State Street Investment Management (formerly known as State Street Global Advisors), which has over $5.6 trillion in assets under management, has published its 2026 Global Proxy Voting and Engagement Policy. State Street also provided a summary of the material changes to the policy, which notes:

The material voting and engagement policy and guideline changes for 2026, which become effective in April 2026, are summarized below.

Engagements with U.S. Issuers

We have included in our publicly-available policy the guidelines State Street Investment Management’s asset stewardship team follows when engaging with U.S. public companies.

Financial Performance

We have systematically embedded financial performance—based on a relative total shareholder return metric—as a factor considered in certain voting policies.

Streamlined Policy for Consideration of Shareholder Proposals

We have streamlined the discussion of the framework we apply when considering shareholder proposals.

With respect to engagement, the State Street policy includes an appendix that sets forth policy guidelines for engagement with portfolio companies that are U.S. public companies. This appendix notes:

As a matter of policy, State Street Investment Management does not seek to influence or change control of any issuer, including U.S. portfolio companies.

When engaging with U.S. portfolio companies, the Asset Stewardship Team may discuss State Street Investment Management’s viewpoints regarding what constitutes best practices supporting effective board oversight of material risks, disclosure of material risks, and shareholder protection consistent with the Policy, including this Appendix A. However, the Asset Stewardship Team will not discuss how it intends to cast its vote on any ballot item, nor its rationale for any vote it has made. Additionally, the Asset Stewardship Team will not dictate or pressure U.S. portfolio companies to adopt or change any policies (including but not limited to policies related to climate, diversity, equity and inclusion, or sustainability) or fundamental business choices like capital allocation. The Asset Stewardship Team will not engage in discussions with U.S. portfolio companies that explicitly or implicitly suggest contingent voting or divestment if a company does not adopt State Street Investment Management’s viewpoint on a particular item, or that suggest that any particular factor, policy or practice is dispositive in making engagement or voting decisions.

All meeting agendas with U.S. portfolio companies are set by the U.S. portfolio company. If requested by the U.S. portfolio company, State Street Investment Management may engage with the company on topics that the U.S. portfolio company has determined to be material to its business, at all times in accordance with the principles set forth in the Policy. However, the Asset Stewardship Team does not discuss, and will remain in listen-only mode during all discussions of, the following topics with U.S. portfolio companies or other investors soliciting State Street Investment Management’s votes in connection with contested shareholder meetings, vote-no campaigns, or shareholder proposals:

– Contested director elections
– Adoption of a climate transition plan
– Adoption of specific targets for emissions reductions
– Scope 3 emissions, including without limitation adoption of a Scope 3 emissions policy, disclosure of Scope 3 emissions, and any reduction of Scope 3 emissions
– Changes to the U.S. portfolio company’s capital allocation

When engaging with U.S. portfolio companies on issues or matters relating to gender, racial or ethnic diversity, the Asset Stewardship Team may discuss State Street Investment Management’s belief that effective board oversight of a company’s long-term business strategy necessitates a board composition with a range of knowledge, expertise, experience, and perspectives. However, State Street Investment Management does not apply, nor will it discuss, specific targets or thresholds of gender, racial or ethnic diversity in connection with U.S. portfolio companies

Consistent with the changes made by Vanguard and BlackRock this years, State Street’s policy reflects a specific focus on financial performance when evaluating the governance matters addressed in the policy. For example, the policy notes:

– “When evaluating board composition, we assess a company’s financial performance relative to its GICS sector (based on a total shareholder return metric) and relevant disclosure.”

– “When evaluating a board’s oversight of risks and opportunities, we assess the following factors, based on various criteria including a company’s financial performance relative to its sector (based on a total shareholder return metric), relevant disclosures by, and engagements with, portfolio companies.”

– With respect to compensation and remuneration, State Street considers “The company’s financial performance relative to its GICS sector, based on a total shareholder return metric.”

On the topic of shareholder proposals, the State Street policy now states:

We believe that company boards do right by investors and are responsible for overseeing strategy and company management. To that end, we do not support shareholder proposals that are on a topic that the company has not determined to be material to its business or that appear to impose changes to business strategy or operations, such as increasing or decreasing investment in certain products or businesses or phasing out a product or business line.

When assessing shareholder proposals, we fundamentally consider whether the adoption of the resolution would promote long-term shareholder value in the context of our core governance principles:

1. Effective board oversight
2. Quality disclosure
3. Shareholder protection

Previously, the State Street policy had gone on to indicate that State Street would consider supporting a shareholder proposal if: (i) the request is focused on enhanced disclosure of the company’s governance and/or risk oversight; (ii) the adoption of the request would protect our clients’ interests as minority shareholders; or (iv) the request satisfied specific criteria that State Street had established for common shareholder proposal topics. The updated policy no longer includes appendices that set forth the criteria used to assess the effectiveness of a company’s disclosure on commonly requested shareholder proposal topics or the criteria for providing support for certain common shareholder proposal topics.

With State Street’s policy, we now have a complete picture of the proxy voting policy changes for the Big Three this year.

– Dave Lynn