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Eastman Chemical 401(k) retirement plan: the investment options

Does your 401(k) vote the way you would? $5m of the $501m in the Eastman Chemical plan votes in secret. Fidelity 500 Index Fund, the most common fund in the plans we track, publishes every vote: answer 3 of its ballots, then see your result.

The question on the ballot

As filed

The Eastman Chemical 401(k) holds $501m. Of the $5m we could identify from the plan’s own filing, every dollar sits in a fund that publishes no record of how it voted your shares — collective trusts, which unlike a mutual fund file no Form N-PX and leave no public trace of a single vote.

SourceEastman Chemical’s own annual retirement-plan filing with the SEC (Form 11-K, Schedule of Assets) · open the filing

What the plan holdsVehicleVoting recordValue
Subtotal Common Stock Eastman Chemical Co Employer stock Voted by the plan trustee $217m
Eastman Chemical Companylisted as “Common Stock, Participant directed **” Employer stock Voted by the plan trustee $116m
Eastman Chemical Companylisted as “Common Stock, Non-Participant directed” Employer stock Voted by the plan trustee $101m
Subtotal Cash and Cash Equivalents Not identified from the filing Not counted either way $5m
Bank Of America Corporationlisted as “Common Stock **” Directly held shares Voted by the plan trustee $4m
Alphabet Inc Cl Clisted as “Common Stock **” Directly held shares Voted by the plan trustee $3m
Conocophillipslisted as “Common Stock **” Directly held shares Voted by the plan trustee $3m
Capital One Financial Corplisted as “Common Stock **” Directly held shares Voted by the plan trustee $2m
Eaton Corp Plclisted as “Common Stock **” Directly held shares Voted by the plan trustee $2m
Chevron Corplisted as “Common Stock **” Directly held shares Voted by the plan trustee $2m
American Express Colisted as “Common Stock **” Directly held shares Voted by the plan trustee $2m
Bank Of New York Mellon Corplisted as “Common Stock **” Directly held shares Voted by the plan trustee $2m

The 12 largest holdings in the plan. “Vehicle” is the description the filing itself gives each investment.

Why there is nothing to show

A mutual fund has to file Form N-PX every year listing every vote it cast on your behalf. A collective investment trust does not. It is a bank-run vehicle sold only inside retirement plans, it is cheaper, and it is now where most 401(k) default money sits — including most target-date funds, which is where savers who never chose anything are put.

So the shares bought with Eastman Chemical employees’ retirement savings are voted every proxy season — on executive pay, on board seats, on climate and workforce proposals — and there is no public document anywhere recording how. This is not an oversight by Eastman Chemical; it is what the disclosure rules currently require, which is to say: nothing.

What you can do

Check whether your plan offers any registered fund as an alternative — those publish their records, and you can read them here. If it does not, the menu itself is the thing that has to change, and that is a decision made by the plan’s fiduciary committee, not by you alone.

See how funds that do publish voted →

CoverageWe classified 99.1% of this plan’s assets from the filing. The figure above is the share of the money we could classify; anything we could not identify is excluded from it rather than assumed either way.

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