NEPC - 1792 Exchange

Rating Overview

NEPC is Medium Risk.

NEPC is Medium Risk. The company often yields to political activism in shaping corporate governance, potentially alienating consumers, dividing employees, and harming shareholders. The company implements race and identity-based policies that replace merit, excellence, and integrity with preferential treatment and outcomes. NEPC 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	High Risk
Political Actions	No Data

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:

NEPC is a signatory of the Principles for Responsible Investment, incorporating ESG issues into investment analysis, decision-making, and other business practices (1)(2). The company integrates ESG into its business practices. It uses ESG factors in its investment process (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:

NEPC does not appear to discriminate against charitable organizations based on views or beliefs. Its charitable giving focus areas are Movember, Homeless Programs, and American Cancer Society (1).

Criteria:

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

Risk Level:

High

Rationale:

NEPC appears to prioritize diversity over merit in its recruitment, hiring, promotions, and mentorship program. From its 2021 DEI Progress Report: “Launched targeted diversity recruiting across firm” and “We remain committed to investing in diverse talent and are in the process of hiring six new interns for the summer of 2022 program” (1). The company offers gender bias, conscious inclusion, and DEI training to its employees (2). The company appears to prioritize diversity over merit in its business structure through the establishment of gender and racial targets for its investment managers. It is seeking “15% diverse manager representation by the summer of 2024” (3). The company is an affirmative action employer (4). The company 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:

NEPC is a signatory to the CFA Institute’s Diversity, Equity, and Inclusion Code, indicating its support of DEI in its recruitment, hiring, onboarding, and promotions. Furthermore, the company pledges to integrate DEI into its policies, promote DEI in the investment industry, and provide regular reporting on its DEI metrics to the CFA Institute (1)(2)(3). NEPC’s CEO Michael P. Manning signed the CEO Action for Diversity & Inclusion pledge, which includes a commitment to promote DEI through bias education training in the workplace (4)(5). The company supports DEI within its business practices, employing a DEI Board (6). The company hosted an allyship workshop and collaborated with the Cultural Enrichment Group to host an LGBTQ+ Pride watch party and discussion (7). The company hosted an Equitable Manager Participation Workshop (8). It also implemented the Explorer Program which “engage(s) with diverse-owned and -led investment management firms” to put such companies on its focus investment list” (9). The company supports DEI within its business practices, employing a Diverse Manager Committee which identifies and evaluates a potential investment’s DEI strategy (10). It is a founding member of the Institutional Investing Diversity Cooperative which promotes diversity in institutional asset managers (11)(12).

Criteria:

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

Risk Level:

High

Rationale:

NEPC is a partner of Toigo Foundation, IDAC, IIDC, and The Denver Foundation (1). Otherwise, there are no publicly known cases of NEPC using corporate funds to advance ideological causes, organizations, or policies (2)(3).

Criteria:

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

Risk Level:

N/A

Rationale:

NEPC does not operate a PAC or engage in lobbying at this time (1)(2)(3).