Here’s an excerpt from this 14-page report on ESG disclosures penned by Labrador’s Deborah Koenen (the report contains numerous disclosure examples):
“In response to the increased scrutiny by anti-ESG factions but mindful of continued investor interest in those topics with clear financial implications, companies took a variety of approaches to ESG disclosures in their 2025 proxy statements.
In reviewing several 2025 proxy statements, Labrador did not notice a “one size fits all” approach but found that companies tailored their response based on their unique circumstances and shareholder base.
Below are some of the approaches taken by companies in 2025:
- Stay the course and retain a description of their ESG programs. For the companies that retained their disclosure in 2025, many acknowledged a clear tie to their business and long-term value creation.
- Retain some disclosure but reduce the amount of content or modify the description to delete controversial words or programs.
- Reduce the amount of content or pages devoted to ESG7.
- Change the location of the disclosure so that it is not front and center, e.g., move the disclosure out of the proxy statement summary.
- Change the nomenclature to remove references to ESG. Companies often use other words like impact, corporate stewardship, or corporate responsibility.
- Make other changes, such as deleting qualifications from the directors’ skills matrix related to climate or ESG and removing stand-alone sections related to ESG stockholder engagement.
- Delete any ESG disclosure from the proxy statement.”
