead deferring to the companies.
This shift materially weakened the procedural protections that shareholders have historically relied on. While most companies have continued to include shareholder proposals that meet the requirements set forth under Rule 14a-8, the lack of a procedural path to challenging corporate exclusions has required shareholders to utilize other legal and strategic approaches to preserve their right to access the proxy ballot. While these alternative paths can be costly and time intensive, it is important for shareholders with the resources and ability to pursue them to explore new or underutilized paths to preserve shareholder rights.
In March, Trillium’s advocacy team employed an innovative path to a successful negotiation with BJ’s following their request for a no-objection letter from the SEC on our GHG emissions proposal. We are proud to join other committed shareholders in the exploration of multiple paths to protect our rights as shareholders. Earlier this year, BJ’s asked the SEC staff for a no-objection letter to omit the proposal pursuant to the vacuum created by the SEC’s withdrawal from its role as referee on Rule 14a-8 shareholder proposals. Trillium responded promptly and engaged the company directly to seek a practical solution that protects shareholder rights. After dialogue with BJ’s , the company has agreed to include Trillium’s GHG emissions shareholder proposal in its 2026 proxy materials.
In those discussions, Trillium outlined a clear path forward under SEC proxy solicitation rules and BJ’s bylaws: if the company continued towards omission, Trillium would submit shareholder proposals under the pathway provided for in the company’s bylaws and solicit proxies in support of those items. Those proposals would have included a GHG emissions proposal and, importantly, additional good corporate governance shareholder proposals. Trillium’s objective throughout was straightforward - ensuring shareholders had the opportunity to consider, at least, Trillium’s GHG emissions proposal on the company’s proxy.
Following further engagement, Trillium and BJ’s reached an agreement: BJ’s will include the Trillium shareholder proposal in its 2026 proxy materials, and the engagement would proceed in the well-established Rule 14a-8 process.
Why this matters:
Trillium continued climate-related engagement with both NextEra Energy (NextEra) and Alphabet in the first quarter of 2026. NextEra is a major developer of wind and solar and, through Florida Power & Light, has expanded renewables and battery storage while retiring its last coal plant in 2020. However, the company recently dropped its zero emissions by 2045 target and has indicated interest in developing new natural gas generation, including to serve growing data center demand. In response, Trillium filed a shareholder proposal in late 2025 requesting that NextEra assess pathways to re-establish an ambitious emissions reduction target; shareholders are expected to vote at the company’s annual meeting in late May 2026.
Alphabet, on the other hand, is among the big tech firms driving electricity demand by building enormous or “hyperscale” data centers to support its growing artificial intelligence business. Trillium has previously engaged the company on responsible growth and the environmental impacts associated with AI-related expansion, alongside ongoing concerns about data governance and consumer protections. Across both engagements, our work in Q1 focused on maintaining dialogue, advancing investor expectations, and doing the significant work of preparing for upcoming proxy votes by encouraging other investors to support these two shareholder proposals.
Trillium continues to believe that racial and gender equity are not only fundamental values but also long-term drivers of business performance, helping to foster innovation, resilience, and a positive workplace culture. In line with this conviction, we are actively engaging our portfolio companies on issues related to workplace fairness and inclusion, striving to ensure that organizations are creating environments where all employees
can thrive. Although we have observed an uptick in overall workforce diversity reporting in recent years, there remains a notable gap: some companies, including Tetra Tech, have yet to release meaningful disclosures about the composition of their workforces or the effectiveness of their inclusion efforts. This lack of transparency can hinder both accountability and progress toward equity goals. In response, this quarter we reached out to Tetra Tech to initiate a conversation about similar topics, encouraging them to enhance their reporting and take proactive steps toward greater workplace equity and transparency. We believe that such engagement supports stronger governance, reduces reputational risk, and positions these companies for long-term success in a diverse and rapidly evolving marketplace.
Trillium understands that a sustainable economy must protect human health and advance equity, which is why we engage beauty companies on chemical safety. Our work is grounded in environmental justice, recognizing that harmful exposures often disproportionately affect women of color. Hair straighteners marketed to Black women highlight this risk: research links certain formulations to elevated cancer rates, yet transparency remains limited. L’Oréal’s responses to investors emphasize legal exposure over proactive, hazard-based management, and current disclosures offer little insight into how chemical safety shapes product development. As a global cosmetics leader, L’Oréal could strengthen trust and reduce litigation risk by adopting independent screening frameworks and fully disclosing substances of concern.
Our January 2026 dialogue aimed to encourage L’Oréal to take a more forward-looking, hazard-based approach and improve transparency around chemicals of concern. While the company maintains sophisticated risk-based systems, it continues to resist broader hazard-based frameworks increasingly used by peers. We noted that L’Oréal does not publish a unified chemicals policy and discloses phaseouts only after completion – such as PFAS, which it phased out in 2024 – making progress hard to assess. Although it applies hazard criteria for environmental impacts, the company lacks a clear health-focused hazard scale and time-bound commitments for phasing out substances of very high concern. Despite strong internal technical capacity, L’Oréal raised concerns about setting group-wide targets across its brands. Going forward, we will encourage the company to expand disclosure, meet with ChemFORWARD (a science-based, non-profit organization focused on advancing safer chemicals through global supply-chain collaboration), and publish time-bound phaseout goals for substances of very high concern aligned with best practice and investor expectations.
Trillium is engaging Target on Diversity, Equity, and Inclusion (DEI) and immigration because we believe the company’s recent retreat from prior racial equity and inclusion commitments—alongside its inconsistent stance on LGBTQ+ issues – presents significant reputational, operational, and financial risks at a time when Target is struggling with declining sales, customer traffic, and brand trust, as documented by investors and media reports. Trillium’s values, rooted in advancing human rights, equity, and the fair treatment of all people across our economy and society call on us to encourage companies to uphold and not abandon these principles, especially when vulnerable communities are at risk. We have been particularly concerned that Target did not directly address the dangers posed by aggressive ICE enforcement in Minneapolis, despite the clear potential for long-term harm to employees, customers, and community trust, and the heightened reputational risk this poses even if enforcement activity later subsides.
In our past engagements, including a defending-ESG letter that raised DEI concerns, as well as discussions during ongoing dialogues on chemicals and pesticides, we expressed strong dissatisfaction with Target’s backtracking, especially as peer investors reported that the company had been defensive and inflexible in related conversations. With a new CEO starting in February 2026, we saw a critical opportunity to reengage Target on reinstating DEI commitments, addressing immigration-related risks in Minnesota, and strengthening governance of values-based risks. Recognizing the need for stronger accountability, Trillium co-led an investor letter, with over $150 billion in assets represented by the signatories to the letter, with Mercy Investment Services, which received national coverage in Reuters and underscored widespread investor concern about Target’s escalating reputational exposure.
Many day laborers wait in Home Depot parking lots seeking employment, and in the past year, these parking lots have been frequent U.S. Immigration & Customs Enforcement (ICE) raid sites. In November, Trillium filed a shareholder proposal at Home Depot with other ICCR members requesting a report assessing risks to customers’ data privacy rights, prompted by concerns about the company’s use of Automatic License Plate
Reader technology that has been linked to data abuse, including by ICE. We have held two meetings with Home Depot in 2026 to better understand the company’s technology policies and governance mechanisms and to advocate for better safeguards.
We continue to engage Apple on App Store governance and human rights concerns following Apple’s removal of the “ICEBlock” application, which allowed users to report sightings of ICE agents. Trillium’s engagement builds on earlier correspondence with Apple dating back to 2009 and 2011 and focuses on transparency, freedom of expression, and the company’s interactions with government authorities.
Beginning in October 2025, Trillium wrote to Apple’s corporate secretary seeking clarification on the grounds for the app’s removal, the role of law enforcement input, and how Apple evaluates politically sensitive content. As public scrutiny intensified – including coverage by major media outlets, advocacy by civil liberties organizations, and inquiries from members of Congress – Trillium urged Apple to take a more transparent and principled stance. In December 2025 and January 2026, Trillium encouraged Apple to emphasize protections for freedom of expression and privacy in its response to a House Committee on Homeland Security inquiry and to disclose more information about the circumstances surrounding ICEBlock’s removal.
In March 2026, Trillium again pressed Apple to publicly release its response to and provide clearer disclosure of its interactions with the U.S. government. We framed these requests as necessary for investors to assess alignment with Apple’s stated human rights commitments and its responsibilities as a steward of digital civic space.
Like many, we witnessed Immigration and Customs Enforcement’s (ICE) operations in Minnesota with deep concern. Corporate relationships with government agencies— particularly those associated with contentious enforcement practices—can expose companies to reputational, operational, and stakeholder-related risks. In Ecolab’s case, its contractual relationship with ICE to supply cleaning supplies carried heightened scrutiny due to escalating public concern and intensified federal detention activity, especially as a company headquartered in Minnesota. These conditions increased the potential for negative brand association, employee-relations challenges, and consumer backlash.
We wrote a letter to Ecolab in late January 2026 urging the company not to renew its contract with ICE when it expires and to carefully assess the reputational and stakeholder risks associated with continuing or entering similar agreements. We emphasized that while Ecolab’s products play an important sanitation role in ICE facilities, any association with ICE’s detention operations now carries heightened visibility and potential harm to the company’s civic reputation in Minnesota. We asked Ecolab to disclose its rationale should it pursue future ICE contracts, including how such decisions align with its stated values, how the company evaluates reputational and stakeholder risks, and how government contracts contribute to long-term shareholder value given their lower margins and added complexity.
In June 2025, Trillium reached out to several retailers and restaurants, including Chipotle, to encourage a move away from phenol-based receipt coatings. Although bisphenol-A (BPA) was phased out of thermal receipt paper due to its endocrine- disrupting effects, bisphenol-S (BPS) became a common substitute despite evidence of similar harms. We urged retailers and restaurants to phase out BPS in receipts, adopt safer alternatives, and protect workers in the interim. We also highlighted leadership from TJ Maxx and Burlington Stores, who several years ago committed to phenol-free receipts thanks to engagement efforts led by Trillium.
Chipotle responded to our outreach, saying they have identified suppliers that can provide phenol-free receipts and that they are in the process of transitioning to phenol- free receipts in all US restaurants. Over 25% of their restaurants were already using phenol-free receipts in October 2025 and their goal was to fully transition by the end of 2025. They were also testing “by request only” receipt options. We congratulated the company and subsequently had a dialogue in January 2026, discussing both BPS phaseout and Chipotle’s approach to pesticide reduction. Although Chipotle is a leader when it comes to whole-ingredient, healthier quick service food options, it does not have a pesticide reduction goal. Synthetic pesticides are linked to serious health harms, including cancers and developmental defects, and they contribute to pollinator decline and soil degradation, undermining regenerative agriculture goals. We believe that Chipotle has an opportunity to align its pesticide management practices with its brand image by encouraging suppliers to adopt regenerative practices and reduce pesticide use. Chipotle shared that they are beginning to assess their biodiversity-related impacts, and we will continue to monitor the company’s progress.
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. Accordingly, Trillium routinely engages in initiatives led by other organizations to help strengthen and amplify shared messages.
Digital Platforms
Trillium has a long-standing history of commitment to safe and healthy workplaces. “Digital platform work” is the human labor that undergirds online corporate services – from digital content moderation to physical delivery services. This type of labor constitutes a growing and relatively unregulated sector. In advance of an upcoming meeting of the International Labor Organization, we signed onto an Interfaith Center for Corporate Responsibility letter in support of passing the proposed binding International Labor Organization Convention to protect Platform Workers from unregulated and abusive working conditions.
Trans Rights
We signed onto Adasina's "Investor Statement in Support of Upholding Gender Equitable Workplaces" as part of our ongoing efforts to support the Trans community and build investor support for the Trans community. This statement frames the issue of Trans inclusion in terms of materiality, as well as social justice and equality. As investors, we support the full inclusion of Trans people - both as they participate in the workforce and the economy, and as they exist in communities at large.
Workforce Disclosures in Illinois
In March, we joined the US Sustainable Investment Forum in endorsing Illinois’ Workforce Investment and Sustainable Employment Reporting Act (WISER Act), which would require companies with business in Illinois to disclose information on workforce composition, compensation and benefits, talent management, health and safety, and workplace inclusion. Trillium has engaged companies for decades on better quantitative metrics about their workforces because we believe such information is necessary to evaluate corporations’ talent management, racial and gender equity, and health and safety performance. In the absence of federal action on this topic, we are encouraged to see states leading efforts to improve corporate transparency.
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.
1Q 2026 Impact by the numbers
American Water Works, recognized as the United States’ largest private water utility, has taken meaningful steps toward advancing environmental justice following several years of sustained engagement with Trillium focused on racial equity. In March 2024, American Water committed to a comprehensive assessment of its policies, practices, products, and services, specifically designed to examine the company’s operations through an environmental justice lens. Over the course of 2024 and 2025, the company selected an independent assessor and diligently completed the evaluation process. In early 2026, Trillium met with both the assessor and American Water leadership to review the assessment findings and discuss potential next steps. Particular attention was given to how the recent merger with Essential Utilities might influence the implementation of recommended changes.
In a February 2026 meeting, American Water acknowledged Trillium for its positive impact on sustainability and governance, attributing several improvements to Trillium’s engagement. The company confirmed it is actively considering the recommendations put forth by the assessment and has begun exploring ways to integrate these insights across the newly merged entity. As American Water transitions to executing these recommendations, Trillium will continue to closely monitor progress, ensuring that environmental justice remains a central focus throughout the integration and operational changes.
Over the past four months, Trillium intensified its engagement with Starbucks in response to growing concerns about labor relations oversight, stalled collective bargaining, and governance backsliding at the board level. In January 2026, Trillium joined other long-term investors in directly challenging Starbucks’ board after the quiet
dissolution of the Environmental, Partner, and Community Impact (EPCI) Committee, which had been established to oversee labor relations. Trillium coauthored and sent a letter to Lead Independent Director Jørgen Vig Knudstorp and Nominating and Corporate Governance Committee Chair Beth Ford, raising concerns about the lack of transparency around the Committee’s elimination and the reassignment of its responsibilities amid ongoing labor conflict.
In February 2026, we took additional steps by publicly initiating a “vote no” campaign against Directors Knudstorp and Ford. Alongside the NYC and NYS Comptrollers and other investors, Trillium issued a shareholder letter urging investors to oppose their reelection due to sustained labor oversight failures, renewed labor unrest, and the board’s retreat from independent Committee level oversight. This action generated significant media attention and placed labor governance squarely before shareholders ahead of the annual meeting.
In March 2026, Trillium continued direct engagement with the company and the board. Investors met with Starbucks leadership, including the Lead Independent Director. We are pleased that following the investor attention paid to how the company was approaching the collective bargaining process that the company and the union agreed to return the bargaining table.
Climate-driven events like droughts and storms are impacting agricultural supply chains, giving food retailers such as BJ’s Wholesale Club (BJ’s) a key role in reducing greenhouse gas (GHG) emissions. Retailers can help by sourcing renewable energy, improving energy efficiency, and preventing refrigerant leaks.
In 2021, Trillium urged BJ’s to set ambitious emissions goals. BJ’s agreed and in 2022 committed to the gold standard – a science-based emissions reduction target – but later withdrew its commitment. After BJ’s moved away from climate-focused practices reneging on its commitment, Trillium filed another proposal calling for decisive GHG reduction plans, which received strong shareholder support (30.4%) in 2025. However, BJ’s continues not to act, so Trillium refiled the proposal for 2026 and continues to push for credible climate action ahead of the company’s annual meeting in June.
In November 2025, under Chair Paul Atkins, the SEC announced a policy that substantially shifted power from shareholders to corporations. For companies seeking to exclude shareholder proposals during the 2025-2026 proxy season, the SEC indicated they would not substantively review most no-action requests, instead deferring to the companies.
This shift materially weakened the procedural protections that shareholders have historically relied on. While most companies have continued to include shareholder proposals that meet the requirements set forth under Rule 14a-8, the lack of a procedural path to challenging corporate exclusions has required shareholders to utilize other legal and strategic approaches to preserve their right to access the proxy ballot. While these alternative paths can be costly and time intensive, it is important for shareholders with the resources and ability to pursue them to explore new or underutilized paths to preserve shareholder rights.
In March, Trillium’s advocacy team employed an innovative path to a successful negotiation with BJ’s following their request for a no-objection letter from the SEC on our GHG emissions proposal. We are proud to join other committed shareholders in the exploration of multiple paths to protect our rights as shareholders. Earlier this year, BJ’s asked the SEC staff for a no-objection letter to omit the proposal pursuant to the vacuum created by the SEC’s withdrawal from its role as referee on Rule 14a-8 shareholder proposals. Trillium responded promptly and engaged the company directly to seek a practical solution that protects shareholder rights. After dialogue with BJ’s , the company has agreed to include Trillium’s GHG emissions shareholder proposal in its 2026 proxy materials.
In those discussions, Trillium outlined a clear path forward under SEC proxy solicitation rules and BJ’s bylaws: if the company continued towards omission, Trillium would submit shareholder proposals under the pathway provided for in the company’s bylaws and solicit proxies in support of those items. Those proposals would have included a GHG emissions proposal and, importantly, additional good corporate governance shareholder proposals. Trillium’s objective throughout was straightforward - ensuring shareholders had the opportunity to consider, at least, Trillium’s GHG emissions proposal on the company’s proxy.
Following further engagement, Trillium and BJ’s reached an agreement: BJ’s will include the Trillium shareholder proposal in its 2026 proxy materials, and the engagement would proceed in the well-established Rule 14a-8 process.
Why this matters:
Trillium continued climate-related engagement with both NextEra Energy (NextEra) and Alphabet in the first quarter of 2026. NextEra is a major developer of wind and solar and, through Florida Power & Light, has expanded renewables and battery storage while retiring its last coal plant in 2020. However, the company recently dropped its zero emissions by 2045 target and has indicated interest in developing new natural gas generation, including to serve growing data center demand. In response, Trillium filed a shareholder proposal in late 2025 requesting that NextEra assess pathways to re-establish an ambitious emissions reduction target; shareholders are expected to vote at the company’s annual meeting in late May 2026.
Alphabet, on the other hand, is among the big tech firms driving electricity demand by building enormous or “hyperscale” data centers to support its growing artificial intelligence business. Trillium has previously engaged the company on responsible growth and the environmental impacts associated with AI-related expansion, alongside ongoing concerns about data governance and consumer protections. Across both engagements, our work in Q1 focused on maintaining dialogue, advancing investor expectations, and doing the significant work of preparing for upcoming proxy votes by encouraging other investors to support these two shareholder proposals.
Trillium continues to believe that racial and gender equity are not only fundamental values but also long-term drivers of business performance, helping to foster innovation, resilience, and a positive workplace culture. In line with this conviction, we are actively engaging our portfolio companies on issues related to workplace fairness and inclusion, striving to ensure that organizations are creating environments where all employees
can thrive. Although we have observed an uptick in overall workforce diversity reporting in recent years, there remains a notable gap: some companies, including Tetra Tech, have yet to release meaningful disclosures about the composition of their workforces or the effectiveness of their inclusion efforts. This lack of transparency can hinder both accountability and progress toward equity goals. In response, this quarter we reached out to Tetra Tech to initiate a conversation about similar topics, encouraging them to enhance their reporting and take proactive steps toward greater workplace equity and transparency. We believe that such engagement supports stronger governance, reduces reputational risk, and positions these companies for long-term success in a diverse and rapidly evolving marketplace.
Trillium understands that a sustainable economy must protect human health and advance equity, which is why we engage beauty companies on chemical safety. Our work is grounded in environmental justice, recognizing that harmful exposures often disproportionately affect women of color. Hair straighteners marketed to Black women highlight this risk: research links certain formulations to elevated cancer rates, yet transparency remains limited. L’Oréal’s responses to investors emphasize legal exposure over proactive, hazard-based management, and current disclosures offer little insight into how chemical safety shapes product development. As a global cosmetics leader, L’Oréal could strengthen trust and reduce litigation risk by adopting independent screening frameworks and fully disclosing substances of concern.
Our January 2026 dialogue aimed to encourage L’Oréal to take a more forward-looking, hazard-based approach and improve transparency around chemicals of concern. While the company maintains sophisticated risk-based systems, it continues to resist broader hazard-based frameworks increasingly used by peers. We noted that L’Oréal does not publish a unified chemicals policy and discloses phaseouts only after completion – such as PFAS, which it phased out in 2024 – making progress hard to assess. Although it applies hazard criteria for environmental impacts, the company lacks a clear health-focused hazard scale and time-bound commitments for phasing out substances of very high concern. Despite strong internal technical capacity, L’Oréal raised concerns about setting group-wide targets across its brands. Going forward, we will encourage the company to expand disclosure, meet with ChemFORWARD (a science-based, non-profit organization focused on advancing safer chemicals through global supply-chain collaboration), and publish time-bound phaseout goals for substances of very high concern aligned with best practice and investor expectations.
Trillium is engaging Target on Diversity, Equity, and Inclusion (DEI) and immigration because we believe the company’s recent retreat from prior racial equity and inclusion commitments—alongside its inconsistent stance on LGBTQ+ issues – presents significant reputational, operational, and financial risks at a time when Target is struggling with declining sales, customer traffic, and brand trust, as documented by investors and media reports. Trillium’s values, rooted in advancing human rights, equity, and the fair treatment of all people across our economy and society call on us to encourage companies to uphold and not abandon these principles, especially when vulnerable communities are at risk. We have been particularly concerned that Target did not directly address the dangers posed by aggressive ICE enforcement in Minneapolis, despite the clear potential for long-term harm to employees, customers, and community trust, and the heightened reputational risk this poses even if enforcement activity later subsides.
In our past engagements, including a defending-ESG letter that raised DEI concerns, as well as discussions during ongoing dialogues on chemicals and pesticides, we expressed strong dissatisfaction with Target’s backtracking, especially as peer investors reported that the company had been defensive and inflexible in related conversations. With a new CEO starting in February 2026, we saw a critical opportunity to reengage Target on reinstating DEI commitments, addressing immigration-related risks in Minnesota, and strengthening governance of values-based risks. Recognizing the need for stronger accountability, Trillium co-led an investor letter, with over $150 billion in assets represented by the signatories to the letter, with Mercy Investment Services, which received national coverage in Reuters and underscored widespread investor concern about Target’s escalating reputational exposure.
Many day laborers wait in Home Depot parking lots seeking employment, and in the past year, these parking lots have been frequent U.S. Immigration & Customs Enforcement (ICE) raid sites. In November, Trillium filed a shareholder proposal at Home Depot with other ICCR members requesting a report assessing risks to customers’ data privacy rights, prompted by concerns about the company’s use of Automatic License Plate
Reader technology that has been linked to data abuse, including by ICE. We have held two meetings with Home Depot in 2026 to better understand the company’s technology policies and governance mechanisms and to advocate for better safeguards.
We continue to engage Apple on App Store governance and human rights concerns following Apple’s removal of the “ICEBlock” application, which allowed users to report sightings of ICE agents. Trillium’s engagement builds on earlier correspondence with Apple dating back to 2009 and 2011 and focuses on transparency, freedom of expression, and the company’s interactions with government authorities.
Beginning in October 2025, Trillium wrote to Apple’s corporate secretary seeking clarification on the grounds for the app’s removal, the role of law enforcement input, and how Apple evaluates politically sensitive content. As public scrutiny intensified – including coverage by major media outlets, advocacy by civil liberties organizations, and inquiries from members of Congress – Trillium urged Apple to take a more transparent and principled stance. In December 2025 and January 2026, Trillium encouraged Apple to emphasize protections for freedom of expression and privacy in its response to a House Committee on Homeland Security inquiry and to disclose more information about the circumstances surrounding ICEBlock’s removal.
In March 2026, Trillium again pressed Apple to publicly release its response to and provide clearer disclosure of its interactions with the U.S. government. We framed these requests as necessary for investors to assess alignment with Apple’s stated human rights commitments and its responsibilities as a steward of digital civic space.
Like many, we witnessed Immigration and Customs Enforcement’s (ICE) operations in Minnesota with deep concern. Corporate relationships with government agencies— particularly those associated with contentious enforcement practices—can expose companies to reputational, operational, and stakeholder-related risks. In Ecolab’s case, its contractual relationship with ICE to supply cleaning supplies carried heightened scrutiny due to escalating public concern and intensified federal detention activity, especially as a company headquartered in Minnesota. These conditions increased the potential for negative brand association, employee-relations challenges, and consumer backlash.
We wrote a letter to Ecolab in late January 2026 urging the company not to renew its contract with ICE when it expires and to carefully assess the reputational and stakeholder risks associated with continuing or entering similar agreements. We emphasized that while Ecolab’s products play an important sanitation role in ICE facilities, any association with ICE’s detention operations now carries heightened visibility and potential harm to the company’s civic reputation in Minnesota. We asked Ecolab to disclose its rationale should it pursue future ICE contracts, including how such decisions align with its stated values, how the company evaluates reputational and stakeholder risks, and how government contracts contribute to long-term shareholder value given their lower margins and added complexity.
In June 2025, Trillium reached out to several retailers and restaurants, including Chipotle, to encourage a move away from phenol-based receipt coatings. Although bisphenol-A (BPA) was phased out of thermal receipt paper due to its endocrine- disrupting effects, bisphenol-S (BPS) became a common substitute despite evidence of similar harms. We urged retailers and restaurants to phase out BPS in receipts, adopt safer alternatives, and protect workers in the interim. We also highlighted leadership from TJ Maxx and Burlington Stores, who several years ago committed to phenol-free receipts thanks to engagement efforts led by Trillium.
Chipotle responded to our outreach, saying they have identified suppliers that can provide phenol-free receipts and that they are in the process of transitioning to phenol- free receipts in all US restaurants. Over 25% of their restaurants were already using phenol-free receipts in October 2025 and their goal was to fully transition by the end of 2025. They were also testing “by request only” receipt options. We congratulated the company and subsequently had a dialogue in January 2026, discussing both BPS phaseout and Chipotle’s approach to pesticide reduction. Although Chipotle is a leader when it comes to whole-ingredient, healthier quick service food options, it does not have a pesticide reduction goal. Synthetic pesticides are linked to serious health harms, including cancers and developmental defects, and they contribute to pollinator decline and soil degradation, undermining regenerative agriculture goals. We believe that Chipotle has an opportunity to align its pesticide management practices with its brand image by encouraging suppliers to adopt regenerative practices and reduce pesticide use. Chipotle shared that they are beginning to assess their biodiversity-related impacts, and we will continue to monitor the company’s progress.
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. Accordingly, Trillium routinely engages in initiatives led by other organizations to help strengthen and amplify shared messages.
Digital Platforms
Trillium has a long-standing history of commitment to safe and healthy workplaces. “Digital platform work” is the human labor that undergirds online corporate services – from digital content moderation to physical delivery services. This type of labor constitutes a growing and relatively unregulated sector. In advance of an upcoming meeting of the International Labor Organization, we signed onto an Interfaith Center for Corporate Responsibility letter in support of passing the proposed binding International Labor Organization Convention to protect Platform Workers from unregulated and abusive working conditions.
Trans Rights
We signed onto Adasina's "Investor Statement in Support of Upholding Gender Equitable Workplaces" as part of our ongoing efforts to support the Trans community and build investor support for the Trans community. This statement frames the issue of Trans inclusion in terms of materiality, as well as social justice and equality. As investors, we support the full inclusion of Trans people - both as they participate in the workforce and the economy, and as they exist in communities at large.
Workforce Disclosures in Illinois
In March, we joined the US Sustainable Investment Forum in endorsing Illinois’ Workforce Investment and Sustainable Employment Reporting Act (WISER Act), which would require companies with business in Illinois to disclose information on workforce composition, compensation and benefits, talent management, health and safety, and workplace inclusion. Trillium has engaged companies for decades on better quantitative metrics about their workforces because we believe such information is necessary to evaluate corporations’ talent management, racial and gender equity, and health and safety performance. In the absence of federal action on this topic, we are encouraged to see states leading efforts to improve corporate transparency.
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.
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