Beyond ESG: Proxy Voting Provisions to Know in DOL’s ESG Rule

Much has been written, on ML BeneBits and elsewhere, about the US Department of Labor’s (DOL’s) so-called “ ESG Rule ” issued in November 2022 (the DOL Rule). The DOL Rule, in part, addressed the appropriate factors for an ERISA fiduciary to consider when making investment decisions, including the potential use of environmental, social, and governance (hence, ESG) factors in ERISA investment decision-making. But there was more to that rule than the ESG topics that seem to dominate the spotlight.