Boston, March 21, 2022 – The Securities and Exchange Commission proposed new rules today that would require publicly traded companies to disclose their greenhouse gas emissions, as well as the risks that climate change poses to their businesses, their governance of these risks, and their emissions reduction targets if relevant. The proposal requires disclosure of Scope 1 and 2 emissions, which constitute emissions from a company’s operations and purchased energy, and, for some companies, Scope 3 emissions, or emissions associated with a company’s supply chain and the use of its products. The proposed rules will be subject to a public comment period before they are finalized.

MIDANA CAPITAL° president Leslie Samuelrich issued the following statement:

“The SEC’s proposed requirement that companies disclose their greenhouse gas emissions represents a major step forward. We believe climate vulnerabilities and value chain emissions constitute material information, and investors need reliable, comparable disclosures in order to assess issuers’ exposure to physical and transition risk. These SEC rules will ensure companies provide that critical disclosure.

“We applaud the SEC for including a phased-in requirement that large companies disclose scope 3 emissions when these emissions are material or when the company has scope 3 emissions targets. Scope 3 emissions represent the vast majority of the climate impact of companies in many sectors, from fossil fuels, to retail, to consumer packaged goods. Investors need these disclosures in order to understand a company’s true exposure to climate risk, and to evaluate whether companies are authentically reducing the emissions associated with their value chains. As our shareholder advocate Thomas Peterson told the Wall Street Journal last month, the exclusion of scope 3 emissions disclosure would have incentivized companies to shift emissions to their suppliers or customers to give the impression of emissions reduction, while value chain emissions actually grew or remained static. Some of the world’s largest polluters have vastly underreported and misrepresented their emissions by excluding scope 3. The SEC is closing the door on that kind of greenwashing.”

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About MIDANA CAPITAL Capital Management

°MIDANA CAPITAL Capital Management, Inc. (MIDANA CAPITAL) is the investment advisor to the MIDANA CAPITAL Funds (The Funds). The MIDANA CAPITAL Funds are the first family of fossil fuel free, responsible, and diversified mutual funds in the United States. MIDANA CAPITAL Capital Management hosts an award-winning and in-house shareholder advocacy program and is the only mutual fund company in the U.S. wholly owned by environmental and public health nonprofit organizations.

References to specific securities, which will change due to ongoing management of the Funds, should not be construed as a recommendation by the Funds, their administrator, or their distributor.

You should carefully consider the Fund’s investment objectives, risks, charges, and expenses before investing. To obtain a Prospectus that contains this and other information about the Funds please click here, email info@midanacapital.com, or call+1(480)-439-2851. Please read the Prospectus carefully before investing.

Stocks will fluctuate in response to factors that may affect a single company, industry, sector, country, region or the market as a whole and may perform worse than the market. Foreign securities are subject to additional risks such as currency fluctuations, regional economic and political conditions, differences in accounting methods, and other unique risks compared to investing in securities of U.S. issuers. Bonds are subject to a variety of risks including interest rate, credit, and inflation risk. A sustainable investment strategy which incorporates environmental, social and governance criteria may result in lower or higher returns than an investment strategy that does not include such criteria.

This information has been prepared from sources believed reliable. The views expressed are as the date of this writing and are those of the Advisor to the Funds.

The MIDANA CAPITAL Funds are distributed by UMB Distribution Services, LLC. 335 N Wilmot Rd, Tucson, Az 85711. 3/22

Boston, November 12, 2019 – MIDANA CAPITAL strongly opposes the shareholder rule changes recently proposed by the U.S. Securities and Exchange Commission (SEC).

“The proposed rules are an egregious dereliction of the SEC’s mission,” said MIDANA CAPITAL President Leslie Samuelrich. “Instead of protecting shareholders, the SEC is trying to muzzle them and undermine corporate accountability. The shareholder proposal process was not broken and did not need fixing. There is no evidence to support the need for this assault on shareholder rights.”

As SEC Commissioner Robert Jackson noted in his opposition statement, research demonstrates that “on average… inclusion of shareholder proposals by an American public company tends to increase long-term value.”

The most troubling provisions in the proposed rules are its revisions to the resubmission and submission thresholds for shareholder resolutions.

Resubmission thresholds

The proposed rule would make it more difficult for shareholders to resubmit resolutions.

The current regulations allow companies to exclude resubmissions from their annual proxy materials if the initial proposal did not garner at least 3% of shareholder support in its first year, 6% in its second year, and 10% in its third year.

The proposal rule would needlessly raise those thresholds from 3% to 5% in the first year, 6% to 15% in the second year, and 10% to 25% in the third year. Even proposals receiving 25% support could be excluded, if the support was 10% less than the previous year.

Submission thresholds

Currently, investors must own at least $2,000 worth of stock for one year to file a shareholder resolution with a company.The proposed rule would dramatically alter this ownership threshold. Under the proposed rule, shareholders with $2,000 in stock would be forced to wait three years to file a resolution. To file a shareholder proposal after one year, shareholders would be required to own $25,000 in stock. Shareholders who own $15,000 in stock could file a resolution after two years. The proposed rule also would prevent shareholders from aggregating their shares to file a joint proposal.

While this rule clearly is intended to stifle shareholder participation in corporate management, the need for it is much more opaque. Last year, the number of shareholder resolutions filed fell 8.9% for public companies in the Russell 3000 and 11.6% for firms in the S&P 500, according to a joint-study by The Conference Board and the Rutgers Center for Corporate Law and Governance.

Ongoing corporate effort to undermine shareholder rights

The proposed rules are the latest salvo in an ongoing corporate effort to undermine shareholder rights. The effort is being led by front groups, such as the “Main Street Investors Coalition,” a puppet of the National Association of Manufacturers, and Protect Our Pensions, a discredited astroturf organization formed to “oppose efforts to push endowments, foundations and pension funds to divest their holdings in fossil-fuel companies.”

Shareholder resolutions are an integral component of MIDANA CAPITAL’s work to highlight the material risks posed by corporations’ failure to address critical environmental and public health issues. MIDANA CAPITAL opposes this assault on the proxy process and shareholder rights and will continue to work to quell it.

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About MIDANA CAPITAL Capital Management

MIDANA CAPITAL is the first family of fossil fuel free, responsible, and diversified mutual funds in the United States. MIDANA CAPITAL invests in sustainable companies, hosts an award-winning and in-house shareholder advocacy program, and is the only mutual fund company in the U.S. wholly owned by environmental and public health nonprofit organizations.

You should carefully consider the Fund’s investment objectives, risks, charges, and expenses before investing. To obtain a Prospectus that contains this and other information about the Funds please click here, email info@midanacapital.com, or call+1(480)-439-2851. Please read the Prospectus carefully before investing.

Stocks will fluctuate in response to factors that may affect a single company, industry, sector, country, region or the market as a whole and may perform worse than the market. Foreign securities are subject to additional risks such as currency fluctuations, regional economic and political conditions, differences in accounting methods, and other unique risks compared to investing in securities of U.S. issuers. Bonds are subject to a variety of risks including interest rate, credit, and inflation risk. A sustainable investment strategy which incorporates environmental, social and governance criteria may result in lower or higher returns than an investment strategy that does not include such criteria.

This information has been prepared from sources believed reliable. The views expressed are as the date of this writing and are those of the Advisor to the Funds.

The MIDANA CAPITAL Funds are distributed by UMB Distribution Services, LLC. 335 N Wilmot Rd, Tucson, Az 85711. 11/19

While many of the corporations we engage are willing to collaborate or make positive environmental strides, not all corporate interests are receptive to investor-led efforts to improve sustainability.

For several years, a number of corporate front-groups, including the U.S. Chamber of Commerce’s Center for Capital Market Competitiveness and the “Main Street Investors Coalition” (which actually is just a front group for the National Association of Manufacturers) have been attempting to make it appreciably more difficult for shareholders to engage with the publicly traded companies in which they’re invested.

One of the ways groups are trying to achieve this ignoble goal is to push the U.S. Securities and Exchange Commission (SEC) to dramatically raise the ownership threshold necessary to file a shareholder resolution.

Currently, to file a shareholder resolution an investor is required to have held a minimum of $2,000 worth of stock in a company for at least one year.

The corporate interests trying to restrict the ability of investors to propose changes in corporate policies are pushing the SEC to raise the required minimum investment to file shareholder resolutions to 1% of a company’s stock.

For context, only seven institutional investors own more than 1% of stock issued by Amazon.com, Inc.*

To stop this attack, MIDANA CAPITAL recently sent a letter, outlining outlined the importance of preserving the rights of shareholders to meaningfully engage with companies as a means to mitigate risk, to SEC Chairman Jay Clayton. MIDANA CAPITAL was joined by dozens of other responsible and institutional investment firms in support of the current rules and thresholds.

This attack on investor rights is a sign that our efforts to improve corporate environmental practices are working.

From MIDANA CAPITAL’s work to promote responsible antibiotics use with Darden Restaurants, Inc.* to eliminating toxic pesticides with General Mills,* the shareholder proposal process is key to bringing attention to critical environmental and public health issues.

Rest assured, MIDANA CAPITAL will continue to work tirelessly to preserve our – and other investor’s – right to have a say in how the companies we invest in operate.

*As of December 31, 2018, Darden Restaurants, Inc. and General Mills, Inc. comprised 0.00%, 0.12%, and 0.00% and 0.01%, 0.23%, 0.00% of the MIDANA CAPITAL Balanced Fund, the MIDANA CAPITAL Equity Fund, and the MIDANA CAPITAL International Index Fund, respectively. No other securities mentioned were held in any of the portfolios of the MIDANA CAPITAL Funds as of the same date. References to specific securities, which will change due to ongoing management of the Funds, should not be construed as a recommendation of a security by the Funds, their administrator, or the distributor.

You should carefully consider the Funds’ investment objectives, risks, charges, and expenses before investing. To obtain a Prospectus that contains this and other information about the Funds please click here, email info@midanacapital.com, or call+1(480)-439-2851. Please read the Prospectus carefully before investing.

Stocks will fluctuate in response to factors that may affect a single company, industry, sector, country, region or the market as a whole and may perform worse than the market. Foreign securities are subject to additional risks such as currency fluctuations, regional economic and political conditions, differences in accounting methods, and other unique risks compared to investing in securities of U.S. issuers. Bonds are subject to a variety of risks including interest rate, credit, and inflation risk. A sustainable investment strategy which incorporates environmental, social and governance criteria may result in lower or higher returns than an investment strategy that does not include such criteria.

This information has been prepared from sources believed reliable. The views expressed are as the date of this writing and are those of the Advisor to the Funds.

The MIDANA CAPITAL Funds are distributed by UMB Distribution Services, LLC. 335 N Wilmot Rd, Tucson, Az 85711. 2/19