Introduction

We believe in the inherent dignity and the equal and inalienable rights of all members of the human family as the foundation of freedom, justice, and peace in the world. Systemic racism is a persistent affront to those beliefs.

The UN Guiding Principles on Business and Human Rights state:

“Business enterprises should respect human rights. That means that they should avoid infringing on the human rights of others and should address adverse human rights impacts with which they are involved.” ¹

We agree and therefore join the growing tide of businesses committed to eliminating racial injustice. We will take responsibility for, and where necessary, take action to address our impact on racial justice across our portfolios, firm and global community.

Our Racial Justice Action Plan is built in context of the dual roles we serve in our society – as investors and as a business. Our impacts primarily occur through our investments; however, our firm’s nexus to racial justice is an area for potential human rights impact that we seek to recognize and address here. We recognize that the system is not external to us, we are of it, affecting it and affected by it.

As a founding signatory of the UN Guiding Principles, we use that human rights framework to guide our development of the plan and our planned actions.

Section I. As Investors

Actions and Goals

As an organization, our greatest leverage point for influence on racial justice is as investors. Domini has had leading human rights standards and practices in our investment processes since our inception. As a respected and long-standing impact investor, our voice has the potential to impact the corporation globally, as well as the financial community. As such, we will work to redouble our commitment to human rights by taking more explicit and focused action on systemic racism. We have used our tools of standards, engagement and community investing to help support and promote diversity and justice.

The following documents our plan of actions and the goal we seek to achieve as well as providing historical context of our past work:

Review Domini’s Impact Investment Standards (“Standards”) to integrate racial equity into our Global Community theme. These standards are core to the investments we make. Inclusion of our commitment to racial justice in our Standards will provide better communication and greater transparency to our investors and the financial community.
Adopt diversity and inclusion as a universal key performance indicator across all industries and consider additional or amended KPIs that explicitly address issues of systemic racism as guided by our processes.

Goal: Elevate diversity considerations in our decision-making across all industries.

History

Domini has consider diversity as a core tenant of a well-managed, forward-looking company since its inception. Since 2005, Domini’s Impact Investment Standards have incorporated several themes to promote diversity and protect marginalized communities. We have included the rights of indigenous peoples and expect companies and issuers to ensure indigenous communities have free, prior and informed consent (FPIC) and to recognize their right to self-determination. We have sought and invested in fixed income investments in communities and regions that have historically been deprived to support necessary infrastructure such as healthcare, education, sanitation, and transportation. We have been a voice at the table for environmental justice for at risk populations.

We have considered diversity on boards, executive management teams and workforce as a positive indicator particularly in certain industries such as banking and media. Domini has informally implemented diversity as our singular universal KPI since 2018 and formalized this position in late 2020. In addition, we have existing KPIs that are industry-specific and capture many issues related to systemic racism, e.g. predatory lending or community health impacts, even without specific reference to race.

In 2019, Domini formalized its practice of excluding private prison operators. We have never invested in publicly traded companies involved in for-profit prison and immigration detention operations due to the serious civil and human rights abuses that occur, particularly for marginalized communities, when operated to extract profit rather than as a public good.

We will engage companies on diversity disclosure in regions where the data collection is permitted by law.
We will engage on workforce equity issues, on worker-driven solutions, on related disclosures, and other issues related to systemic racism as they arise.
In all engagements, we will apply a racial justice lens, seek to center affected communities and look to those communities for guidance and leadership.
Maintain industry leading proxy voting guidelines on issues of diversity and racial justice

Goal: Stimulate disclosure and respond to the data.

History

We believe that gender and racial diversity on boards helps to mitigate governance risks and promote a more equitable workplace. Companies with diverse leadership are more likely to better understand customer needs, anticipate new societal trends and emerging issues, and foster cooperation with their workforce and communities. Having diverse leadership also helps deter discriminatory practices and fosters a culture of tolerance and inclusiveness throughout an organization.

Throughout our history, Domini has engaged companies to promote diversity in company management through letter writing campaigns, shareholder proposals, company dialogues, and voting our proxies. In addition to our dedication to improving gender diversity, we are also committed to promoting racial diversity on corporate boards.

In 2019, we adopted a new proxy voting standard for diversity on boards. The Domini Funds now oppose the election of some or all directors where women make up less than 40% or at least three members of the board (whichever is greater). We apply the same standards for historically underrepresented ethnic and racial groups in markets where the information is available.

Invest in Community Development Financial Institutions (CDFIs) and bonds created to finance and promote a more just economy for Black, Indigenous and People of Color (BIPOC) communities.

Goal: Fill capital gaps left by traditional finance.

History

Launched in June 2000, the Domini Impact Bond Fund has sought investments help build healthy vibrant by addressing three key goals: to increase access to capital for those historically underserved by the mainstream financial community, create public goods for those most in need, and fill capital gaps left by current financial practice. We seek to support access to affordable and quality housing, health care, education, jobs, transportation, energy, water, financial services, and other critical resources. Through fixed-income investments, we believe we can contribute to the sustainability of communities and help foster economic opportunity for generations to come.

By placing deposits with CDFIs, we help channel money to projects in low-income neighborhoods and regions of great need. We also conduct our own corporate banking with a CDFI based in Arkansas.

“As an Investor” Assessment

We refer to the guidance laid out by the Investor Alliance for Human Rights in the “Investor Toolkit on Human Rights.”² As per the toolkit, it has “…a primary focus on investment activities, the Toolkit’s viewpoint is for equity ownership investments in both public and private companies, as well as both active and passive investment strategies.” With its investment-centric approach, we use it to report on our progress in our “As Investors” section of this report.

The following assessment is consistent with the “Toolkit Annex” included in the guide:

✔ Approved at the most senior level of the institution

The Domini Standards Committee, which is comprised of Domini’s most senior-level social and environmental expertise, is responsible for the Domini Standards and engagement activities.

✔ Informed by relevant expertise

Informed by human rights expertise on our staff
Worked with external consultant

☐ Describes expectations of relationships

Expand our human rights expectations in Domini Impact Investment Standards

✔ Communicate publicly and actively, internally and externally

Publish on Domini website and share on social media
Disseminate detailed plan internally containing information such as responsible party, timeline and budget

✔ Embedded throughout the business, including within other policies and procedures

Plan covers Domini overarching standards, detailed key performance indicators used in investment selection and engagement to hold companies and issuers accountable

✔ Approach is grounded in the institution’s policy commitment and embedded into governance systems

Policy commitment integrated into Domini Impact Investment Standards (see Tool #1 above).

✔ Allocation of responsibility and accountability is assigned to specific functions

Domini’s internal documents specify parties responsible, timeline and budget

✔ Ultimate responsibility and accountability for implementation assigned to senior leadership

Senior Domini leaders developed our “As an Investor” actions and goals and will monitor progress bi-annually

✔ Board of Directors has oversight of and receives regular updates on implementation of the policy commitment from senior management

Domini reports updates to our Domini Impact Investment Standards to the Domini Funds Board of Trustees

✔ Resources are allocated for implementation of commitment

Domini’s internal documents specify parties responsible, timeline and budget

✔ Capacity building takes place across all functions

Domini’s senior staff provide training to research and engagement

✔ Clear procedures for selection, engagement, oversight, and review of all business partners (e.g., portfolio companies, consultants, and other service providers)

Domini’s Standards and Key Performance Indicators provide clear procedures for selection and Domini’s 2021 Engagement Plan provides specific actions.

Not applicable as Domini Impact Investments is an asset manager

✔ Provide a summary of the company’s disclosed human rights policies and processes, as well as key gaps in the implementation of the corporate responsibility to respect human rights.

Domini maintains a proprietary database to maintain all data collected on a company’s social and environmental performance as directed by its subindustry key performance indicators. Diversity is a universal key performance indicator; additional metrics to be considered.

Section II. As a Business

Actions and Goals

As a business, Domini has always appreciated the value of diversity and racial equity. In fact, it is integral to creating a product that our investors want. Environmental and social research depends on having non-traditional voices involved in assessing corporate impacts.

However, we are now adopting several policies and practices to more intentionally increase diversity on our team. (Note: BIPOC refers to Black, indigenous and people of color).

Revamp job searches to include BIPOC-specific job postings to enhance representation of BIPOC candidates and new hires.
Establish relationships with HBCUs and schools with diverse student bodies to post entry-level job postings.
Seek to interview at least one BIPOC candidate for every job opening
Communicate commitment to being an equal opportunity employer in job postings

Goal: Increase BIPOC representation on Domini’s workforce.

History

With an understanding of the advantages diversity brings, Domini’s team has historically had racial and gender diversity higher than that of our financial industry peers.

Domini’s employment policies and procedures have historically included a commitment to being an equal opportunity employer and treating all employees fairly without regard to age, ethnicity, physical disability, national origin, race, religion, sexual orientation, actual or perceived gender identity or expression (including the status of being transgender), or any other characteristic protected pursuant to applicable federal, state or local law. Domini also prohibits discrimination and harassment in the workplace and maintains a no retaliation policy for filing or cooperating with an investigation of such complaints.

We estimate the diversity of our team members to be as follows:

Swipe to view table

Diversity	Current	5-year average	10-year average
BIPOC	14.3%	15.3%	15.9%
White	85.7%	84.7%	84.1%

Conduct firm-wide anti-racism training regularly
Conduct team voluntary diversity survey to measure workforce diversity
Conduct compensation study to assess pay equity
Recognize and celebrate BIPOC history, culture and influence

Goal: Build a multi-cultural community

History

Domini’s office was intentionally designed by our Founder and Chair, Amy Domini, with personally selected art and memorabilia from the southern hemisphere to celebrate cultural diversity and to serve as a reminder of our global community.

In 2020, Domini added Juneteenth (June 19th) to our paid holiday calendar to recognize and celebrate the emancipation of those who had been enslaved in the United States.

Engage new and existing suppliers, consultants and other business partners on their own diversity and equity policies, leadership, and racial justice impacts

Goal: Stimulate disclosure and respond to the data.

History

In the past, Domini has relied on our in-house ESG research when doing business with a publicly traded companies and, when possible, sought engaged with only those that were considered eligible for investment.

Build best practices across all communication channels such as:

Use of appropriate language and imagery
Diversity requirement for Domini participation on all conference panels

Goal: Reflect our commitment to racial inclusion, diversity and respect

History

Domini has informally reviewed materials with a lens of racial and ethnic sensitivity and sought to use imagery that is culturally diverse.

Integrate risk assessment related to systemic racism

Goal: Detect and prevent systemic bias

“As a Business” Assessment

For our “As a business” section, we again turn to the “Investor Toolkit for Human Rights.” We use relevant items of tools #1 and #2, which are related to policy and governance, to assess our plan and actions.

✔ Approved at the most senior level of the institution

Our “As a Business” Actions and Goals have been approved by our most senior executives.

✔ Informed by relevant expertise

Informed by human resources and human rights expertise on our staff
Worked with external consultant

✔ Describes expectations of relationships

Our “As a Business” Actions and Goals provide clear, concrete description of expectations

✔ Communicate publicly and actively, internally and externally

Publish on Domini website and share on social media
Disseminate detailed plan internally containing information such as responsible party, timeline and budget

☐ Embedded throughout the business, including within other policies and procedures

To be integrated into Domini’s Employee Manual
Domini procurement guide to be created

✔ Approach is grounded in the institution’s policy commitment and embedded into governance systems

Policy commitment integrated into Domini Impact Investment Standards (see Tool #1 above).

✔ Allocation of responsibility and accountability is assigned to specific functions

Domini’s internal documents specify parties responsible, timeline and budget

✔ Ultimate responsibility and accountability for implementation assigned to senior leadership

Senior Domini leaders developed our “As a Business” actions and goals and will monitor progress bi-annually

✔ Board of Directors has oversight of and receives regular updates on implementation of the policy commitment from senior management

Domini’s Operating Agreement Managers have participated and overseen the development of our “As a Business” Plan and will receive regular updates

✔ Resources are allocated for implementation of commitment

Domini’s internal documents specify parties responsible, timeline and budget

✔ Capacity building takes place across all functions

Domini will conduct firmwide training and seek additional training where needed

N/A - Clear procedures for selection, engagement, oversight, and review of all business partners (e.g., portfolio companies, consultants, and other service providers)

Not applicable to “As a Business” section

Learn more about our beliefs and objectives Read more about our Impact Investment Standards

Domini Impact Equity Fund ℠

Domini Impact International Equity Fund ℠

Domini Impact Bond Fund ℠

Domini Sustainable Solutions Fund ℠

Domini’s Commitment to Racial Justice

Introduction

Section I. As Investors

Actions and Goals

“As an Investor” Assessment

Section II. As a Business

Actions and Goals

“As a Business” Assessment