ESG Engagement

TCI is in the process of submitting shareholder resolutions (where possible) requesting that its portfolio companies disclose their current greenhouse gas emissions in a manner consistent with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), including their emission reduction strategy and progress made in their reduction strategy. TCI is also requesting that all shareholders be given a non-binding advisory vote in respect of such matters at annual meetings.

To date, TCI has filed resolutions in respect of the following companies:

  • Canadian Pacific Railway
  • Canadian National Railway
  • Moody’s Corp
  • S&P Global
  • Union Pacific Railroad (See below in relation to the SEC)
  • Charter Communications
  • Alphabet Inc.
  • AENA (resolution passed)

ESG Engagement Letters

U.S. Securities and Exchange Commission (SEC)

The SEC have rejected Union Pacific’s attempt to exclude our resolution on technical grounds.

Company that submitted the reasons for excluding the proposal.
Shareholder that submitted the proposal to the company.
Date of company's initial submission.
Regulatory bases asserted by company to exclude the proposal.
Staff's response to the company's request.
Date of staff's response.
Did the staff respond by letter?
Union Pacific Corporation The Children’s Investment Master Fund






James McRitchie
1/15/2021 Rule 14a-8(b)/(f)
Rule 14a-8(c)
Rule 14a-8(i)(11)
Unable to concur that Rule 14a-8(c) provides a basis to exclude (The Children's Invesment Master Fund)

Concur that Rule 14a-8(i)(11) provides a basis to exclude (James McRitchie)
3/22/2021 No