Photo by SpaceX on Unsplash In a July 1 article Reuters reported that Oregon Treasurer Steiner wanted guidance from the federal Securities and Exchange Commission (SEC) about SpaceX. How should pension funds handle the new company with the giant market valuation? SEC Commissioner Mark Uyeda answered Elizabeth Steiner in an interview in Reuters . One takeaway is his simple point that if you don't like the governance arrangements of a stock, don't buy it. A message from the SEC's Uyeda: If you don't like SpaceX's governance, don't buy the shares ( Reuters Sustainable Finance , July 1, 2026) Note: The Oregon State Treasury has $6.8 million in exposure to SpaceX through one public equity index fund and one global equity portfolio ( Portland Business Journal July 2, 2026). Divest Oregon has made the same point to Treasurer Steiner, repeatedly. For example, Treasurer Steiner posted on Facebook on May 6, 2026 that she is “deeply troubled” by the ways ICE contractor Geo Group fails to adhere to Oregon Investment Council (OIC) policy. Divest Oregon responded : The Oregon Treasury has held stock in private prison/immigrant detention contractors for years, in spite of well-publicized abuse. If a company is violating OIC policy the Treasury has an obligation to sell the stock. In fact, Treasury’s screening process can and should prevent purchasing or holding stock that violates OIC/Treasury standards. The SEC Commissioner quoted in the Reuters ’ interview about SpaceX also says pension funds have the duty and ability to do such screening: Question by Reuters to SEC Commissioner Uyeda: "You write that ‘If prospective investors have concerns with the governance arrangements, then their most powerful tool is to not purchase shares of the stock.’ But critics like some big pension funds say the fast-track addition of SpaceX to big indexes could make them unwilling buyers of the stock. What would you say to such critics? Response from SEC Commissioner Uyeda: "Large pension funds have choices with respect to ​their investment decisions as part of their fiduciary duty to the plan. While index funds may have certain conveniences and low costs, there is a trade-off to outsourcing securities selection to a third party. There are alternatives, such as selecting a fund that follows a different index or is actively managed, or engaging in customized direct indexing that would provide more control over the portfolio.”

A Geo Group van leaving the Northwest ICE Processing Center in Portland Oregon. May 2026

At the March 2026 OIC meeting, John Goldstein from Goldman Sachs spoke of the strength of renewable energy stocks (recap in Net Zero Investor 5/3/2026 ). Bill McKibben shows us how the sector is evolving with battery technology advances. Night into Day ( The Crucial Years substack 3/30/2026): “For the first time, the United States now has the capacity to supply 100% of domestic energy storage project demand with American-built systems,” said Noah Roberts, executive director of the U.S. Energy Storage Coalition. “That is a fundamental shift from where we were just a year and a half ago, when the majority of battery storage systems were imported.” “Already, the U.S. has enough capacity to meet demand for finished grid battery enclosures…. By the end of this year, the U.S. will also achieve self-sufficiency in a higher-value part of the supply chain: the battery cells themselves. It’s a major industrial coup that is bringing thousands of high-tech manufacturing jobs to communities across the country.” Solid-state batteries are becoming a possibility; they promise to solve several problems: “Batteries are now being tested by multiple companies that can go 800 miles on a single charge….“In September, Mercedes drove a modified EQS over 1,200 km (745 miles) using 106 Ah solid-state battery cells supplied by US-based Factorial Energy. Factorial launched the first commercial solid-state battery program in the US …earlier this year.” The Finnish company Donut Labs shows where this is heading: “The Donut batt can charge to full in five minutes…; has a practically unlimited lifespan (100,000 charging cycles); is unaffected by heat and cold (-30C to 100C); and contains no rare earth, precious metals or flammable liquid electrolytes. With all that, Donut Lab says it will be cheaper to produce than conventional lithium-ion batteries…” “And the technological miracles are only beginning. For instance, Christopher Mims reported last week in the Journal on a new round of ‘thermal batteries that store solar power as heat instead of electricity, perfect for use in high-temperature industrial processes.’” “Marija Maisch was reporting in January that…salt-based batteries are nearing price and performance parity, if not for cars then for utility scale batteries.” And this chart shows the surge of batteries coming online as solar installations lose sunlight. Night into day.

A question from Divest Oregon, a coalition of a hundred organizations with strong PERS representation, remains unanswered: What screening process does the Oregon State Treasury (OST) use, if any, when investing PERS funds or choosing investment managers? Is the Treasury screening investments in fossil fuel companies? Andrew Bogrand, Divest Oregon’s Communications Director, spoke at the Oregon Investment Council (OIC) in January 2026. He noted that investment in fossil fuels contributes to global instability, using Venezuela as an example. (See this blog .) The current Iran war emphasizes this point. Andrew regularly comments on the ties between insecurity and fossil fuels as a policy lead for human rights and natural resource justice at Oxfam. The argument that fossil fuel investments are a sensible diversification of a portfolio has long been outdated. But looking at the most recently published June 2025 public equity and fixed income data, the Treasury is still investing in fossil fuels. Under fiduciary duty and the Climate Resilience Investment Act ( CRIA ), the Treasury must move to alternative investments that align with the reality of climate change and a rapidly destabilizing world. Is the Treasury screening investments prone to legal liability, human rights abuses, or reputational risk? In an April 2023 report , Divest Oregon called out the Treasury's investment in private prisons and surveillance technology as context for the question: Does the Treasury have a screening process? If so, what is the screening process? One example given in that report was the NSO/spyware technology that OST heavily invested in. The Guardian reported extensively (2022) on the OST’s investment in NSO/Pegasus spyware: “However, it now appears that the Oregon pension fund, one of the most prominent in the US, gave its tacit approval over an investment in NSO several years ago – at a time when security researchers were already publicly raising alarms about the company.” In a more recent report, Oregon Treasury’s Investment Screening Failures ( October 2025 ), Divest Oregon again questioned the Treasury’s investment screening process. Examples of questionable investments included GEO Group, CoreCivic, and Palantir. Investments in GEO Group and CoreCivic fund private prison contractors and ICE detention centers. Investment in Palantir funds ICE surveillance software used against US residents. See additional information below for each of these companies. The most recent public data ( June 2025 ) shows that the Treasury continues to invest in these private prison and surveillance technology companies with a long history of human rights abuses and legal vulnerability. These companies are central to the current federal administration’s construction of a police state and its massive violation of due process. See Trump’s Mass Deportation Campaign ( The New Yorker 3/15/2026). For example: Recent private prison contractor GEO Group news: In February 2026, the Supreme Court found that GEO Group, a private prison operator running an Immigration and Customs Enforcement (ICE) facility, cannot claim governmental immunity from lawsuits for violating human trafficking laws, even if those violations were under government orders. Recent surveillance technology company Palantir news: In Portland, now, Palantir’s Elite app is being used to identify potential deportation targets, generate dossiers on individuals and provide a “confidence score” on the person’s address. ( The Guardian 3/13/2026) Why should the Treasury screen its investments? Screening is necessary to avoid investments that contravene Treasury standards, OIC policy, legal standards including fiduciary duty, or Oregon State law. For instance: The Oregon Department of Justice has recently opened an inquiry as to whether OST investment in companies with contractual ties to ICE violates the Oregon Sanctuary Promise Act of 2021 . The CRIA Act of 2025 mandates that the Treasury: -- “actively analyze and manage” climate risk to the portfolio -- report on its progress toward investing in public equity holdings that incorporate the tenets of a just transition in their overall priorities and portfolio

Part 2: Building on Oregon State Treasury’s 2025 Progress toward Net Zero Emissions Divest Oregon applauds initial action, offers recommendations for future reporting, including the use of multiple metrics

Part 1: Building on Oregon State Treasury’s 2025 Progress toward Net Zero Emissions Divest Oregon applauds initial action, offers recommendations for future reporting, including the use of multiple metrics

Thanks to the passage of CRIA and the Coal Act, Oregon is moving toward a more transparent assessment of climate-related risks, engaging with asset managers and companies, and identifying climate-positive investments. OPERF has nearly $90 million invested with Exxon, $40 million in Chevron, and $5 million in Shell. Can the Treasury hold these companies accountable and protect the wider portfolio from major conflict exposure? Following is incisive testimony to the January 2026 Oregon Investment Council by Andrew Bogrand, Divest Oregon’s volunteer Communications Director. For over five years, the Divest Oregon coalition has encouraged the Oregon State Treasury to take seriously the financial risks associated with fossil fuel investments, particularly within the context of the wider energy transition. Treasury, as well as the Oregon Investment Council, has listened and responded. Thanks to the 2025 Climate Resilient Investment Act (CRIA) and the 2024 Clean Oregon Asset Legislation (COAL) Act , our state is moving toward a more transparent assessment of climate-related risks, engaging with asset managers and companies, and identifying climate-positive investments. Of course, much of the work remains. In the spring of 2025, Divest Oregon provided testimony to lawmakers in Salem about the coalition’s support of CRIA. We shared how the bill would help Treasury address “new economic realities, where geopolitical contestation…and natural resource competition will upend the financial logic of passive investing.” A year later, this statement rings painfully true. We stand on the precipice of resource-driven conflicts in Venezuela, Greenland, and Iran. We are witnessing a deterioration of the international rules-based order, which will come with serious financial implications. This breakdown is not random. Chevron has played “the long game” in Venezuela, spending millions lobbying the Trump administration and positioning itself to profit following the US invasion. Shell is seeking a multi-billion gas project following the illegal ouster of President Maduro, which presumably also secured ExxonMobil’s interests – not in Venezuela, but in neighboring Guyana . And, the American Petroleum Institute, an industry lobby group including Chevron, Shell, and Exxon, recently pledged to “stabilize Iran” if the regime is ousted there, too.  Of course, whether these companies will profit from this new era of resource colonialism remains unclear. Darren Woods, the CEO of ExxonMobil, said bluntly that Venezuela is “un-investable.” Chevron has also acknowledged that any future work in Venezuela will require extensive guarantees and long-term stability, conditions which remain absent. Despite all the money spent on lobbying, the oil market remains volatile and these companies will likely seek taxpayer support and sanctions relief for risky bets abroad Treasury has nearly $90 million invested with Exxon, nearly $40 million in Chevron, and over $5 million in Shell. Now the question is how to hold these companies accountable and protect the wider portfolio from major conflict exposure. Not all energy companies are equal. In contrast to Chevron, France’s TotalEnergies, which Treasury also owns, has no intention to enter Venezuela despite its operations in nearby Suriname, presumably worried that their presence could make a humanitarian crisis worse or even directly fund human rights violations. If Treasury is serious about engagement, as set forth in CRIA, now is the time to exercise this commitment toward the most politically-exposed companies. Extraction by military force pushes the absolute boundaries of the social license to operate and undermines other holdings in Treasury’s portfolio. Companies have a major and well-recognized responsibility to avoid contributing to war. This responsibility is rooted in the UN Guiding Principles on Business and Human Rights as well as in international humanitarian law. Companies are expected to conduct rigorous human rights due diligence to ensure that their operations, supply chains, and technology do not fuel or contribute to conflict. If companies like Chevron and Exxon fail to respond to engagement along these lines then divestment is both an appropriate business decision -- and the right thing to do.

Oregon Treasury Investment Team Causes $3.7 billion loss to PERS Retirement Fund since 2023. Treasury staff disregarded policies limiting private equity investments. Overview A Divest Oregon analysis of Oregon Treasury private equity investment practices finds that years of exceeding the Oregon Investment Council’s (OIC) policy limiting high-risk private equity significantly reduced the performance of the Oregon Public Employees Retirement Fund (OPERF). These effects total about $3.7 billion in reduced value since 2023 . At the center of this issue is Oregon Treasury Chief Investment Officer Rex Kim and his investment team , whose long-term private equity acquisitions significantly exceeded OIC’s risk tolerance for OPERF as stated in its investment policy targets. The OIC is a trustee , and an agent’s failure to follow a trustee's instructions is a breach of trust . These events raise broader questions about policy oversight, internal accountability, and the Treasury’s ability to align its investment practices with new directives under the Oregon Climate Resilience Investment Act (CRIA) . Policy Departures and Oversight Challenges Since at least 2019, OPERF’s investments in private equity substantially went over the levels established in OIC’s policy targets. Corresponding reductions in lower-risk public equity went well below target. While the OIC sets investment targets, it relies on Treasury investment staff to implement them faithfully. By 2022, excessive amounts of private equity led to urgent pressure within OPERF to obtain cash for PERS benefit payments. Treasury then undertook substantial sales of public equities. During this time, the CIO argued ( audio at 1:26:40) that OIC’s private equity policy target was just “some 20 per cent artificial number” and existing overinvestments in private equities should continue. His remark highlights the continuing tension between policy set by the OIC and its implementation by Treasury leadership. Documented Financial Impact In 2025, the Oregon Journalism Project reported that Treasury’s overinvestment in private equity reduced OPERF’s exposure to better-performing public equities and caused $1.4 billion in lost value during 2024 alone. Treasury officials did not contest the reported dollar loss, although Treasurer Elizabeth Steiner noted that a single-year snapshot cannot fully capture the long-term effects of complex portfolio dynamics. Nonetheless, she acknowledged in October 2025 the need to rebalance OPERF’s exposure away from private equity toward more liquid, lower-risk assets. Broader Review by Divest Oregon Following Oregon Journalism Project reporting, Divest Oregon conducted an independent examination of Treasury’s investment return statements from January 2020 through the third quarter of 2025. Impacts were calculated by looking at investment yields as they would have been had the Treasury leadership followed OIC policy targets, and comparing them with the yields that Treasury reported. The analysis confirmed the substance of the Oregon Journalism Project’s finding of a $1.4 billion underperformance in 2024, and identified additional damage to OPERF returns totaling $2.3 billion for 2023 and 2025. Divest Oregon’s Chart 1 shows these underperformances resulted in cumulative damage of $3.7 billion to OPERF returns since 2023. Had Treasury met the OIC targets, Divest Oregon calculates that OPERF’s total returns would have increased by 1% to 1.5% annually in 2023 and 2024, improving the system’s funded ratio in 2024 by roughly 1% , from 73% to 74%.

Two new reports by Divest Oregon highlight the interdependency of lowering fossil fuel investments and a just transition to clean energy. Pension funds seeking to invest in low carbon investments to support climate health must examine the impact of proposed investments on the health and well-being of communities. The Oregon Treasury is committed, by a recently passed Oregon law , to “the goal of reducing the carbon intensity of the [Oregon Public Employees Retirement] fund through a preference for investments that reduce net greenhouse gas emission” while “investing in public equity holdings that incorporate the tenets of a just transition in their overall priorities and portfolio.” Pension fund investments that do not support a just transition present a financial risk to investors. As a United Nations International Labour Organization report explains: A failure to promote a just transition represents a threat to effective climate action, and can contribute to increased inequality and fuel social unrest. This, in turn, can lead to major financial implications for banks and insurance companies as social instability, transition risks and physical climate change impacts may disrupt clients’ business operations due to interruptions in their supply chains, impacts on human health, or loss of livelihoods. In its report, Oregon Treasury’s Investment Screening Failures , Divest Oregon finds that Oregon Treasury’s failure to screen its investments results in investments that worsen the climate crisis, violate people’s rights, cause injury, and cause negative consequences to the Oregon Treasury and its holdings. The report offers examples of the interdependence of climate and investment results. One notable example is the Rio Grande Liquid Natural Gas (LNG) Export Terminal. In December of 2022, OST committed $350 million to GIP Fund V for the project. The 900-acre project was sited on sacred tribal lands without free, prior and informed consent (FPIC) in the face of strong and broad community and global opposition. Construction and operation of the terminal promised to devastate the last deepwater port in the Gulf without fossil fuel projects, and destroy key components of the local community and economy. The risks were financial as well as environmental. Multiple banks and insurers had already withdrawn their support when the Oregon Treasury chose to invest. The project had no FERC permit and was in litigation. GIP’s two previous funds had a history of underperformance. There were numerous indicators that the LNG market would be glutted by the time this project came online. A July 31, 2025 decision by FERC gave a green light to the project. As of September 2025, the earliest projected completion date is 2030. Pipeline and export terminal infrastructure is designed to last for decades with obvious repercussions for the climate and the community. Opposition to the project continues. Divest Oregon’s Just Transition and the Oregon State Treasury report describes the financial benefit to pension funds of investments that promote a just transition to clean energy. Citing the guide for investor action from the Investing in a Just Transition Initiative and United Nations’ Principles for Responsible Investment (UNPRI), it notes 5 reasons why investing in a just transition is in the best interest of beneficiaries and in line with fiduciary duties by: Responding to systemic risks Reinvigorating fiduciary duty Recognizing material value drivers Uncovering investment opportunities Contributing to societal goals The report presents recommendations for a just energy transition for public pension funds. It calls for pension funds to establish investment policies regarding Free, Prior and Informed Consent (FPIC) and Fair Labor Rights and provides a detailed explanation of these principles and their relationship to the financial health of pension funds. Citing examples of pension funds that have successfully utilized the principles of just transition like NYSERS and CalPERS, the report provides a guide for pension funds to adopt ethical and beneficial investment strategies.