Many people are outraged to learn that their 401k’s are indirectly supporting genocide through their investments in mutual funds. Many are also outraged that their employers have business relationships with a company that makes such investments. Here are steps you can take to address your 401K, seeking to make it genocide-free.

Check your 401K plan

  • Is the plan administered by one of the problem investing companies? We'll call them the PIF, the Problem Investment Firm.
  • Does the plan offer a broad range of funds from other companies, or only funds from the problem companies?

Contact your company's 401k plan administrator

  • Alert the plan administrator to the problem. Typically, the plan administrator will want to help address employee concerns. However, they may be resistant to making changes in the plan. Building a broader base of concerned activists within the ranks of employees is often an important early step.
  • Ask the plan administrator to help so that employee savings and pension funds are not tied in any way to genocide.

Complain to the PIF (Problem Investment Firm)

  • Each contact from a company will carry considerably more weight with the PIF than many individual contacts due to the concentrated nature of the feedback (speaking for many people) and the risk to the PIF’s revenue from managing the 401k plan. Your company can express that its employees are concerned about the PIF and that working with the PIF is becoming a business problem.
  • Using a public meeting with the PIF, such as a periodic performance update meeting or employee information session, is a good way to ask the PIF probing questions.
    • Ask if the PIF is concern about investments from their funds being linked to genocide.
    • Ask whether there are any moral limits to the investments that the PIF makes.
    • Ask which of their funds currently holds PetroChina, Sinopec, ONGC, or Petronas? If they won't answer the "current holdings" question, ask which of their funds held PetroChina, Sinopec, ONGC, or Petronas as of their last quarterly report.
    • Ask which of their funds can be relied on to NOT hold PetroChina, Sinopec, ONGC, or Petronas?
    • Ask what options there are, within the limitations of the 401K plan, to investing in funds that are known to be tainted with genocide or may become tainted.

Assist employees to switch within the PIF (Problem Investment Firm)

  • The company’s plan administrator can request that the PIF provide an analysis of the PIF funds offered in the plan to determine which, if any, hold PetroChina, Sinopec, ONGC, or Petronas, the oil companies that are the main targets of the Sudan divestment movement.
  • The administrator can also request that the PIF suggest Sudan-free funds that are substantially similar to the offending funds.
  • Even without your company taking a position, a letter can then be sent to all employees indicating which of the PIF funds have investments in Sudan, why they are an issue, how divestment can help, and how to join the campaign.
  • The letter should provide instructions, for those that want them, on moving to Sudan-free funds.

Assist employees to switch out of the PIF (Problem Investment Firm)

  • There are many discount brokers and mutual fund providers that are have more responsible positions on investments in the Sudan. For those employees that want to stop doing business with the PIF, given its ethical position, alternative funds should be offered.
  • In many cases these alternative funds will already be available as part of the company’s portfolio of investment options. Again, a letter to the plan participants can advise people of the situation and assist those that are interested in making this response.

End the relationship with the PIF (Problem Investment Firm)

  • The ultimate expression of dissatisfaction with PIF is to move the company’s plan completely. Further, to the extent that the company has corporate investments (e.g., endowments) made through the PIF, a similar range of options are available. The PIF may also be providing a broader range of services to the company, such as payroll, benefit processing and management, or HR services. The company can choose to re-evaluate the PIF as a provider, and potentially move to a new vendor.
  • Even if your company is not ready to end the relationship with the PIF, the plan administrators can take the other steps outlined above with little cost and effort and without taking a position – they are just helping those who want to take individual action.
  • To the extent that the organization does not see the need to take action, individual employees have a harder task.  The challenge is to organize enough support to encourage the company to engage with the PIF and to
    reconsider existing relationships. 
  • Before any public campaign is instituted against the company, an inside discussion is appropriate, particularly if champions within management, corporate responsibility organizations, or human resources can be identified. Helping managers to understand the range of options open to them is useful in gaining support.

Contact us


We want to hear about your activities and will help.  Please contact us via phone or email.