IN-DEPTH: Q&A with Trillium on navigating a new era of shareholder advocacy

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Shareholder advocacy entered 2026 on uncertain footing. With the SEC stepping back from the no-action relief process and investor support for climate and other proposals under pressure, proponents rethought how to get companies and fellow investors to engage. Trillium Asset Management responded by combining shareholder proposals with dialogue, while also mulling an independent proxy solicitation.

Andrea Ranger, director of shareholder advocacy at Trillium, discusses how the firm is measuring success beyond the ballot, the issues shaping its engagements and why smaller investors can serve as an early warning system for larger institutions.

The opening half of 2026 saw a drop-off in the number of shareholder proposals to reach the ballot, with many proponents changing strategy to include increased engagement. How has the approach changed?

Because of the challenging landscape created by the SEC’s 14M bulletin, which narrowed the scope of what proponents can ask for, many investors opted to try to make progress with companies through dialogue as a more workable approach for this season. For Trillium, we felt it was important to both engage in dialogue, which we normally do, but to continue to use the tools available to us. In the cases where we decided to file, we were careful to craft resolved clauses that adhered to the 14M framework, while still clearly articulating solutions for addressing ESG-related risks.


Trillium recorded 16 new engagements in Q2 with five listed as successful. How do you define and measure success on and off the ballot?

We measure success in a few different ways. If a company takes action as a result of dialogue or a shareholder proposal that we’ve filed, that’s one measure of success. But success can be measured by the outcome of a vote where the tally is high enough to signal broader investor concern about an ESG risk we have surfaced. Sometimes success means our advocacy elevated an issue beyond IR staff to a broader group of company executives. In my case, I work on risks related to climate change, so I want to be in dialogue with the chief sustainability officer. Finally, success is when we get access to the board, which is something that was part of the agreement we struck with BJ’s - we'll now be speaking to a member of the audit committee, which oversees the company’s ESG strategies.


Trillium tested a different approach at BJ's Wholesale Club Holdings. Can you expand on that?

Our shareholder proposal asking BJ’s to accelerate its greenhouse gas reduction efforts was the culmination of a five-year history with the company starting with the commitment it made to us to set a science-based target. Over time, when we saw no progress or movement on cutting emissions, we filed the same proposal in 2026 as we had in 2025, and BJ’s responded by submitting a no-action request. It seemed wholly inappropriate, given the 30% vote of support for the proposal the year before.

Because climate change poses a portfolio-wide risk, and because we wanted other investors to be able to weigh in on the proposal again this year, we considered filing an independent proxy solicitation. We contacted the company on our intention to run a zero-slate proxy solicitation, which would include our original proposal and four good governance proposals. BJ’s pretty quickly reversed course and agreed to pull the no-action letter and put our proposal on the ballot in exchange for our dropping the independent proxy filing. Ideally, we would prefer not to rely on tools like this, but we will certainly consider them under the right circumstances.

In another twist to this story, BJ’s contacted us two days before its annual meeting asking whether we would withdraw our proposal. In the end, we were able to negotiate everything that we had wanted, including monitoring the development of its new sustainability report, and meeting with an audit committee member. We signed the final withdrawal agreement at 4 p.m. the day before the annual meeting.


What were the key focus areas for Trillium when engaging with portfolio companies this season?

Some of the behind-the-scenes successes have come through dialogue, for example, ensuring that companies provide healthcare that covers the needs of trans people.

Sometimes companies aren’t aware that there’s a gap in their policies or practices, and it’s helpful for them to hear from investors, especially if it’s a less obvious risk to them.

Over the last several years, we have asked many companies to publish EEO-1 data, with some notable successes. Despite the current political climate, we continue to feel that gathering this data is important because it provides companies better insight into their labor force and where there might be inequitable patterns that they’re reinforcing. At the very least, keeping data collection mechanisms in place can prepare companies to report to state governments and in the future, the federal government.

On the environmental side, for many years, Trillium has focused on toxic chemical management, particularly among consumer goods companies. We’ve observed that concern about exposure to toxic chemicals is an area of bipartisan concern. Overall, we just continue engage on the areas where we see ESG-related risks, because they remain risks regardless of the political environment. Climate has obviously become a hot potato but, in my experience, no company is denying that is an ongoing and burgeoning risk.

Bottomline: in our advocacy work, we try to ask for things that are common sense, such as at Alphabet, where I asked the company for greater disclosure on its climate transition plans. We all understand that AI is pushing everything forward at light speed, but many targets were made prior to this huge explosion. The same is true of Microsoft.


On climate, it is argued by some that many climate-focused shareholder proposals are overly prescriptive or have already been addressed to some degree. What’s your view?

I think there are a few proposals that could be described as prescriptive. However, I would counter that part of what we're seeing in this moment began about four years ago with pressure on institutional investors, blacklisting, lawsuits against the proxy advisors, who are now collectively being extremely cautious. As a result, supportive votes had been trending down, in my opinion, out of fear.

I describe smaller values-aligned investors like us as the antennae for risks that the larger investors may not be picking up on. We're putting forward proposals that may be uncomfortable for companies, and maybe some are too prescriptive for some.

But then other institutional investors can come in behind us and say to companies, "what are you doing about risks?" Yes, maybe we get a low vote, especially on first-year proposals, but by having them on the proxy and by meeting with investors and the proxy advisors prior to our votes, it's creating greater awareness.


The SEC has recently confirmed its withdrawal from the no-action relief process. It has also clearly flagged its concerns regarding the rules governing shareholder proposals. Without such a tool, how are investors likely to have their voices heard?

We will likely see more votes against directors, against executive compensation, and even against auditors, but also likely more lawsuits and perhaps more independent proxy solicitations. I think smart companies are the ones that continue the dialogue and seek withdrawal agreements or just put proposals on the ballot. The companies that are excluding the proposals are creating reputational risk, legal risk.

Companies don't love shareholder proposals and that's partly why they have been an effective tool. Essentially, we're surfacing issues that they don't want to address through normal channels.


What's at the top of the agenda for Trillium for the next season?

We're always assessing the most effective ways to conduct our advocacy, whether that's dialogue or other means. We will continue to file shareholder proposals. That's not going to stop until we no longer have them, which I hope will not happen. No matter what, we're always innovating.