Q4 2025 Impact Update

Marcela I. Pinilla
Director of Sustainable Investing

As 2025 comes to a close, a throughline has emerged across our engagement work, policy analysis, and client conversations: power—who holds it, how it’s exercised, and how investors can insist on accountability when governance falls short. From the expanding surveillance economy to mounting pressure on shareholder rights, these dynamics are no longer theoretical. Below, we highlight our recent work and why it matters for long-term investors managing systemic risk.

Data Is the New Oil; Our Engagements Are Focused on the Pipelines

Personal data now operates like oil—extracted, aggregated, refined, and monetized—yet the pipelines moving it to corporations, brokers, advertisers, and governments lack safety valves. Once it enters the commercial market, weak data governance leaves individual and customer data largely unprotected. Across the cases below, the core question is the same: who controls the pipeline, who profits from it, and who bears the risk when data is misused:

  • Alphabet operates one of the world’s largest data ecosystems through Google Services and Google Cloud. Weak downstream governance enables surveillance, censorship, profiling, and targeting— especially in countries with broad government access to data. Our engagement focuses on risks stemming from customer misuse.

  • Amazon sits at the center of the data economy through AWS, Ring, and its AI tools, which can serve as surveillance pipelines for law enforcement, immigration, and military actors. Our engagement assesses whether these uses align with Amazon’s stated Responsible AI commitments to fairness, privacy, safety, and transparency.

  • Microsoft publicly opposes mass civilian surveillance, yet its cloud and AI services have been implicated in large-scale data collection linked to military and intelligence operations. Through sustained engagement, we have pressed for stronger human rights due diligence and clearer accountability for harmful customer use.

  • Home Depot shows that surveillance pipelines extend beyond the tech sector. Through vendors like Flock Safety, customer and employee data—including license plate and location—can flow from retail parking lots into databases used by law enforcement and accessed by immigration enforcement agents.

A Direct Hit to Shareholder Democracy

In November, the SEC made it easier for companies to mute shareholders by loosening the rules on excluding shareholder proposals from proxy ballots. What once required SEC review will now largely be left to management’s own legal reasoning, turning the regulator into a spectator.

But when employees organize, customers protest, or communities push back, these are not distractions from operating a corporation in the capital markets, they are early warnings of unmanaged risk. Shareholders serve the same function, surfacing persistent social, environmental, and governance risks and impacts that boards are charged with overseeing. That pressure is not a nuisance—it is a core feature of functioning markets and corporate democracy. When real-world issues are shut out of the proxy, the risks don’t just suddenly vanish, they often appear as impacts with a high human and environmental cost.

The SEC’s retreat may seek to block the most direct channel for investor accountability, but investors are unlikely to be deterred. So far this proxy season, we have exercised those rights by filing shareholder proposals at five companies:

Proxy Season 2025 | Proposals filed this quarter

AbbVie, Co-filed with Friends Fiduciary Corporation

We requested board oversight of human rights due diligence, including an impact assessment of AbbVie’s operations and supply chain focused on the right to health. U.S. branded drug prices far exceed peer-country levels, creating access barriers that a robust assessment would help identify and address.

Alphabet, Primary filing

Our proposal asks Alphabet’s Board to publish a report assessing risks arising from weaknesses in how the company manages and oversees user and customer data across Google Services and Google Cloud, particularly in contexts where misuse could enable surveillance, censorship, profiling, or targeting of people.

Amazon, Co-filed with Investor Advocates for Social Justice

We requested a report evaluating the alignment between Amazon’s Responsible AI commitments and its sale and deployment of AI and cloud technologies. Limited transparency around controversial uses of AWS and Ring creates uncertainty for investors and heightens legal, regulatory, and reputational risk.

Home Depot, Primary filing

We began engaging Home Depot in June amid ICE raids at California store parking lots. In September, with more than 60 investors representing $378 billion in assets under management we urged the company to assess customer and employee data privacy risks tied to its Flock Safety partnership, which reporting shows is accessed by ICE to enable vehicle tracking during these raids.

Microsoft, Co-filed with Investor Advocates for Social Justice

We requested that Microsoft assess the effectiveness of its human rights due diligence processes in preventing misuse of AI and cloud services. The proposal received a substantive 26% support in December. While Microsoft’s decision to disable certain Israeli military services presents progress, reports that surveillance data shifted to other providers underscore the need for stronger, enforceable sector-wide governance.

Perspective-Sharing and Learning
This quarter also reinforced the importance of dialogue across a range of constituencies:

  • ICCR Fall Conference: Marcela Pinilla participated as a plenary speaker on the role of dialogue amid political, cultural, and economic upheaval, and as a panelist on investor responsibility in the immigration crisis.

  • Academic Engagement: Marcela guest-lectured students from UC Berkeley Haas and Harvard Kennedy School in the Turner Impact Portfolio Challenge on Zevin’s approach to sustainable investing and corporate engagement.

  • Investor Education: Hosted by Lucid Capitalism and the Racial Justice Investing Coalition, Zevin Asset Management delivered an investor briefing on how capital markets enable the surveillance economy and what investors can do to address their exposure.

  • Client briefing: We also hosted a client webinar with Esra’a Al Shafei, founder of Surveillance Watch, examining how the surveillance economy works, how investors are exposed to risks and what can be done. Slides or a recording of the webinar are available upon request.

    Looking Ahead
    We remain committed to evaluating our portfolio companies to assess undermanaged risks. When corporations ignore equity and accountability, costs are pushed onto workers, communities, and ultimately investors. When companies get it right, they build trust and workforce resilience, protecting long-term shareholder value.

Thank you for reading and sharing. For more on this work and our broader advocacy, visit our website, and join us on LinkedIn, Facebook, and Instagram. And please don’t hesitate to contact Marcela Pinilla, Zevin Asset Management’s director of sustainable investing, at marcela@zevin.com with your questions, thoughts, and suggestions.

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