David Brook is an individual shareholder with a focus on environmental, social, and governance (ESG) issues who uses corporate engagement to promote a left-of-center environmental agenda. Brook is a shareholder of Lowe’s, Home Depot, and FMC Corp, and has been submitting resolution proposals since 2011. ¹

The shareholder proposals that Brook has submitted are directly associated with environmentalist issues such as climate change and include resolutions asking for storm-water management policies, annual “sustainability” reports, and setting environmentalist energy targets. ²

Shareholder Engagement

Storm Water

David Brook submitted shareholder proposals to Home Depot in 2012 and 2013, each time requesting that the board of directors adopt a storm-water management policy. In each case, the proposal includes demands such as a storm-water management report from each Home Depot location, identification of all Home Depot operations that may generate contaminated storm-water, and implementing unnamed “best management practices” for all potential sources of contaminated storm-water. The resolution received a 4.4% vote in 2013,³ and a 3.6% vote in 2012. ⁴ Prior to this, in 2011, Brook submitted an almost identical shareholder proposal to Lowe’s, which was omitted from Lowe’s proxy vote in 2011. ⁵

“Sustainability”

Between 2012 and 2016, Brook focused on shareholder resolutions asking companies to publish annual environmentalist “sustainability” reports.

In 2012, Brook submitted a proposal to the FMC Corporation, requesting that the board provide a sustainability report, and continue to do so annually. In so doing, the proposal requests that the report define FMC’s definition of sustainability, in terms of the company’s policies and practices as related to human health and rights, wildlife, and the environment. The proposal was withdrawn, as FMC committed to providing this annual report. ⁶

In 2015, Brook submitted sustainability proposals to both Lowe’s and Home Depot, requesting annual reports showing the “short-and long-term responses to ESG-related issues.” ⁷ The proposals both specifically ask for company climate change policies and goals relating to greenhouse gas emissions, energy efficiency, human rights, and other environmental and social impacts. The proposal cites the Global Reporting Initiative’s (GRI) Sustainability Reporting Guidelines as a reference point. In both cases, the proposals were withdrawn, as both companies committed to providing these reports. ^{8 9}

In 2016, Brook submitted another sustainability proposal to Lowe’s, nearly identical to the previous proposal that Lowe’s committed to in 2015. Brook’s 2016 proposal claims that Lowe’s ESG reporting does not adequately meet the demands of the prior resolution. ¹⁰ In this case, Lowe’s presented an opposition letter defending the company’s reporting of its sustainability efforts in its “Social Responsibility Report,” and argues that a stand alone social responsibility report is not an effective use of the company’s resources. ¹¹ The proposal received a 7.5% vote. ¹²

Energy Policy

In 2017, Brook submitted a shareholder proposal to Lowe’s, asking the company to set environmentalist energy targets in response to climate change. The proposal asks for an assessment report, with specified time-bound environmentalist energy goals, and their potential resulting climate benefits. Brook’s resolution purports that providing a report with quantitative goals will help reduce greenhouse gas (GHG) emissions and directly address climate change. It also goes on to commend Lowe’s for its role in promoting solar panels to homeowners, and the company’s effort to use more efficient lighting for their stores, but then condemns them for not going further. The proposal received a 6.9% vote. ¹³

1. “Engagement Tracker.” Ceres, 2016. Accessed December 1, 2019. https://engagements.ceres.org/.
2. “Engagement Tracker.” Ceres, 2016. Accessed December 1, 2019. https://engagements.ceres.org/.
3. “Adopt Stormwater Management Policy (HD, 2013 Resolution).” Ceres, 2016. Accessed December 1, 2019. https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0lA00000045PwdIAE.
4. “Adopt Stormwater Management Policy (HD, 2012 Resolution).” Ceres, 2016. Accessed December 1, 2019.  https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0lA0000003A4tOIAS.
5. “Adopt Stormwater Management Policy (LOW, 2011 Resolution).” Ceres, 2016. Accessed December 1, 2019.   https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0l1H00000C4YIgQAN.
6. “Publish Sustainability Report (FMC, 2012 Resolution).” Ceres, 2016. Accessed December 1, 2019. https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0lA0000002qHrQIAU.
7. “Publish Sustainability Report (HD, 2015 Resolution).” Ceres, 2016. Accessed December 1, 2019. https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0l1200000BKbFTAA1.
8. “Publish Sustainability Report (HD, 2015 Resolution).” Ceres, 2016. Accessed December 1, 2019. https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0l1200000BKbFTAA1.
9. “Publish Sustainability Report (LOW, 2015 Resolution).” Ceres, 2016. Accessed December 1, 2019.  https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0l1200000BKbGMAA1.
10. “Publish Sustainability Report (LOW, 2016 Resolution).” Ceres, 2016. Accessed December 1, 2019.   https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0l1H00000C4Ur0QAF.
11. “Notice of Annual Meeting and Proxy Statement.” Lowes, May 27, 2016. Accessed December 1, 2019. https://lowes.gcs-web.com/static-files/978306ec-d4ee-4795-8b0b-3d4566082085.
12. “Publish Sustainability Report (LOW, 2016 Resolution).” Ceres, 2016. Accessed December 1, 2019.   https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0l1H00000C4Ur0QAF.
13. “Set Renewable Energy Targets (LOW, 2017 Resolution).” Ceres, 2016. Accessed December 1, 2019.   https://engagements.ceres.org/ceres_engagementdetailpage?recID=a0l1200000BmT1vAAF.