Your browser is out of date.

Environmental Social Governance (ESG) Investing

Employers 11.30.2020 6 MIN READ


As waves of social, political and economic changes flood the country, many investors are taking a closer look at where their money is going—and who benefits. This shift has left many employers searching for solutions that match their employees’ priorities. A recent survey by JUST Capital and The Harris Poll showed 89% of Americans agree these changes are an opportunity for large companies to hit “reset” and focus on doing right by their workers, customers, community and the environment.1

Already this year, the number of investments being directed based on ESG principles has increased and more employers are looking to accommodate employee requests by adding options to 401(k) investment line-ups.

ESG continues to evolve

Even before the concept of ESG investing was fully developed, some investors had begun considering moral implications when weighing their investment decisions. These early approaches focused on avoiding certain “vice” industries (like tobacco, alcohol or gambling) or excluding investments originating from countries with poor human rights policies. Over time, the method progressed from mere avoidance to actively choosing companies for investments based on their efforts to reduce global warming or make an impact with diversity and inclusion, among other causes.

The list of ESG investors’ considerations continues to grow. Now more than ever, the COVID-19 pandemic has aimed a spotlight on companies’ “social responses”—how they are treating employees, customers, suppliers and society at large. Recently, transparent accounting, crisis management and strong supply chain management are also gaining popularity.

Having a social purpose is not a luxury: It is a critical business imperative

Companies can benefit in a variety of ways from maintaining a strong ESG strategy in their corporate governance and the 401(k) investment options available to their employees.

  • Help attract and retain talent. As younger generations enter the workforce, they have made clear their desire to support and work for companies that embrace the values they champion. By 2025, millennials will make up 75% of the workforce and account for 46% of the nation’s income. In addition, 76% of the 1.35 billion women currently in the workforce rate ESG factors as important for making investment decisions.2
  • Drive stock value. Investment research firms like Thomson Reuters, Sustainanalytics and MSCI have developed indices that measure and rank companies based on ESG factors. The investment funds that benchmark these indices are raising trillions of dollars to invest in companies that execute sound ESG policies, fueling demand for these companies’ stock.
  • Attract customers. Interest in companies’ social, economic and environmental policies is not limited to potential employees and investors—consumers are increasingly basing purchasing decisions on these principles.
  • Improve relationship with activist shareholders. Groups of investors and NGOs are working together to push for corporate accountability on ESG initiatives. These activist shareholders have used both social media and proxy campaigns to put pressure on companies and ensure they are adequately showing progress in areas such as climate control and board diversity.


To support a meaningful ESG framework, companies should identify the key initiatives they most identify with and start focusing on a small number of purpose-driven goals that can be integrated at all levels of the organization. Successful ESG policies depend on commitment from the CEO, prioritization by management and communication to all stakeholders demonstrating the company’s dedication to the initiatives.

Trading off return for social impact

As investors and companies alike are learning—making investments based on ESG considerations does not preclude profit. A recent Goldman Sachs report, "Five Lessons Learned: Environmental, Social and Governance (ESG) and Impact Investing," identified that investors’ most frequent question on this topic concerns whether they must sacrifice returns in order to achieve impact. The report answers this question with a firm “no” and suggests that concessionary returns are not necessary. In fact, a cited meta-study of over 2,200 individual academic studies indicates that 90% showed a neutral or positive relationship between ESG and performance.

Bloomberg recently reported that investors have poured a record $22 billion into ESG exchange-traded funds this year, nearly tripling 2019's total.3 While the popularity of ESG investing is undeniable, many investors are advising caution, pointing out that the ESG designation is not regulated in the U.S. There is no consistent method for evaluating and defining an ESG classification. As these investment funds multiply in numbers, it will be important for investors to dig beyond surface labels and marketing materials to determine for themselves whether a fund truly delivers on its promises.

ESG as a defined contribution investment choice

For many, an employer-sponsored defined contribution plan is their first—and potentially only—entry into the world of investing. Most employers have not widely added ESG funds within their defined contribution retirement plans, but America’s increasingly diverse and socially conscious workforce is driving this forward. At the same time, there is growing concern that the lack of standardization on ESG criteria may affect investors’ ability to make informed ESG investment decisions.

Building the personal financial literacy skills necessary to carefully evaluate investment decisions takes time. Employer-sponsored education and support is a critical part of helping employees build financial literacy. Ayco’s group education and financial wellness programs can help bridge this gap for employees. 

The U.S. Department of Labor (DOL) takes action

​Earlier this summer, the DOL turned its attention to ERISA retirement plans that wished to add fund choices based on ESG principles. The DOL issued proposed rules followed by a 30-day comment period, which received a high level of public response. Over 1,100 unique comment letters and 7,000+ signed form letters were submitted by members of the investment industry and the public. Most of the comments argued for the importance of ESG-themed investments and criticized the DOL’s view of ESG investing as outdated.

Last week the DOL announced their final rule, “Financial Factors in Selecting Plan Investments,” which updates and clarifies the investment duties regulation under Title I of ERISA. This ruling is intended to provide clear, regulatory guideposts for plan fiduciaries in light of recent trends involving ESG investing.

The ruling no longer singles out ESG—in fact, the final rules don’t even refer to “ESG.” Instead, they emphasize that retirement plan fiduciaries should only use “pecuniary” factors when assessing investments of any type. In other words, only factors that have financial implications. So, assuming ESG investments can measure up in a purely economic manner, there would be no restriction from including them in a fund line-up. ESG factors alone will also not disqualify a fund from being used as a qualified default investment alternative (QDIA). As long as the fund is assessed strictly on pecuniary factors and doesn’t state an objective other than the financial outcome of investors, the fund can be offered as an option. Our recent Insight provides more details about the DOL ruling.

Next steps for employers

The final rule is effective 60 days after publication in the Federal Register. While ESG options have not widely been adopted yet, the topic has been top of mind for many of Ayco's corporate partners—especially as more employees ask for these options.

Ayco works with several companies that offer ESG options within their 401(k) plan core investment lineups. A unique strategy we have seen companies implement or consider is highlighting the availability of ESG options within their brokerage window. This is an interesting option for providing ESG exposure for companies that currently offer a brokerage option, or may be considering one for the future.

As employers move forward within the new guidelines, effective communication and participant education are critical. ESG investment options carry unique characteristics and complexities. Employees will need more assistance to make informed investment decisions. Ayco’s advisors can help employees navigate these complicated topics, tailoring the experience to meet each individual’s specific needs. 


For further background on the rising importance of ESG factors, check out these additional resources from Goldman Sachs:

  • ESG Amplified explores the rise of importance of ESG factors and their applicability across asset classes.
  • The ‘S’ in ESG is a brief blogpost that explores the rising importance of the ‘S’ in ESG.
  • GS SUSTAIN has put together a number of pieces highlighting ESG in the context of COVID-19.



1COVID-19 Corporate Response Tracker, JUST Capital and the Harris Poll, May 2020




For disclosures relating to this article, please click here.