Download copy of the Halliburton Shareholder Proposal (pdf)

Download copy of Comptroller’s Dec. 8th letter to Halliburton (pdf)

New York City Comptroller William C. Thompson, Jr. today vowed to continue efforts on behalf of the City’s Pension Funds to force the Halliburton Company to thoroughly review its offshore subsidiary’s connections with Iran.

Thompson made the announcement after a proposal by the New York City Police and Fire Department Pension Funds to require the company to report on those ties did not muster a majority of votes at Halliburton’s annual meeting.

Twenty-two million shares – 7.4 percent of the total shares cast - were voted in favor of the proposal.

“I am pleased we received more than double the percent needed to allow New York City to resubmit the proposal later this year,” Thompson said, also noting that 34 million shares were abstained. “As fiduciaries, we must ensure that companies in our portfolio are not using off-shore subsidiaries to legally evade United States sanctions against terrorist-sponsoring states. This is an issue of paramount importance.”

Thompson filed the shareholder proposal with Halliburton in December after the company failed to comply with an agreement to provide the funds with a report detailing the "potential financial and reputational risks" of its Iranian operations. Under the agreement, Thompson withdrew a shareholder proposal last year when Halliburton promised to designate a committee of its Board of Directors to review the operations and then submit a report on those risks.

However, contrary to that agreement, Halliburton's report failed to address the concerns specified in the pension funds' proposal. Thompson then resubmitted the shareholder proposal in December. Halliburton, in its proxy materials, then claimed to shareholders that the company had already provided the required report.

The proposal followed reports that Halliburton had opened an office in Iran under the name Halliburton Products and Services Ltd., its Cayman Islands subsidiary, in February 2000. It read in part: "The Iranian government has actively supported and funded terrorist operations against innocent civilians outside its own borders. These activities led to the imposition of government sanctions that provide that virtually all trade and investment activity with Iran by U.S. corporations is prohibited."

“We believe their use of an off-shore subsidiary to establish operations with a country that sponsors terrorism violates the spirit, if not the letter, of the law," Thompson said. "These actions can have a negative impact on shareholder value by exposing the companies to the prospect of negative publicity, public protests, and a loss of consumer confidence.”

The Police and Fire Department Pension Funds have 325,634 shares worth about $9 million and 123,948 shares worth about $3.4 million, respectively, in holdings in Halliburton. In total, the city's five pension funds have invested 1,554,037 shares worth more than $43.4 million in the corporation.

Besides Thompson, trustees on the New York City Fire Department Pension Fund are: Mayor Michael Bloomberg; Nicholas Scoppetta, Chair, New York City Fire Commissioner; Martha Stark, Commissioner, New York City Finance Department; Stephen Cassidy, President, James Slevin, Vice President, Robert Straub, Treasurer, and John Kelly, Brooklyn Trustee, all of Uniformed Firefighter's Assoc. of Greater New York; Peter Gorman, President / Captains Rep., Uniformed Fire Officers Assoc.; Nicholas Visconti, Chief's Rep., and Stephen Carbone, Lieutenant's Rep., Uniformed Fire Officers Assoc.; and, Joseph Gagliardi, Marine Engineers Assoc.

In addition to Thompson, trustees on the New York City Police Pension Fund are: Mayor Bloomberg; Commissioner Stark; Raymond Kelly, Chair, New York City Police Commissioner; Patrick Lynch, Police Benevolent Association; Mubarak Abdul-Jabar and Scott Williamson, Chair of the Board of Trustees, Police Benevolent Association; Thomas Scotto, Detectives Endowment Association; Edwin Mullins, Sergeants Benevolent Association; Anthony Garvey, Lieutenants Benevolent Association; and John Driscoll, Captains Endowment Association.