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SOC Investment Group has filed shareholder proposals at Alphabet, Amazon and Walmart seeking disclosure on the impacts of U.S. immigration policy changes. Below, SOC's corporate governance director Louis Malizia speaks to DMI on what drove the campaign.

SOC has engaged on a wide range of themes over recent years, from labor relations, health and safety to executive compensation. What drove the group to turn its attention to immigration policy ahead of the 2026 season?



There's been rapid and expansive changes to the nation's immigration policy and enforcement. We see this changing the landscape for U.S.-based companies with risks for investors, workers and consumers.

Companies that have extensive reliance on H-1B visa hires and exposure to industries with large immigrant populated workforces such as agriculture, transportation and logistics are vulnerable to these sharp contractions in the labor supply chain and related increasing costs.

We think the residual risks are going to be even more difficult to surmount. Those risks include declines in productivity and threats to innovation, as well as a blow to a company’s reputation.

For workers, the impact is often immediate, with job loss and loss of opportunity as well as severe changes to immigration status, which can lead to detainment and deportation.

All three companies that we filed the resolution at are some of the highest-level employers of H-1B visa applicants, with Amazon being the largest sponsor of H-1B visas in 2025.



At Amazon and Walmart, SOC has focused on the impacts changes in immigration policy could have on agriculture and logistics. What do you feel are the greatest risks?



I think it's important to realize that there is a great risk to workers and consumers because of shrinking labor supply leading to rising prices. This alongside the reliance that some companies like Amazon and Walmart have on fresh produce as profit and sales centers can impact their bottom lines. Walmart says 70% of produce sold in its stores comes domestically, and 60% of its sales comes from the produce aisle.

This same logic applies to Amazon and Walmart when it comes to their trucking and logistics segments – a shrinking labor force due to immigration policy changes can impact operations and raise costs. These are some very real impacts and I don’t think it’s an issue that companies can or should easily omit from their disclosures.



At Google parent company Alphabet, SOC took a different approach and flagged concerns that such policy changes could have a detrimental impact on AI innovation. Can you expand on this?



The AI revolution and these massive immigration changes are happening at the same time. The dramatic increase that occurred when H-1B application fees went from $125 to $100,000 last September had an immediate effect on the tech industry.

Job creation is put at risk by this reduction in visas. Studies show that five to seven jobs are created for domestic workers for every foreign-born temporary worker employed at a U.S. business.

We think innovation is certainly at risk as a disproportionate number of the high-quality patents are products of H-1B visa workers.

This shrinking of the talent pool is even further threatened by changes in student visa policies. More than 50% of the computer scientists with graduate degrees are non-U.S. born students and approximately 70% of all graduate students were born abroad.

Alphabet is largely driven by its investment in its technology. Its CapEx reached upwards of $90 billion in 2025, double that recorded just a year prior. These investments have been highly successful for the company with Gemini 3 and Google's custom AI chip met with praise from consumers and investors alike.

The Google research paper “Attention Is All You Need” is the foundation of the generative AI products that we're seeing out there now and when you look at who wrote it, six of the eight were born outside the U.S.



Last year, the U.S. Securities and Exchange Commission (SEC) argued that nothing has epitomized the politicization of shareholder meetings more than shareholder proposals focused on environmental and social issues. As you press for disclosure around immigration policy, how would you respond to this view?



Immigration policy has an effect on the bottom line and on all key stakeholders of a company, workers, investors and consumers.

Sometimes, politics are indeed out of a company’s hands. However, companies are political players too with specific issues they advocate on.

While we’re sympathetic to companies being subject to U.S. policy change, we’re invested for the long term, and we’d like to hope that our companies are thinking of sustainable growth plans that reflect the current crisis and their ideas for getting past these problems while protecting the company from these risks in the future.



What do you ultimately hope to achieve from your campaign?



We've been left as investors with a lot of uncertainty, not just due to the pace and scope of these policy changes, but also the lack of transparency on how companies plan to deal with the transformation that's taking place in both the near and long-term.

We’d like to see far better reporting coming from companies on the impacts the shift in immigration policy and enforcement is having on their operations.

At the moment, this is a line or two in a 10K saying there may be risk to the company due to U.S. policy change, and that can be lumped with any number of other instances of U.S. policy change. But we think some of these impacts are having a very direct impact on labor supply chains.

We would like to see how companies are viewing the risk and the types of mitigation efforts they are putting forward to prepare themselves for these risks. We'd want to see the board level responsibility that’s overseeing these risks and protecting our investments and workers.

There could be a wide range of decisions companies are making but we’re not privy to that right now.

IN-DEPTH: Q&A with SOC as it shifts focus to immigration policy 

Policy and procedure management is the foundation that connects board-level governance with day-to-day operations. With hybrid work now firmly established and growing emphasis on 

 — alongside constant regulatory and business change — effective policy management is more critical than ever.

Yet there's often a significant gap between board-level policymaking and organization-wide adoption. According to

, 60% of organizations report their governance and finance systems are either completely siloed or only partially integrated, with just 4% achieving full platform integration. This fragmentation extends to policy management, where well-crafted policies frequently end up in a virtual cupboard and are forgotten.

Boards face a fundamental challenge: How do you set strategic policy direction while ensuring those policies translate into consistent organizational behavior? The answer lies in establishing clear accountability, structured processes and technology-enabled oversight that bridges the gap between governance vision and operational reality.

This guide explains how boards can implement effective policy and procedure management by covering:

What policy and procedure management is and why it matters for organizational governance

The full policy lifecycle from creation to retirement

How boards balance strategic direction with appropriate delegation

Best practices for documenting, reviewing and updating policies

Common risks during policy change, and how to mitigate them

Policy and procedure management is the systematic process of creating, approving, communicating, maintaining and enforcing policies and procedures across an organization. It encompasses the full lifecycle from initial drafting through review, approval, distribution, attestation and eventual retirement.

Effective policy and procedure management connects board governance with operational execution. Your policies set out your corporate position, establishing your standpoint and supporting your goals and values. They provide the bridge between leadership vision and management tactics — aptly described as the "collective voice of the board."

, we need to consider the importance of policy over all.

Why is having policies important? Your business policies set out your corporate stall, establishing your standpoint and supporting your goals and values.

Your policies give your business operations a structure and framework that underpin your 

 programs. But of course, setting policy is only half the battle. Life would be easy if boards could set the organization on its chosen course and sit back to enjoy the ride.

In practice, there can be a chasm between board-level policymaking and business-wide adoption. 

 — an annual survey of more than 200 U.S. public company directors conducted in partnership by the Diligent Institute and Corporate Board Member — shows this gap is widening. The findings reveal that 53% of directors say they don’t receive real‑time data between meetings, and 47% want more structured full‑board risk discussions — expectations that put even more pressure on having up‑to‑date, well‑documented policy frameworks. This is where policy management is vital.

Effective policy and procedure management follows a complete lifecycle:

: Developing policy content that reflects board direction and regulatory requirements

: Routing policies through proper approval chains with documented sign-offs

: Ensuring policies reach all relevant employees and stakeholders

: Confirming employees understand and acknowledge their obligations

: Tracking adherence and identifying gaps before they become violations

: Evaluating policies against changing requirements at regular intervals

: Formally removing outdated policies to prevent confusion

Each stage requires clear accountability and documented processes. Organizations that skip stages, particularly attestation and regular review, discover gaps only during audits or crises, when remediation is most expensive.

The board's responsibilities: Knowing when to step in and when to step back

Directors play a central role in determining policy, but should employ a lighter touch on implementation and oversight.

The board should determine company policies and delegate the implementation of those policies to management, confining the board's role to monitoring and evaluating this implementation. This sounds reasonable when you consider that delegating appropriate decision-making is recognized as one of the 

Understanding when to step back is a skill all board directors should refine when it comes to policy. Your leadership team has been appointed for their collective expertise and judgment and should be allowed to exercise them.

Setting strategic direction without micromanaging

Your policy statements should be broad yet concise, designed to outline your corporate purpose and position rather than providing step-by-step implementation actions. This approach enables the business to take ownership of policies, tailoring them to fit specific circumstances and updating them as needed in response to internal or external change.

Effective delegation doesn't mean disengagement. Boards retain crucial accountability in periodically reviewing and evaluating policies. The 2026 What Directors Think report found that 58% of directors want less time spent on presentations and more time for strategic planning — a clear signal that boards continue to prioritize forward-looking strategic discussions over operational detail, a finding that applies directly to policy oversight.

"There's often an inclination to avoid bad news, with a hope that problems will be resolved before they escalate to the board level," says Pav Gill, CEO of Confide. "But boards should proactively request access to whistleblowing reports. It's essential to see firsthand how secure, effective and current mechanisms are. Only then can you be confident in the integrity of your compliance framework."

Building cross-functional policy governance

While boards set direction, effective implementation requires coordinated involvement across multiple organizational functions. Large organizations increasingly establish cross-functional policy committees that handle lifecycle activities day-to-day. These committees typically include representatives from:

This structure ensures policies reflect operational reality while maintaining alignment with board-level governance direction.

What does best practice policy management look like?

What constitutes best practice in policy and procedure management? It encompasses several interconnected activities that transform policies from documents into organizational behavior.

When organizations start out, they often take a relaxed approach to documenting policies. A small number of employees and an entrepreneurial ethos can drive a reluctance to overly formalize procedures. As a business grows, though, documenting policies and processes becomes more critical.

Documenting your policies enables you to take a more consistent approach — especially if your organization consists of several locations or 

 — facilitating proactive risk management and giving boards comprehensive oversight of organizational operations and performance.

When you ask, 'How often should we review our corporate policies?' answers vary. But best practice is to review policies every one to two years — some experts 

. And of course, if organizationally you have undertaken change, this will usually demand a change in your policies and procedures.

The most lovingly crafted policy is no good if the regulation it refers to was superseded years ago, or if legislation has been expanded since it was drafted, or if your business no longer resembles the organization described in the policy.

. External events may have caused you to revisit your business 

. All of these should trigger a review of your corporate policies.

3) Harnessing best practice policy management to drive GRC

Policy management is vital in itself, but from a board perspective, its importance in helping to create a risk-management-focused organization shouldn't be overlooked.

A best practice approach to policy management gives you a framework for your 

 — enabling you to embed GRC at every level of your business. Having well-defined policies is a vital starting point for any programs designed to improve governance, risk or compliance. Policy management enables you to see where documented procedures are lacking and where your approach could be improved.

Mitigating risk during company policy change

All change initiatives, including policy changes, come with execution risks. Whether you're undertaking an organizational restructuring, implementing new AI governance frameworks, or adapting to regulatory changes, any change to business policy and strategic management brings several risks that require careful management.

Risk 1: Changes fail to drive improvement

Not all changes are for good, and every policy tweak carries the chance that the new approach won't better the previous one. Boards need to communicate a sound rationale for change, underpinned by data that evidences the shortcomings of the outgoing policy.

Before approving significant policy changes, directors should ask:

What specific problem does this change address?

What evidence supports the need for change?

What are the unintended consequences we should monitor?

Risk 2: Management lacks capacity to implement changes

Management must remain focused and positive (although realistic) about the project, particularly any slippages in timescales, to inspire commitment and buy-in. Resource constraints are real: according to Diligent's Transaction Readiness Report, 56% of organizations cite limited resources as their top challenge.

Boards can mitigate this by ensuring adequate resources are allocated for implementation, setting realistic timelines that account for operational demands, providing clear escalation paths when implementation encounters obstacles and monitoring progress without micromanaging execution.

Risk 3: Employee resistance undermines adoption

Change is often met with skepticism, fear and resistance. Boards can help mitigate this by introducing policy change in small steps, rather than overhauling too much at once, and by leading by example in adopting new practices.

Turning reluctant employees into advocates of policy change demands clear communication and a pragmatic approach. Change should never be forced but should be bought into at all levels.

This requires clear explanation of why changes are necessary, involvement of affected teams in implementation planning, visible leadership commitment to new policies and recognition of early adopters and compliance champions.

Learn how automated policy management reduces compliance risk while freeing resources for strategic priorities.

Build compliant, audit policies

How AI transforms policy and procedure management

For boards overseeing complex policy frameworks across multiple jurisdictions and business units, technology has become essential infrastructure rather than an optional enhancement. Centralized policy and procedure management platforms address the fragmentation challenges that undermine governance effectiveness.

1. Automated workflows and approval routing

Policy and procedure management software like 

 provides configurable workflows that route policies through proper approval chains automatically. Rather than relying on email chains and manual tracking, policies move through creation, review and approval stages with full audit trails documenting who did what and when.

For enterprise organizations managing thousands of policies across global operations, these automated workflows ensure consistency while reducing administrative burden. Customizable workflows adapt to your organizational structure and approval requirements rather than forcing rigid processes.

2. Policy attestation and comprehension tracking

Automated attestations fundamentally change policy governance by providing documented evidence that employees acknowledged and understood their obligations. Policy Manager automatically tracks acknowledgment, delivers comprehension testing where appropriate and escalates incomplete attestations without manual follow-up.

This capability is particularly valuable during audit preparation and regulatory examinations. Instead of scrambling to compile evidence of policy compliance, organizations maintain continuously updated documentation that demonstrates governance maturity.

3. Version control and audit-ready documentation

Policy changes create compliance risk when organizations cannot demonstrate which policies were in effect at specific times. Centralized policy management maintains a complete version history, approval tracking and audit trails that support regulatory compliance and litigation defense.

Advanced analytics transform this documentation into actionable intelligence. Organizations can demonstrate policy compliance metrics to investors and auditors while identifying departments or locations that require additional attention.

4. Integration with broader GRC infrastructure

The most significant benefit of modern policy management platforms comes from integration with broader governance, risk and compliance systems. Policy Manager connects with the 

 to ensure policy management aligns with risk assessments, compliance monitoring and board reporting.

Rather than managing policies in isolation, organizations connect policy frameworks to the risk and compliance activities they're designed to support.

Effective policy management requires boards to set strategic direction while allowing management to oversee implementation. Get this balance right, and you'll enjoy better documented processes while strengthening your entire GRC strategy.

See how Diligent delivers audit-ready policy management that scales with your organization. 

Frequently asked questions about policy and procedure management

How often should policies and procedures be reviewed?

Best practice is to review policies at least every one to two years, with interim reviews triggered by material changes. These triggers include regulatory changes, corporate restructuring, M&A activity, IPO preparation, technology adoption and crisis events that expose policy gaps.

Policy and procedure management platforms automate review cycles and reminders, ensuring policies stay current without relying on manual tracking. This continuous approach prevents the common problem of discovering outdated policies only during audits or incidents.

What is the board's role versus management's role in policy management?

Policy and procedure management: A strategic guide for boards

This article originally appeared in our January 29th edition of the Diligent Minute Newsletter. For more insights like these, delivered straight to your inbox, subscribe 

AI is top of mind for directors this year, the connective tissue linking growth, risk, human capital and compliance. That’s what we found in our 

 report, an annual survey of U.S. public company directors produced in partnership with Diligent Institute and Corporate Board Member. More than 200 directors shared how they’re navigating strategy, risk, talent and governance in an environment defined by volatility and technological change. The result is a rich window into what’s really on board agendas in 2026 — and what may be missing.

One in four boards view technological disruption, including AI, as among the greatest opportunities for their companies, yet only a small minority cite it as a top risk — highlighting an optimism that may not fully account for how quickly AI‑native competitors can upend business models.

Some headline AI‑related stats from the survey:

 of directors say pursuing growth through M\&A and strategic partnerships is a top priority for 2026, while 

 cite deploying AI technology across the business and 

 point to growth through new products or new markets.

 say technology adoption and integration will be a primary focus of capital investment in 2026, outpacing M&A and market expansion.

 of boards report that AI is fully embedded in risk oversight and decision‑making; 

 of directors expect AI and technology‑related regulation to demand the greatest compliance‑related board attention in 2026, and 

 say AI and technology regulation is the most underestimated area of compliance oversight today.

When asked how to strengthen risk oversight, 

 want enhanced use of AI‑powered data and technology tools, and 

 say access to AI‑powered technology for board work and oversight would help optimize governance processes overall.

Behind these figures is a widening governance gap

While AI dominates strategic conversations and investment plans, only 

 of directors say their board has strong AI expertise, and 

 rank technological developments, including AI, among the most challenging issues to oversee. 

 through composition, increasingly looking for directors who can pair traditional governance experience with practical, credible AI fluency.

Boards’ own use of AI also lags their ambitions

Despite the surge in digital tools like board portals, secure messaging and AI‑assisted briefings, only about one in five boards use AI‑powered technology regularly to 

support risk oversight and strategic decision‑making

, and very few have fully embedded AI into their processes. Directors themselves point to AI‑enabled analytics and dashboards as one of the most powerful levers to enhance both risk and compliance oversight, suggesting many recognize the gap and are actively looking for practical ways to close it.

Workforce implications are real and rising

Finally, the survey underscores that AI is fundamentally a people and skills story. Directors expect skills development and reskilling for emerging technologies such as AI and broader workforce strategy to consume substantial board time in 2026, even as workforce investment overall remains relatively underprioritized. They also anticipate that productivity monitoring, job redesign and redeployment, and the ethical use of AI in workforce management will require ongoing, deeper board attention.

Taken together, the findings paint a clear mandate for boards: treat AI not as a discrete project, but as a 

 that touches strategy, risk, compliance and talent. The boards that will lead in this next chapter are those that pair bold bets on AI with equally rigorous oversight — building the expertise, data and governance structures to ensure AI becomes a durable source of advantage, not an underappreciated source of risk.

Get the insights: Download your copy of What Directors Think 2026 

AI adoption rivals M&A as a 2026 priority

This article originally appeared in our January 15th edition of the Diligent Minute Newsletter. For more insights like these, delivered straight to your inbox, subscribe

After three quarters of near-record low confidence levels

, America’s boardrooms ended 2025 on a surprisingly hopeful note, even as directors brace for another demanding year. The latest 

, our quarterly survey of U.S. public company directors conducted with Corporate Board Member, shows sentiment rebounding sharply after three consecutive quarters at a five-year low throughout much of last year.

Why U.S. board confidence rebounded at the end of 2025

Confidence rose 23% in the final month of the year, climbing from 4.9 to 6.0 on a 10-point scale and finally nudging back into what respondents consider “good” territory. As a key driver behind the shift, directors point to:

In other words, after a year of policy whiplash, boards feel they at least understand the playing field a bit better - even if they don’t like it.

That late-year rally, however, shouldn’t be mistaken for a victory lap. For 2025 overall, average confidence registered just 5.0, well below 2024’s 6.2 and far short of the 6.9 directors had forecast a year ago.

Three quarters of respondents say tariffs were a primary reason conditions fell short of expectations, far outpacing any other factor. Their comments underscore how hard it is for boards to plan when rules change midgame; familiar playbooks don’t work when trade policy and enforcement shift repeatedly.

Tariffs, uncertainty and a new risk landscape

Directors in sectors long considered resilient

, like life sciences, describe this period as unlike anything they’ve seen in decades. Many point to deferred capital spending and elongated decision cycles as companies try to model scenarios that are, frankly, impossible to model with precision. That reality is reshaping how boards think about risk, resilience and the very nature of their oversight role.

Their outlook for business conditions by late 2026 is 6.0, essentially flat from today’s reading. CEOs, by contrast, are modestly more upbeat: in a parallel survey by Chief Executive, they project a 6% improvement to 6.4, and 44% say they expect conditions to improve, compared with 32% of directors. That gap is telling. CEOs are closest to near-term operations; boards are increasingly focused on longer-horizons, compounding risks.

Those directors who are optimistic tend to anchor their confidence in 

 seeing opportunities to transform productivity and reimagine business models. Among those who expect deterioration, concerns skew heavily toward macro and geopolitical risk, with uncertainty emerging as a dominant theme -— on par with inflation for many neutral respondents.

How boards can strengthen oversight and learning in 2026

directors emphasize adaptability, deeper engagement and faster learning, recognizing that they must connect dots across 

5 years of the Director Confidence Index: Tracking a more demanding role

This quarter also marks five years of fielding the Director Confidence Index, and we asked respondents how their roles have evolved since 2020.

Board members say they are spending far more time on risk in a “more complex and faster moving” environment, with cybersecurity, AI, geopolitical shocks, supply-chain integrity and policy volatility now standard agenda items. Many describe a shift from “managing the present” toward future-oriented scenario planning and strategic resilience, alongside heightened scrutiny from investors and activists that expands the mandate beyond financial performance to culture, human capital and corporate character.

Taken together, the picture is clear: being a director today is more time-intensive, strategically demanding and consequential than it was in 2020 and perhaps than it has ever been. One director distilled the 2026 playbook to three words: “Defend and survive.” I would add a fourth: learn. Boards that invest in learning about AI technology, geopolitics, regulation and stakeholder expectations will be best positioned not just to endure whatever comes next, but to help their organizations emerge stronger on the other side.

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IN-DEPTH: Q&A with SOC as it shifts focus to immigration policy

Policy and procedure management: A strategic guide for boards

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