Norwegian Cruise Lines - 1792 Exchange

Rating Overview

Norwegian Cruise Lines is Medium Risk.

Norwegian Cruise Line Holdings Ltd. (NCL) 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. Norwegian Cruise Lines 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	Medium 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:

NCL integrates ESG into its business practices. From its 2022 ESG Report: “Tied ESG to compensation adding ESG as a component of our 2022 and 2023 short-term incentive program” (1). In 2024, NCL rebranded its ESG policy & language as Sustainability; however, it remains unclear whether the underlying divisive corporate policies/practices materially changed following the rebrand (2).
However, the company has not publicly canceled customers, suppliers, or vendors based on political views or religious beliefs (3).

Criteria:

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

Risk Level:

Lower

Rationale:

NCL does not appear to discriminate against charitable organizations based on views or beliefs (1)(2).

Criteria:

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

Risk Level:

High

Rationale:

NCL offers DEI training to its employees (1). NCL appears to prioritize diversity over merit in its leadership composition. From its Corporate Governance Guidelines: ” The Board is committed to seeking out candidates with diverse backgrounds, viewpoints, experiences and skills, which may include women and minority candidates, as part of each Board search the Company undertakes” (2). NCL operates a supplier diversity program. “We maintain strong and collaborative relations with our global suppliers to continuously find new ways to source responsibly and make our supply chain more diverse and sustainable” (3). However, in 2024, the company removed DEI training, language, and policies from its 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). NCL 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:

Sixthman, a subsidiary company of NCL, joined the ATL Action for Racial Equity in 2021 (1). The company’s CEO, Harry Sommer, signed the CEO Action for Diversity & Inclusion pledge, which includes a commitment to promote DEI through bias education training in the workplace (2)(3). NCL is committed to net zero emissions by 2050 (4). NCL supports DEI within its business practices. from its 2023 Sustainability Report: “Our Company is committed to fostering an inclusive workforce, where diverse backgrounds are appreciated” (5). NCL supports ESG within its business practices. From its 2022 ESG Report: “Our environmental, social and governance (ESG) strategy is focused on five pillars, prioritizing efforts that meaningfully serve both our business and our stakeholders” (6).

Criteria:

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

Risk Level:

Medium

Rationale:

NCL partners with the Florida Diversity Council and sponsored its 2022 LGBTQ+ Summit (1). Otherwise, there are no publicly known cases of the company using corporate funds to advance ideological causes, organizations, or policies (2).

Criteria:

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

Risk Level:

Lower

Rationale:

NCL does not operate a PAC or report on its lobbying at this time (1)(2)(3).