Marcela Pinilla Director of Sustainable Investing
Zevin Asset Management believes that Alphabet Inc.'s governance of customer and user data represents a material and underappreciated risk to investors, to the company's long-term reputation, and to the broader public interest. We have taken two coordinated steps to push for greater accountability: a formal shareholder proposal submitted for the Annual Meeting, and a direct engagement letter sent to Alphabet's Board of Directors as part of a broader investor coalition. What follows describes each action and the concerns that motivate them.
1. Letter to the Board
On April 20, 2026, a coalition of more than 40 long-term institutional and fiduciary investors, including co-filers of the shareholder proposal, wrote directly to Alphabet's Board of Directors requesting urgent engagement on its governance related to its cloud and AI deployments.
This group of investors represent over $1.15 trillion in assets under management.
2. The Shareholder Proposal
Zevin Asset Management, together with 34 co-filers representing over $2.2 billion in Alphabet shares, has submitted a shareholder proposal for the 2026 Annual Meeting.
Proposal request:
A public report assessing operational, regulatory, reputational, and legal risks arising from gaps in the company's policies, controls, and oversight of customer and user data processed through Google Services and Google Cloud.
why this matters?
Alphabet is not simply a technology company. It is an infrastructure provider for governments, corporations, and security systems across the world.
Through Google Services and Google Cloud, the company processes vast amounts of sensitive data, including location data, behavioral patterns, and, in some contexts, facial imagery and surveillance-related information. These systems increasingly support artificial intelligence applications used in public sector operations, national security, and enterprise decision-making.
When governance falls short at this level, the consequences extend far beyond corporate performance. They shape how power is exercised, who is monitored, how data is used, and what recourse exists when harm occurs.
Investors are raising these concerns because failures in oversight, accountability, and control create material financial risk. At the same time, these failures carry broader implications for civil liberties, human rights, and democratic accountability. This proposal reflects both realities.
Three Core Concerns
Alphabet's growth strategy increasingly relies on cloud and AI systems that process sensitive government and enterprise data—including facial imagery and location data in surveillance, security, and military contexts. As cloud services become more central to Alphabet's overall performance, the governance risks associated with their deployment become correspondingly more material to investors.
Investors have not received sufficient clarity on whether the Company retains sufficient contractual authority, escalation mechanisms, and Board-level oversight to manage material legal, regulatory, operational, and reputational risks when these technologies are deployed by government or security-related customers.
Investors request engagement on how Alphabet assesses and mitigates downstream misuse risk, how contractual structures preserve authority to intervene when risk escalates, and how lessons from high-risk deployments are integrated into enterprise-wide governance and Board oversight.
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