Pages 20-22 of Comcast's Proxy Material
PROPOSAL 5: TO REQUIRE A SUSTAINABILITY REPORT
The following proposal and supporting statement were submitted by the General Board of Pension and Health Benefits of the United Methodist Church, 1201 Davis Street, Evanston, IL 60201-4118, which has advised us that it holds 658,209 shares of our common stock.
WHEREAS:
Investors increasingly seek disclosure of companies’ environmental and social practices in the belief that they impact shareholder value. Many investors believe companies that are good employers, environmental stewards, and corporate citizens are more likely to generate better financial returns, be more stable during turbulent economic and political conditions, and enjoy long-term business success.
Sustainability refers to endeavors that meet present needs without impairing the ability of future generations to meet their own needs. According to Dow Jones, “Corporate Sustainability is a business approach that creates long-term shareholder value by embracing opportunities and managing risks deriving from economic, environmental, and social developments. Corporate sustainability leaders achieve long-term
shareholder value by gearing their strategies and management to harness the market’s potential for sustainability products and services while at the same time successfully reducing and avoiding sustainability costs and risks.” (http://www.sustainability-index.com/htmle/sustainability/corpsustainability.html)
We believe that improved reporting on environmental, social, and governance issues will strengthen our company and the people it serves. Furthermore, we believe this information is necessary for making well-informed investment decisions as it speaks to the vision and stewardship of management and can have significant impacts on our company’s reputation and on shareholder value.
Globally, over 2,000 companies produce reports on sustainability issues (www.corporateregister.com). Several telecommunications companies have already produced sustainability or corporate responsibility reports, including AT&T and Verizon.
The GE 2006 Citizenship Report provides a compelling rationale for sustainability reporting: “Investors are increasingly interested in evaluating companies based on a broader set of criteria than just financial performance... The strength of reputation, trust in brand and governance, and the ability to perform as a good corporate citizen, all impact GE’s valuation and shape the perception of the Company’s worth. In fact, according to a recent study, 70% of institutional asset managers believe the Company’s citizenship factors will be part of mainstream analysis in the next 3 to 10 years... GE’s focus is on providing transparent communications relating to the Company’s citizenship performance.”
RESOLVED: Shareholders request that the Board of Directors issue a sustainability report to shareholders, at reasonable cost, and omitting proprietary information, by December 31, 2007.
Supporting Statement
The report should include Comcast’s definition of sustainability, as well as a company-wide review of policies, practices, and indicators related to measuring long-term social and environmental sustainability.
We recommend that Comcast use the Global Reporting Initiative’s Sustainability Reporting Guidelines (“The Guidelines”) to prepare the report. The Global Reporting Initiative (www.globalreporting.org) is an international organization with representatives from the business, environmental, human rights, and labor communities. Over 900 companies use or consult the Guidelines for sustainability reporting.
Company Response to Shareholder Proposal
We recognize the importance of social and environmental practices, as well as economic performance, to our shareholders. We are committed to being a good citizen in all communities in which we operate. Our Board believes that our current policies and practices concerning social, environmental and economic issues already address the concerns behind this proposal, and our current disclosure already provides shareholders with meaningful information regarding several of our activities in these areas.
Our social practices are evident in our community engagement. We are committed to improving the quality of life in local communities where our subscribers and employees live and work. We work with existing local organizations to positively impact each community we serve while using our resources to bring visibility to important local issues. In 2006, our charitable support exceeded $100 million. The Comcast Foundation provided more than $11.2 million in grants to more than 550 local non-profit organizations and other charitable partners across the country. In addition, more than $90 million of in-kind contributions (mostly in the form of televised public service announcements) and $2.0 million in corporate contributions were distributed to more than 180 organizations. To maximize our impact, we focus our community investment efforts in four important areas where we believe that we can make the most significant and measurable impact: youth leadership, volunteerism, diversity and literacy. For more information on our commitment to community investment, please review the “In the Community” section of our Web site at www.comcast.com.
We believe that our conduct and reputation are among our best assets. We are committed to the practice of good ethics and conduct among our officers, directors and employees. In that regard, we maintain our code of ethics and business conduct which represents the core of our business philosophy and values and which defines how the company conducts itself. All of our officers, directors and employees are expected to carefully read and adhere to the policies set forth in our code of ethics and business conduct, which we invite shareholders to review in the “Governance” section of our Web site at www.cmcsa.com or www.cmcsk.com. Our code of ethics and business conduct covers many sustainability issues, including such topics as Compliance with Laws, Privacy, Non-Discrimination, Equal Opportunity and Non-Harassment, Environment, Health and Safety and more.
Given the nature of our services-oriented businesses, as opposed to, for example, a manufacturing business, environmental practices do not play a significant role in our operations. Nonetheless, we are committed to conducting our businesses in compliance with all applicable environmental laws and regulations, and we strive to avoid adverse impact and injury to the environment and to the communities in which we conduct business. We believe in reducing greenhouse gases and are reviewing the use of fuel efficient vehicles, energy efficient emergency generators and energy efficient appliances and devices at our facilities. Our new corporate headquarters, which we plan to move into beginning in the fourth quarter of 2007, hopes to achieve a “Leadership in Energy and Environmental Design” certification from the U.S. Green Building Council.
The Board believes that our track record demonstrates that, wherever we operate, we work hard to be a good corporate citizen and to promote social, environmental and economic issues. Therefore, the Board believes that conducting a special review on social, environmental and economic issues and preparing a sustainability report for shareholders is unnecessary and would not be an effective use of our resources. The time and expense involved in preparing such a report would detract from our focus on our business and operations and would not be in the best interests of our shareholders.
FOR THESE REASONS, OUR BOARD UNANIMOUSLY RECOMMENDS THAT SHAREHOLDERS VOTE “AGAINST” THIS PROPOSAL.
