The Howard Hughes Corporation Inc.

Rating Overview

The Howard Hughes Corporation Inc. is Medium Risk.

The Howard Hughes Corporation 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. 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	High 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	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:

The Howard Hughes Corporation integrates ESG into its business practices. From its 2022 Communities Report: “Executive pay is tied tofinancial metrics and strategic goals, including ESG and DEI” (1). The company integrates DEI into its supply chain. From its Supplier Code of Conduct: “Treating people with respect and dignity, actively fostering diversity of thought and background, and creating equitable opportunities for
employment are critical aspects of Howard Hughes’ culture. Suppliers are encouraged to contribute to a culture of inclusive productivity” (2). The Howard Hughes Corporation has a history of divisive corporate policies and practices. However, in 2024, the company removed ESG policies from its 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 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:

High

Rationale:

The Howard Hughes Corporation will not match employee donations to “religious institutions deemed
as houses of worship” (1).

Criteria:

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

Risk Level:

High

Rationale:

The Howard Hughes Corporation appears to prioritize diversity over merit in its leadership composition. From its Diversity Policy: “With regard to diversity, the Company is committed to considering candidates for the Board regardless of gender, ethnicity and national origin. Any search firm retained to assist the Committee in seeking candidates for the Board will affirmatively be instructed to seek to include diverse candidates from traditional and nontraditional candidate groups” (1). The company does not provide viewpoint protections for its employees (2).

Corporate Governance and Public Policy

Criteria:

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

Risk Level:

High

Rationale:

The Howard Hughes Corporation’s CEO David R. O’Reilly signed the CEO Action for Diversity & Inclusion pledge, which includes a commitment to promote DEI through bias education training in the workplace, strategize on DEI programs/initiatives with other signatories, and engage boards of directors when developing and evaluating DEI strategies (1)(2). The company is aligned with the Paris Agreement, which entails a commitment to net zero carbon emissions by 2050 (3). The Howard Hughes Corporation supports DEI within its business practices. From its 2022 Communities Report: “Diversity, Equity, and Inclusion are essential to our success as a company and we strive to source, engage,
and retain diverse and talented people, partners, residents, and suppliers” (4). The company supports ESG within its business practices. From its 2021 Annual Report: “With the publication of our fourth-annual ESG Report, we reinforced our commitment to ESG best practices in alignment with the United Nations’ Sustainable
Development Goals” (5). The Howard Hughes Corporation has a history of divisive corporate policies and practices. However, in 2024, the company removed DEI and ESG language and policies from its 2025 Annual Report. To date, the company has not publicly addressed these changes, leaving shareholders without clarity regarding the company’s reasoning or future direction (6).

Criteria:

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

Risk Level:

Lower

Rationale:

The Howard Hughes Corporation 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:

N/A

Rationale:

The Howard Hughes Corporation does not operate a PAC or engage in lobbying at this time (1)(2)(3).