Last week, the Advisory Committee on Investor Responsibility unanimously rejected a divestment proposal from Dartmouth Divest for Palestine that calls for the College to divest from six weapons manufacturers it says are “directly involved in Israeli apartheid, genocide and violations of international law.” The DD4P proposal is the first divestment proposal to be officially reviewed by ACIR under guidelines updated in 2013, according to the ACIR website.
ACIR is comprised of nine voting student, administrator, faculty and alumni members appointed by College President Sian Leah Beilock. It is the first group to review divestment proposals for “completeness” before determining whether to send the proposal to Beilock, who then decides whether to bring the proposal to the Board of Trustees. ACIR met ten times over three months to discuss DD4P’s proposal and determined that it did not meet the five criteria for “completeness,” according to their response issued on May 12.
Peter Cooch ’07, a member of Dartmouth Alumni for Palestine who worked with DD4P on the proposal, said the group intends to resubmit a proposal that addresses ACIR’s concerns while the “core elements of the proposal remain unchanged.”
ACIR was founded in 2003 to ensure Dartmouth “act[s] as a responsible and engaged investor,” according to the ACIR’s 2024 annual report. Its principal mission is to advise the College on how it should vote on shareholder resolutions relating to social issues for companies that Dartmouth invests in.
In 2013, the Board of Trustees adopted the “Statement on Investment and Responsibility Issues” to guide ACIR. It established the new five criteria for completeness: that a company’s actions are inconsistent with Dartmouth’s values, the exhaustion of shareholder rights to solve the issue, a material impact from divestment on a company’s actions, Dartmouth’s academic mission will be unaffected by divestment and consensus in the community in favor of divestment.
Four of the criteria are based on SISR, and the fifth criterion for consensus comes from ACIR’s statement of responsibilities.
Dartmouth has divested in the past, under different parameters. In 2005, the Board of Trustees voted to ban Dartmouth holdings in 21 companies “due to the conclusion by ACIR that their activities amounted to direct complicity in the genocidal activities of the government of Sudan in its Darfur region.”
In 2014, Divest Dartmouth submitted a petition to then-President Philip Hanlon ’77 advocating for divestment, though it was not a formal proposal. Two years later, with the petition nearing 2,000 signatures, ACIR commissioned a report on fossil fuel divestment. It did not issue a formal recommendation for or against divestment.
In 2021, Dartmouth announced its intentions to divest from fossil fuel companies, but the decision was made by the Dartmouth Investment Office and was not the result of a formal proposal reviewed by ACIR.
Before ACIR’s inception, the Board of Trustees divested from companies involved with South African Apartheid in 1989.
Criterion one: Inconsistency with Dartmouth’s values
SISR’s first requirement is that divestment proposals must demonstrate that target companies have acted in a way that is “inconsistent” with Dartmouth values, history or mission. ACIR’s interpretation includes the additional requirement that a proposal must also “engage with the opposing view” to further demonstrate that a company’s actions are inconsistent with the College’s values, history or mission.
The DD4P proposal argues that Israel’s actions in Gaza Strip constitute “state violence and racist discrimination,” and that continued investment “clearly violates the College’s stated commitments to responsible leadership, mutual respect and social responsibility.”
Cooch said “extensive” research into past divestment efforts at Dartmouth went into writing the proposal.
“These moments [have] been some of the proudest moments in our history,” he said. “The times that we have lived up to our values and mission as a campus to be moral leaders.”
The group also researched war crime accusations against Israel — “which include apartheid, scholasticide and illegal occupation” — and how the six companies are “directly implicated” in those actions, Cooch added.
ACIR wrote that DD4P’s proposal made a “reasonable effort to provide information that could satisfy” the first criterion, which was ultimately only “partially satisfied” because of a lack of engagement with counterarguments.
Cooch said it was “hard to imagine a counterargument to the genocide that’s occuring” but that the group would make “good faith effort” to respond to any example counterarguments that ACIR provided.
Criterion two: Exhaustion of shareholder rights
Secondly, proposals must provide evidence that shareholder rights to change a company’s behavior, including shareholder votes, have been “exhausted.”
The proposal states that shareholder activism has “historically been resoundingly unsuccessful” for companies dependent on military contracts, such as those targeted for divestment. It points to shareholder votes at RTX and Lockheed Martin, two defense companies targeted by the divestment proposal, which would have required a human rights impact assessment. Both votes failed by wide margins.
ACIR determined that DD4P’s proposal did not meet this criterion, calling the RTX and Lockheed Martin votes “anecdotal.”
Cooch noted that this criterion had not been applied to previous divestment decisions, such as the decisions to divest from fossil fuel and tobacco companies, when the College “acted based on core attributes of those companies.”
“We made that argument in our proposal here,” he said. “So I think that the rejection for incompletion that they provided doesn’t acknowledge … why our proposal is being held to such a different standard.”
Criterion three: Material impact
ACIR’s third criterion requires proposals to show that divestment will make a “material impact” on correcting the actions of targeted companies.
The DD4P proposal wrote that “the depreciation of stock prices driven by the sale of stock can potentially decrease profits,” which may “decrease these companies’ ability to manufacture arms, weaponry and surveillance technologies.”
The proposal argues that while Dartmouth’s lone divestment may have a marginal material impact, it may encourage other universities to also divest and create “profound cumulative effects.”
ACIR found that the third criterion was not met because “no counterarguments are addressed.” Namely, “the proposal does not include a discussion of the resulting reduction of diversification in Dartmouth’s investment pool or limitation of access to investment managers that could occur in the event of divestment,” the ACIR response wrote.
Criterion four: Academic mission interference
ACIR’s response interpreted the fourth criterion — that “divestment will not compromise Dartmouth’s ability to address the target issue through its academic work and other channels” — to mean that divestment “would not hinder” open dialogue on campus or the College’s ability to engage in research and teaching on “economic, political and social issues” related to Israel and Palestine.
The proposal wrote that Dartmouth’s endowment “can be reinvested elsewhere,” while divestment “will enhance Dartmouth’s ability to study Palestine and Israel with transparency and honesty and for those findings to be published without fear of repercussions.”
ACIR found that the proposal did not sufficiently address this criterion because it did not fully address how federal and philanthropic funding might be affected by divestment.
Criterion five: Community consensus
Once a proposal meets the first four criteria, it must show that a consensus of the Dartmouth community — students, faculty, staff and alumni — supports divestment. ACIR defined a consensus as “more than a majority support for the proposal among a set of individuals but not necessarily unanimous support.”
However, a successful proposal “must engage with the ideas held by community members who are opposed to the proposal, even if those ideas are held by a small minority,” ACIR wrote.
ACIR found that the proposal had “no compelling evidence” for consensus, pointing out there is “almost certainly deep opposition to [divestment] among some members of the Dartmouth community.”
The proposal included a list of 35 student, alumni and faculty organizations who endorsed the proposal, but ACIR did not consider the endorsements sufficient evidence for consensus because the signatories allegedly did not represent subgroups of the Dartmouth community. It was also unclear whether the endorsements were issued democratically, according to ACIR.
Cooch said ACIR did not provide DD4P a definition of consensus before rejecting their proposal.
“In my perspective, there is a huge moral majority who support divestment,” he said. “We will ask ACIR if they agree that we are compellingly arguing that what is happening in Palestine is genocide. Ultimately, is it necessary to have 50% of the Dartmouth community — including its alumni community — sign their name?”
Visiting government professor Bernard Avishai said he thinks the divestment movement is “tremendously naive.”
“If you want to help defeat [Israeli Prime Minister Benjamin] Netanyahu’s policies, get on the side of those Israelis, like myself, who want democratic forces from around the world to be supporting us,” he added. “Don’t find ways of trying to hurt Israel in general.”
Several members of ACIR declined to comment on the record.
