United States Securities and Exchange Commission
Washington, D.C. 20549
NOTICE OF EXEMPT SOLICITATION
Pursuant to Rule 14a-103
Name of the Registrant: Capital One Financial Corp
Name of persons relying on exemption: Inspire Investing, LLC
Address of persons relying on exemption: 3597 E Monarch Sky Ln, Suite 330, Meridian, ID 83646
As over 100 investors and financial professionals, serving thousands of clients and managing/ advising on over $250 billion in assets, we, the Undersigned, urge shareholders to vote YES on the Proposal Item 6 - Report on Respecting Workplace Civil Liberties submitted by National Center for Public Policy Research.
In recent years, many of the world’s largest corporations have made the decision to needlessly insert themselves into divisive political issues. Not only have companies been focused outward on political activism, but they have also turned their attention inward. Particularly problematic are workforce initiatives that focus on Diversity, Equity, and Inclusion (DEI). These initiatives have been shown, and in most cases designed, to intentionally discriminate on the basis of race, sex, religion, viewpoint, and other factors.
It is estimated that companies in the U.S. spend close to $8 billion a year on DEI training.1 Although the trend does seem to be turning, especially given the recent Supreme Court ruling against affirmative action2, companies continue to push DEI initiatives, further alienating their workforce and exposing themselves to unnecessary legal and financial risk.
While advocates of DEI claim that it promotes belonging, strengthens unity, and helps companies fight injustice, in reality DEI programs have the opposite effect. According to a survey conducted by Alliance Defending Freedom on 3,000 adults across a variety of professions, a plurality (40%) of employees say DEI divides, rather than unites, colleagues.3 Gallup polling has also confirmed that, after years of positive progress since the Civil Rights Movement, race relations in America are now at the lowest point in decades.4 Even the UK government has weighed in recently in a new report that reached the conclusion that DEI programs have little if any benefit on corporate culture (and in some cases are counterproductive or unlawful).5
These workforce concerns and related corporate activism raise serious legal, regulatory, and financial risks to companies. For example, Bowyer Research, on behalf of Alliance Defending
1 https://www.wsj.com/articles/diversity-equity-inclusion-united-kingdom-report-d73d47ed?st=a87mlghjgkpo33e&reflink=article_copyURL_share
2 https://www.reuters.com/legal/legalindustry/with-supreme-court-affirmative-action-ruling-its-time-companies-take-hard-look-2023-06-29
3 https://www.viewpointdiversityscore.org/polling
4 https://news.gallup.com/poll/1687/race-relations.aspx
5 https://www.gov.uk/government/publications/inclusion-at-work-panel-report-on-improving-workplace-diversity-and-inclusion
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Freedom, has explained how companies’ DEI policies are not only alienating members of their workforce, but also exposing the company to unnecessary legal and financial risk.6 In a recent white paper entitled Corporate Political Activism and Shareholder Value, Bowyer Research also analyzed corporate performance data from a number of different angles (including brand erosion and stock performance, risk, and risk/adjusted return) and reached the conclusion that corporate politicking on divisive social issues “at the very least raises legitimate financial concerns” for investors. 7 The Proposal would assist both the company and shareholders by identifying these sources of risks—risks that have already materialized to the substantial detriment of other companies in recent years.
In light of these growing concerns, we are calling on public companies, including Capital One Financial Corp, to provide greater transparency and disclosure to shareholders. That is why we are urging shareholders to vote YES on Proposal Item 6 that asks the company to issue a report evaluating how the company’s policies and practices impact employees and prospective employees based on their race, color, religion (including religious views), sex, national origin, or political views, and the risks those impacts present to the company’s business.
Sincerely,
The Undersigned
Robert Netzly CEO Inspire Investing | Michael Skillman CEO Faith Investor Services | Matt Monson Partner Sovereign’s Capital
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William Flaig CEO and Founder American Conservative Values ETF | Sarah Newman Vice President Innovest Portfolio Solutions, LLC | Kevin Freeman CEO and Founder Freeman Global
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Justin Bennett Associate First Trust Advisors | Dan Wallick Managing Partner & CIO Wallick Investments, LLC | Chris Murray President Murray Financial Group
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Art Ally President Timothy Plan | Matt Cunningham Investment Advisor Inspire Advisors | Ronald Thompson Financial Advisor LPL Financial
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Matthew Daugavietas Wealth Advisor Inspire Advisors | David Eck Wealth Advisor Oakstreet Financial | Borja Barragan CEO Altum Faithful Investing
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Michael Graef Financial Planner Christian Wealth Management | Paul McWilliams Founding Advisor Inspire Advisors | Matthew Bonito Financial Adivisor Upward Management Group
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6 https://www.sec.gov/Archives/edgar/data/927628/000109690624000642/bowy_px14a6g.htm
7 https://bowyerresearch.com/docs/Corporate%20Political%20Activism%20and%20Shareholder%20Value.pdf
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Luke Andrews Financial Advisor Inspire Advisors | Darrell Lyons CEO Pax Financial Group, LLC | John Wildern CEO LIFE Advisor Group
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Eric Boyum Financial Advisor Inspire Advisors | Derek Mauldin Financial Advisor/RIA Kingdom Focused Financial | Derek Hastings CFP Inspire Advisors
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Johnathan Cunningham Financial Advisor Inspire Advisors | David Zumbusch Owner & CFP Inspire Advisors MN | Terrence Rocks Founder/Advisor Teleios Financial Partners
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Matthew Baldini Wealth Advisor Inspire Advisors | Paul Bryer Financial Advisor Inspire Advisors | Aaron Hoffman Financial Advisor Inspire Advisors
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Scott Harlan Financial Planner/Practice Owner Inspire Advisors HH | Jaime Pagotto Compliance Specialist Kingdom Focused Financial | Jay Richardson Investment Advisor Kingdom Wealth Stewards
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Rick Figueroa CEO Patron Partners Wealth Advisors | Jon Nettles CEO Revo Financial | Daniel Catone CEO Arimathea
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William Poland Financial Advisor Carolina Financial Advisors | Matthew Mohlman President Monument Ventures | Kurt Spackman President/CEO Capital Resource Mgmt, Inc.
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Bruce Parmenter Financial Advisor Ameriprise Financial | Carole Murray Treasurer Murray Financial Group, Inc. | Benjamin Wilhelm CEO Lone Oak Financial
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Rachel McDonough Financial Advisor Wealth Squared | Evan Frazier Founder & CEO Tekwise Financial Planners | Jon Halverson Partner Talanton LLC
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William Feus CEO Gray Rock Financial Planning | Steve French Founding Advisor Harvest Money | IYF | Randy Umbaugh Financial Advisor Diligent Wealth Mgmt.
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Ronald Harczak Financial Advisor Steward Guide Wealth Partners | Daniel Bailey Financial Advisor Ambassador Advisors | Gerry Frigon CIO Taylor Frigon Capital
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Craig Mardi Financial Advisor Cetera Advisor Networks | Dennis Williams Financial Advisor WSI Financial Partners, LLC | Thomas Payne Founder Prosperitas Wealth Management
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Ron Zunker Financial Advisor PAX Financial Group | Nolan Dill Financial Advisor CFD Investments | Steve Ellis Financial Advisor Sage Oak Financial
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Daryl Schafer Financial Advisor Culbertson Financial Services | William Holt Financial Advisor UBS | Eric Dorman Financial Advisor Affiliated Financial Planners
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Mark Trice Financial Advisor ClearVista Financial | Michael Smith Founder/CEO Kingdom Focused Financial | Joseph James Vice President Greater Texas Financial Solutions
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William Woodyard Vice President LifeSmart Financial
| Brock Baker Financial Advisor Inspire Advisors | Doug Gathright Financial Advisor LifeSmart Financial |
George Williams Financial Advisor WSI Financial Partners LLC | Jacob Chandler Owner/Financial Advisor Chandler Wealth Mgmt, Inc. | Jevon Webster CFP Inspire Advisors
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Douglas Hanson Financial Advisor Christian Wealth Management | Ryan DeAmicis Wealth Advisor Christian Wealth Management | Jesse Hamilton Financial Advisor ClearVista Financial
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Erik Bloomfeldt Investment Advisor Insight Financial | Heidi Foster Vice President American Wealth Management | Dr. Erik Davidson Asst. Clinical Professor of Finance Baylor University
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John Moore Founder John Moore Associates | Ron Bergenske Financial Advisor LPL Financial | Kenneth Wince Financial Advisor LPL Financial
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Micky Reeves Senior Wealth Advisor EverSource Wealth Advisors | Jerrold Ganz Financial Advisor Jerry Ganz Financial Planning | Charles Immekus Financial Advisor Dedicated Financial Services
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Jeff Hybiak CIO SEM Wealth Management | Beau Zumbusch CEO Inspire Advisors Minnesota | Ed Lytle Financial Advisor ERL Financial Services, LLC
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Shane Enete Associate Professor of Finance Biola University | Laura Simpson Financial Advisor PAX Financial Group | Daniel Hardt Managing Partner Dan Hardt Financial Services
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Jonathan Hunt Financial Advisor Intentional Wealth | Matt Carr Owner/Financial Advisor TruPurpose Advisors | Salvador Rodriguez Financial Advisor Cetera Financial Specialists
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John Ruzza CFP Cambridge | Mark Nicholas Founder/Financial Adviser Transform Retirement | Tony Adkison Financial Advisor Stewardship Advisory Group
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Henry Groves Financial Advisor Stephens, Inc. | Paul Carlson Owner/Wealth Manager 4:8 Financial | Matthew Holt Financial Advisor CWM
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James Jon Benet Financial Advisor Triumphant Portfolio Mgmt, LLC
| Larry Moss Certified Financial Planner Northwest Investments | J. Michael Salley President/CEO Salley Wealth Advisors Group
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Brent Jackson President Harvest Financial | Jerry Bowyer President Bowyer Research | Mike Ching Founder/President Nardene Wealth Management
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Andrew Lehman Financial Advisor Inspire Advisors | Joseph Verissimo Owner/Financial Advisor Christian Wealth Management | Andrew Hreha Institutional Fixed Income Stephens, Inc.
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Joseph Allen Financial Advisor/RIA Inspire Advisors | Gerard Farkas Owner Gerard Farkas & Associates | Ryan Munoz Wealth Advisor Inspire Advisors
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Luke Zumbusch Financial Planner Inspire Advisors MN | Thomas Strobhar President Strobhar Financial | Stephen Werner Financial Advisor/RIA Covenant Financial Group
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Robert Franer III Owner/Wealth Advisor Castellum Financial Advice | James Kreid President Rock Solid Retirement Strategies | Mark Reynolds Wealth Advisor Terrier Financial Group
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| Scott Shepard Director, Free Enterprise Project National Center for Public Policy Research |
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