ARTICLE 23 Feb 2024

Investors Exit Climate Action 100+

What's Next for Investor Climate Commitments

In a significant shift,  prominent investors – BlackRock, JP Morgan Asset Management (JPMAM), and State Street Global Advisors (SSgA) – withdrew from Climate Action 100+. These exits, announced simultaneously on Feb 16, come just ahead of the initiative’s Phase 2 rollout, marked by increased demands for signatories to take assertive actions in stewarding investee emissions, and ultimately casts a shadow on how investors will engage on today’s hottest topic, climate change. 

Investor Rationale for Departure


Transferred membership to its international arm, citing that Phase 2 commitments "across our assets under management would raise legal considerations, particularly in the US", where money managers are required act solely in client's long-term economic interest. 

State Street Global Advisors

"The enhanced CA100+ Phase 2 requirements for signatories will not be consistent with our independent approach to proxy voting and portfolio company engagement"

J.P. Morgan

The investor made "significant investment" in its own stewardship team. "Given these strengths and the evolution of its own stewardship capabilities, JPMAM has determined that it will no longer participate in CA100+ engagements"


What is Climate Action 100+?

Climate Action 100+ (CA100+) is a leading climate-focused investor initiative comprising +700 investors across 33 markets. CA100+ stewards  systemically important corporate emitters, with the overarching objective to achieve clear commitments to cut emissions and strengthen climate-related governance/disclosures. 

The initiative has entered its Phase 2, running until 2030. Key changes are:

  • Renewed goals: CA100+ has strengthened its focus on implementation, prioritizing board accountability and transition plans.
  • Enhanced requirements for lead investors: Lead investors will be required to prepare a year-ahead engagement plan and conduct an engagement progress review.  
  • Phase 2 focus list: The focus list has been updated, with 13 new companies added and 10 companies removed. The focus list was reviewed using the latest CDP data, focusing on top emitters. Other considerations include sector expertise, investor interest in engaging the company, and potential for engagement impact.
  • Net Zero Company Benchmark updates: The updated framework, which consists of Disclosure Framework Indicators and Alignment Assessments, emphasizes emissions reductions, alignment with the 1.5°C pathway, and robust transition plans.

How did Stakeholders React to the News?

From “victory laps” (Fox News) to calling the departure “smacks of cowardice ” (Rebecca Kowalski), market reaction was certainly nuanced. Dissecting the responses by stakeholder groups…

  • Asset Owners: despite their public disappointments, executives of Brunel Pension Partnership, Church of England Pensions Board, PKF were “delighted by BlackRock International’s resolve to hold firm in continuing to support CA100+”.
  • Politicians: whilst not representative of their entire political party, several Republican leaders labelled the exit as “big wins for freedom” (Jim Jordan), and that “investment firms should only consider the economic value of investments” (Patrick Morrisey) and “need every asset management firm to follow suit” (Austin Knudsen). Several Democrats opposed this view, “by caving into the demands of right-wing politicians (…) financial institutions are failing in their fiduciary duty” (Brad Lander).
  • Other Industry Players: nuanced responses, with climate-NGOs (Sierra Club) blaming "political attacks from climate-deniers". However, there are those who saw it coming. “[JPMAM and SSGA’s] voting and engagement record on climate issues has been consistent with this view for much of the last year and a half” (Lindsey Stewart, Director of Investment Stewardship Research, Morningstar), a view echoed by other consultants and investors.

Saw it Coming?

As claimed by several stakeholders, were BlackRock, JPMAM, and SSGA’s departure inevitable? A deeper look at these investors’ voting/engagement records and stewardship policy sourced from AQTION reveals that:

BlackRock 2023 vs. 2024 EMEA Stewardship Policy Changes

  • On inadequate sustainability disclosure/actions, BlackRock will “express any concerns through our voting (…) in light of the materiality of the business risk”
  • “Not the role of BlackRock” to implement “company’s long-term strategy to deliver long-term financial returns” on sustainability
  • “BlackRock encourages companies to use (…) TCFD and (…) ISSB”, instead “long-term investors like our clients can benefit” if disclosure is aligned with TCFD and ISSB
  • Via disclosures, firms should demonstrate that they have a “Sustainable business model” “resilient business model”
  • “It is our view that climate change has become a key factor in many companies’ long-term prospects”

Supporting fewer climate-related shareholder proposals and engaging less on environment with investees were noticeable trends for BlackRock. The stewardship voting policy changes reflect BlackRock’s narrowing of focus to material sustainability risks, with added emphasis of “long-term financial return” being the goal of improving sustainability disclosures/actions.

State Street Global Advisors 2022 vs. 2023 Environmental & Social (E&S) / Voting Policy

  • Holds engagements on E&S topics “relating to the promotion of long-term shareholder value creation”
  • “We use our voice and our vote through engagement (…) to communicate with issuers and educate market participants about our perspective on important sustainability topics.”
  • Term “ESG” replaced with “E&S” or “Sustainability”
  • “Proactively identify companies for engagement”, replaced with “focus on priorities that we consider important to be considered”
  • Established a new section on assessing shareholder proposals, with emphasis of “determination of materiality”

As with BlackRock, SSgA supported fewer climate-related shareholder proposals and engaged less on environment, trends possibly explained by the new voting policy that is less proactive and more selective. “Materiality” and “long-term shareholder value creation” were terms that SSgA felt necessary to include in the new policy. 

J.P. Morgan 2021 vs. 2022 Climate Risk Change Engagement & Voting Report

Note, JPMAM’s voting policy on sustainability remained unchanged.

  • “(…) we express our views through our voting activity, holding boards accountable and supporting resolutions that we feel will support companies toward progress in their climate transition strategies that address financially material risks and opportunities facing such companies”
  • Climate Change Engagement section 11 pages 18 pages, plus new section on Nature Capital and Ecosystems.

Contrary to BlackRock, SSGA, and perception of stakeholders, JPMAM is doubling-down on its climate commitments, in-line with their rationale for departure (“significant investments… (…) of its own stewardship capabilities”). Whilst their voting policy on sustainability remained unchanged, JPMAM’s engagement & voting report evidence increased focus on climate stewardship, further supported by the recent addition of “Nature Capital and Ecosystems” chapter. Nonetheless, the asset manager emphasises that addressing “financially material risks” is the key purpose for climate engagement. 

What does it mean for Companies?

Does BlackRock, SSgA, and JPMAM’s departure from CA100+ mean companies can ignore their climate risk? No! Despite varying reasons for departure, a central message across investors is the increased focus on financial-materiality and long-term value-creation in-relation to climate-risk. Further, these investors will continue to uphold their own climate-stewardship policies, which advocates for good climate-risk related disclosure, governance, and targets. Through AQTION, we summarize these key expectations:



State Street Global Advisors

J.P. Morgan


"Long-term investors like our clients can benefit (...) the International Sustainability Standards Board (ISSB)standards (...). The standards build on the Task Force on Climate-related Financial Disclosures (TCFD) Framework".

State Street Global Advisors finds that the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) provide the most effective framework for disclosure of climate-related risks and opportunities.

"We engage with companies to actively encourage enhanced disclosure of ESG and climate-related data (...) in line with TCFD recommendations".

Science-Based Targets

"Companies disclose short, medium and long-term targets, ideally science based."


"We encourage our investee companies to set science-based net-zero targets, which we view as an integral first step in managing climate risk effectively."

Board Oversight

BIS would like to understand from company disclosure (...) board's oversight of climate-related risks and opportunities (including board mandates, committee responsibility and experience, as applicable)".

"We may take voting action against companies in the S&P 500, S&P/TSX Composite, FTSE 350, STOXX 600, and ASX 200 indices if companies fail to provide (...) board oversight of climate related risks and opportunities, in accordance with the TCFD framework"


Pay Link

"BIS does not have a position on the use of sustainability-related performance criteria, but, in our view where companies choose to include them, they should be as rigorous as other financial or operational targets".

"We are agnostic to companies choosing to include ESG performance metrics in executive compensation structure. However, if used, ESG metrics need to be tied to strategy, quantifiable, sufficiently challenging and incentivize behaviour that is clearly articulated in companies' disclosure".

"We recognize that these metrics have not been used for long, and we  do not yet know what best practices will look like".


Authored by Anais Gaiffe and Chinguun Nyambat