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Interpretive Bulletin Relating to the Exercise of Shareholder Rights and Written Statements of Investment Policy, including Proxy Voting Policies or Guidelines, 2016



This document sets forth supplemental views of the Department of Labor (Department) concerning the legal standards imposed by sections 402, 403 and 404 of Part 4 of Title I of the Employee Retirement Income Security Act of 1974 (ERISA) with respect to voting of proxies on securities held in employee benefit plan investment portfolios, the maintenance of and compliance with statements of investment policy, including proxy voting policy, and the exercise of other legal rights of a shareholder. In this document, the Department withdraws Interpretive Bulletin 2008–2 and replaces it with Interpretive Bulletin 2016–1, which reinstates the language of Interpretive Bulletin 94–2 with certain modifications.


United States




North America

Issuer (type)

Employee Benefits Security Administration (Government)

Instrument type


Disclosure instrument


Geographical scope


Mandatory or voluntary


Text analysis

    • Moderate 0.90%
    • Low 0.01%
    • E focus: climate change, climate risk, pollution, environment
    • S focus: diversity, compensation
    • G focus: responsible investment, accountability
    • Finance, Management