Sustainable Finance Lobbying Overview: The National Association of Manufacturers (NAM) appears opposed to regulatory intervention on sustainable finance, engaging actively against efforts to mandate corporate ESG disclosure and expand shareholder rights.
Top-Line Messaging on Sustainable Finance Policy: The NAM has voiced support for reducing GHG emissions in line with a 2°C target, however it does not place these reductions on a clearly defined timeline.
Position on Regulated Corporate ESG Disclosure: The NAM has engaged in opposition to efforts to mandate corporate ESG disclosures. In comments to the SEC in June 2022, the NAM questioned the need for rulemaking on climate disclosure and the SEC’s authority to undertake such rulemaking. In letters to Congress in April and July 2023, the NAM called on lawmakers to prevent the SEC from finalizing its climate disclosure rule. Additionally, in a July 2023 House Financial Services Committee hearing, NAM Managing Vice President of Policy Christopher Netram urged lawmakers to “limit the SEC’s ESG reporting rules.” In February 2023, NAM also opposed efforts by the Federal Acquisition Regulatory Council to require climate disclosure from contractors, including Scope 3 emissions disclosure.
Position on Incorporating ESG Factors Into Investor Duties: The NAM has been actively engaged in opposition to policies that seek to incorporate ESG factors into investor duties and expand shareholder rights. In 2020, the NAM strongly supported proposed rollbacks by the Trump-era Department of Labor to limit fiduciaries' ESG investing and voting on ESG issues. Similarly, in feedback to the SEC and a press release in 2020, it also strongly supported regulation which would limit shareholder rights in the US. According to external investigations, led by Bloomberg, NAM has funded groups such as the Main Street Investors Coalition that have worked to influence sustainable finance policy by, in one instance, allegedly writing comments to the SEC in support of the proposed rollback of shareholder rights. The comments were falsely attributed to members of the public who had ties to 60 Plus, a MSIC member. NAM denied any involvement with the 60 Plus SEC letters and NAM’s website lacks any disclosure of its ties to these groups and their impact on sustainable finance policy.
In November 2021, the NAM opposed the Biden-era SEC’s revised guidance on shareholder proposals. In September 2022, the NAM opposed the SEC’s proposed amendments to rules governing shareholder access to the proxy ballot, arguing that the proposal would “empower activists and prioritize their agendas.” In letters to Congress in April and July 2023, and in congressional testimony in July 2023, the NAM called on lawmakers to reverse these rules and guidance from the SEC. NAM is also currently pursuing legal action to argue that the SEC lacks any authority to require companies to include shareholder proposals on proxy ballots.