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Norfolk Southern 401(k) retirement plan: the investment options

Does your 401(k) vote the way you would? $899m of the $1.71bn in the Norfolk Southern 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

Norfolk Southern 401(k) match and balances, from the filing

Company money in
about $3,210 per active participant
$15m in plan year 2024
Employees saved
about $9,140 each
$42m in plan year 2024
Average balance
$237,200
6,541 people with a balance
In the plan
$1.55bn
at the end of plan year 2024

Company money is the match plus any other employer contributions, averaged over all 4,579 active participants, including anyone who did not contribute. The filing reports dollars, not the match formula; the plan’s summary plan description states the formula.

SourceThe plan’s annual report to the Department of Labor — Form 5500, Schedule H, plan year 2024 · filed by NORFOLK SOUTHERN CORPORATION as “THRIFT AND INVESTMENT PLAN OF NORFOLK SOUTHERN CORPORATION AND PARTICIPATING SUBSIDIARY COMPANIES” · EIN 521188014, plan number 002 · search the filings

The Norfolk Southern 401(k) holds $1.71bn. Of the $899m 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.

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

What the plan holdsVehicleVoting recordValue
for NS stocklisted as “units of NS Stock Fund” Not identified from the filing Not counted either way $308m
The Vanguard Group, Inc.listed as “units of Vanguard Institutional 500 Index Trust C” Collective trust or separate account NONE $193m
The Vanguard Group, Inc.listed as “shares of Vanguard Growth Index Fund Institutional Shares” Not identified from the filing Not counted either way $188m
The Vanguard Group, Inc.listed as “shares of Vanguard Wellington Fund Admiral Shares” Not identified from the filing Not counted either way $120m
The Vanguard Group, Inc.listed as “units of Vanguard Institutional Total International Stock Market Index Trust C” Collective trust or separate account NONE $106m
The Vanguard Group, Inc.listed as “units of Vanguard Institutional Total Bond Market Index Trust C” Collective trust or separate account NONE $84m
The Vanguard Group, Inc.listed as “units of Vanguard Target Retirement 2050 Trust I” Collective trust or separate account NONE $76m
The Vanguard Group, Inc.listed as “units of Vanguard Target Retirement 2045 Trust I” Collective trust or separate account NONE $72m
The Vanguard Group, Inc.listed as “units of Vanguard Retirement Savings Trust III” Collective trust or separate account NONE $69m
The Vanguard Group, Inc.listed as “units of Vanguard Target Retirement 2035 Trust I” Collective trust or separate account NONE $68m
The Vanguard Group, Inc.listed as “shares of Vanguard Value Index Fund Institutional Shares” Not identified from the filing Not counted either way $65m
The Vanguard Group, Inc.listed as “units of Vanguard Target Retirement 2040 Trust I” Collective trust or separate account NONE $58m

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 Norfolk Southern 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 Norfolk Southern; 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 53.5% 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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The largest employer plans on the site, and a few more. Each page shows what the plan’s funds did with the shares its savers paid for.

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