D2L - 1792 Exchange

Rating Overview

D2L is Medium Risk.

D2L is Medium Risk. The company often yields to political activism in shaping corporate governance, potentially alienating consumers, dividing employees, and harming shareholders. D2L implements race and identity-based policies that replace merit, excellence, and integrity with preferential treatment and outcomes. The company occasionally embraces corporate initiatives that redirect its central focus from business goals to partisan policies and divisive issues at times. This approach fails to safeguard free exercise, free speech, and free enterprise.

Rating Criteria

Corporate Weaponization Risk Levels
Criteria	Risk Level
Cancellations	Medium Risk
Discriminatory Philanthropy	Lower Risk
Employment Protection	High Risk

Corporate Weaponization ⓘ

Corporate Governance and Public Policy Risk Levels
Criteria	Risk Level
Advocacy Bias	High Risk
Funding	Lower Risk
Political Actions	Lower Risk

Corporate Governance and Public Policy ⓘ

Rating Criteria Detail

Criteria Risk Level Rationale

Corporate Weaponization

Criteria:

Has canceled customers, suppliers, or vendors due to their political views or religious beliefs OR corporately boycotts, divests, or sanctions regions, people groups, or industries.

Risk Level:

Medium

Rationale:

D2L integrates ESG into its business practices. From its FY23 ESG Report: “senior leaders contribute to the development and implementation of our approach to ESG… who play integral parts in the implementation and oversight of ESG at D2L” (1). The company integrates ESG into its business practices. From its FY23 ESG Report: “We drive change through our supply chain by communicating with our supply chain
actors on the importance of ESG issues and the expectations we hold of suppliers to
be thinking about and working to lower their own impacts” (2). D2L has a history of divisive corporate policies and practices. However, in June 2026, the company removed ESG language from its FY26 Sustainability Report. To date, the company has not publicly addressed this change, leaving shareholders without clarity regarding the company’s reasoning or future direction (3). However, the company has not publicly canceled customers, suppliers, or vendors based on political views or religious beliefs (4).

Criteria:

Charitable giving (including employee matching programs) policies or practices discriminate against charitable organizations based on views or religious beliefs.

Risk Level:

Lower

Rationale:

D2L does not appear to discriminate against charitable organizations based on views or beliefs (1).

Criteria:

Employment policies fail to protect against viewpoint or other discrimination and/or are ideological in nature.

Risk Level:

High

Rationale:

D2L requires its employees to take unconscious bias and DEI training (1). The company appears to prioritize diversity over merit in its supply chain. From its FY23 ESG Report: “D2L maintains a Supplier Diversity Policy to promote procurement from businesses
owned by individuals identifying as Black, Indigenous, People of Colour (BIPOC),
Women, or disabled veterans” (2). D2L appears to prioritize diversity over merit in its recruitment. From its FY23 ESG Report: “We believe DEIB strengthens innovation and
is pivotal in continuing to build great products,
solve important problems and better serve the
needs of our global customers. We are working
to continue to advance diversity efforts with
specific initiatives. Recruitment. We are working to combat
implicit and unconscious bias in our recruitment
processes” (3). The company has a history of divisive corporate policies and practices. However, in June 2026, the company removed DEI and training policies from its FY26 Sustainability Report. To date, the company has not publicly addressed these changes, leaving shareholders without clarity regarding the company’s reasoning or future direction (4). D2L does not provide viewpoint protections for its employees (5)(6).

Corporate Governance and Public Policy

Criteria:

Uses corporate reputation to support causes, organizations, or policies hostile to freedom of expression.

Risk Level:

High

Rationale:

D2L supports DEI within its business practices. From its FY23 ESG Report: “Our team continuously reviews our People
policies, programs, and processes from
a DEIB lens so that our policies embed
belonging and do not pose barriers to any of our employee groups” (1). The company supports ESG within its business practices. From its FY23 ESG Report: “Our CGN Committee oversees the ESG program at D2L and
is responsible for supporting the Board on matters such as the
evaluation of the effectiveness, competencies and skills of directors” (2). D2L has a history of using reputation to support divisive practices. However, in June 2026, the company removed DEI and ESG language from its FY26 Sustainability Report. To date, the company has not publicly addressed these changes, leaving shareholders without clarity regarding the company’s reasoning or future direction (3).

Criteria:

Uses corporate funds to advance ideological causes, organizations, or policies hostile to freedom of expression.

Risk Level:

Lower

Rationale:

D2L has not used corporate funds to advance ideological causes, organizations, or policies (1).

Criteria:

Uses corporate political actions and/or financial contributions for ideological, non-business purposes.

Risk Level:

Lower

Rationale:

D2L does not operate a PAC at this time and has not used its lobbying for ideological purposes (1)(2)(3).