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Southwest Airlines 401(k) retirement plan: the investment options

Does your 401(k) vote the way you would? $15.35bn of the $15.80bn in the Southwest Airlines 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

Southwest Airlines 401(k) match and balances, from the filing

Company money in
about $6,490 per active participant
$482m in plan year 2024
Employees saved
about $6,670 each
$495m in plan year 2024
Average balance
$199,200
85,318 people with a balance
In the plan
$16.99bn
at the end of plan year 2024

Company money is the match plus any other employer contributions, averaged over all 74,221 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 SOUTHWEST AIRLINES CO. as “SOUTHWEST AIRLINES CO. RETIREMENT SAVINGS PLAN” · EIN 741563240, plan number 004 · search the filings

The Southwest Airlines 401(k) holds $15.80bn. Of the $15.35bn 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.

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

What the plan holdsVehicleVoting recordValue
Jennison Associateslisted as “Harbor Capital Appreciation Trust units” Collective trust or separate account NONE $2.81bn
Vanguardlisted as “500 Index Trust units” Collective trust or separate account NONE $2.22bn
Dodge and Coxlisted as “Stock Fund units” Collective trust or separate account NONE $2.12bn
Vanguardlisted as “Vanguard Target Retire 2035 Trust units” Collective trust or separate account NONE $962m
Vanguardlisted as “Vanguard Target Retire 2030 Trust units” Collective trust or separate account NONE $926m
Vanguardlisted as “Vanguard Target Retire 2040 Trust units” Collective trust or separate account NONE $841m
Vanguardlisted as “Vanguard Target Retire 2045 Trust units” Collective trust or separate account NONE $762m
Vanguardlisted as “Vanguard Target Retire 2050 Trust units” Collective trust or separate account NONE $694m
Southwest Airlines Co.listed as “Common Stock units” Collective trust or separate account NONE $595m
The American Funds Grouplisted as “Captial Group Europacific Growth Trust units” Collective trust or separate account NONE $544m
Vanguardlisted as “Vanguard Target Retire 2055 Trust units” Collective trust or separate account NONE $501m
Vanguardlisted as “Vanguard Target Retire 2025 Trust units” Collective trust or separate account NONE $497m

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 Southwest Airlines 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 Southwest Airlines; 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 100% 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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