ESG

Testimony Before the Iowa House Subcommittee on Judiciary in Support of HF 922

By

 Testimony Before the Iowa House Subcommittee on Judiciary in Support of HF 922

Samantha Vick, Senior State Government Relations Manager

Heartland Impact

February 3, 2026

Chairman Holt and Members of the Subcommittee:
Thank you for holding this hearing on HF 922 and allowing me to speak on this bill.

My name is Samantha Vick and I am the Senior State Government Relations Manager at Heartland Impact. Heartland Impact is the advocacy and outreach arm of The Heartland Institute. Both are independent, national, nonprofit organizations working to discover, develop, and promote free-market solutions to social and economic problems. Heartland specializes in providing state lawmakers the policy and advocacy resources to advance free-market policies towards broad-based economic prosperity.

As you are likely well aware of, environmental, social, and governance (ESG) scores are essentially a risk assessment mechanism increasingly being used by investment firms and financial institutions that forces companies, entire industries like agriculture, and society at large to focus upon politically motivated, subjective goals. Pursuing these goals often directly contravenes the interests of companies, shareholders, and customers, while also degrading macroeconomic prosperity, free markets, democratic institutions, and individual liberty.

HF 922 prohibits financial institutions from using a social credit scoring system that evaluates a person’s “speech, religious exercise, association, expression, or conduct protected by the first amendment to the Constitution of the United States, Article I of the Constitution of the State of Iowa, or federal or state law.” Further, it prohibits a financial institution from using this system to negatively impact a person for their failure or refusal to “adopt targets or disclosures related to greenhouse gas emissions beyond targets or disclosures required by state and federal law, conduct a racial, diversity, or gender audit or disclosure, or provide a quota, preference, or benefit based on race, diversity, or gender, [or] facilitate or assist an employee in obtaining an abortion or gender reassignment services,” as well as their “participation in business activities related to a manufacturer or dealer of firearms and ammunition, or business activities with an oil or gas company.”

ESG-driven financial discrimination against entire groups—whether whole industries like agriculture, companies, or individuals—has been prolific. For example, in 2018, some large U.S. banks, including Citibank and Bank of America, implemented restrictions for gun manufacturers and retailers. According to a report by the New York Times, banks are “restricting their credit card and banking services to gun retailers and halting lending to gun makers that do not comply with age limits and background check rules determined by the banks. They are also freezing out businesses that sell high-capacity magazines and ‘bump stocks,’ attachments that enable semiautomatic rifles to fire faster, even though such products are legal under federal law.”i

Deutsche Bank AG and Signature Bank announced in early 2021 that they would no longer provide services to President Donald Trump or his business, the Trump Organization.ii

Also in 2021, Sustainalytics, an ESG business owned by Morningstar, published a report titled How Sustainable Finance is Shaping Change in Banking.iii In the publication, Sustainalytics notes:

Most major banks screen their lending portfolios against specific ESG risks as per the OECD Due Diligence guidance, and many embrace negative or positive screening for potential corporate lending transactions or project finance transactions. Screening strategies filter potential transactions using predetermined ESG criteria to rule companies in or out of contention for financing. Negative screening and norm-based screening involve the exclusion or avoidance of transactions not aligned with environmental, social and ethical standards. Exclusion criteria often include issues like weapon manufacturing, tobacco sales or production of fossil fuels. While negative and norm-based screening are the most popular techniques used for ESG asset management, these practices have been losing traction since 2015.

Positive screening, on the other hand, selects corporate borrowers that score highly on ESG factors relative to their peers. This can include best-in-class screening, or the inclusion of investments in companies and sectors with higher ESG scores as compared to their peers or companies that are actively improving their ESG performance. This screening method does not necessarily exclude ESG laggards but rather focuses on those performing best with regards to ESG in relation to comparable companies or industries. In comparison to corporate lending transactions, the intensity of screening is often higher for project finance transactions given due diligence requirements under the Equator Principles.

Dozens of the world’s most powerful banks and insurance companies have, to varying degrees, weaponized ESG to screen out businesses and even some individuals who refuse to comply with those institutions’ social justice or environmental policies. Although there are many examples of financial institutions flexing their muscles as a tactic to create larger societal changes through ESG, perhaps the most economically important is that virtually every large bank in the United States has committed to forcing the businesses they work with to phase out their use of fossil fuels—even if it causes economic harm to customers and businesses.

Many of these financial institutions have pledged to make their entire business portfolios “net-zero emissions” by 2050, and to halve their emissions by 2030.iv If fulfilled, these pledges would necessitate that banks eliminate all or nearly all lending and banking activities with customers who use fossil fuels, including individuals who drive gasoline- powered motor vehicles, significantly impacting virtually every family and industry in the United States.

Most major U.S. banks—including JP Morgan Chase, Citigroup, Bank of America, Wells Fargo, Goldman Sachs, and Morgan Stanley, among others—have announced restrictions on financing for certain fossil fuel projects as well, such as coal mining and oil and natural gas projects. In addition, financial institutions such as JP Morgan Chase, Bank of America, Wells Fargo, and U.S. Bank and credit card processors such as PayPal have discriminated against faith-based organizations.v

Discrimination has also been endemic among major insurance companies. Many of them across the globe have implemented policies refusing to underwrite fossil fuel projects, including Allianz, AXA, Swiss RE, Munich RE, Zurich Insurance Group, The Hartford, Chubb, and AIG.vi

For a recent example, Zurich announced in 2024 it would cease underwriting new oil and gas exploration and development projects, as well as metallurgical coal mining. The insurer also now requires its highest-emitting corporate clients to adopt credible climate transition plans aligned with a 1.5°C pathway and the goal of net-zero emissions by 2050. The company has stated it will review these clients’ progress and may terminate relationships that fail to show sufficient transition momentum.vii

Chubb also updated its policies in 2024, announcing that it would continue to provide coverage for oil and gas producers with annual revenues greater than $1 billion that are demonstrating progress towards achieving near-zero methane emissions—0.2 percent— but that it may “decline coverage if a potential policyholder cannot meet our methane performance expectations.”viii

That August, the company withdrew its insurance coverage for the Rio Grande liquefied natural gas project in Brownville, Texas—one of the largest proposed fossil fuel infrastructure investments in the state.ix

Many of ESG’s metrics, primarily those related to imposing environmental controls, are directly linked to the agricultural industry and food production. Examples of some of these metrics include: “Paris-aligned GHG emissions targets,” “Impact of GHG [greenhouse gas] emissions,” “Land use and ecological sensitivity,” “Impact of air pollution,” “Impact of freshwater consumption and withdrawal,” “Impact of solid waste disposal,” and “Nutrients”— which, despite its innocuous-sounding name, is a metric that forces companies to estimate the “metric tonnes of nitrogen, phosphorous, and potassium in fertilizer consumed.”x Farmers and food producers use chemical fertilizers and pesticides for crop growth, in addition to producing waste byproducts, consuming substantial quantities of water, using vast swathes of land, and releasing what climate alarmists claim to be planet-ending carbon dioxide emissions.

The world has already experienced adverse food supply shocks caused directly and/or indirectly by ESG mandates, with the most prevalent occurring in Sri Lanka, where a regulatory ban on chemical fertilizers cut crop production nearly in half and resulted in societal upheaval that toppled the Sri Lankan government. Other disruptions in food supply related to ESG have occurred throughout Europe— especially in the Netherlands—as well as in Canada and the United States.xi

In the United States in particular, investment giants and banking behemoths had signed on to international agreements such as the United Nations-led Glasgow Financial Alliance for NetZero (GFANZ), a global coalition dedicated to climate change mitigation efforts organized under the auspices of the United Nations.xii Reading the tea leaves from the last presidential election, many of these firms, such as Bank of America, Citi, Goldman Sachs, JP Morgan, and Wells Fargo have since left the alliance. Back in 2021, GFANZ consisted of approximately 450 banks, investors, and insurance companies, whose members controlled $130 trillion in assets. Through GFANZ and its industry subgroups, such as the Net-Zero Asset Managers Initiative and the Net-Zero Banking Alliance—which controlled 41 percent of global banking assets in 2021, but has since folded—the world’s biggest investors and banks agreed to set United Nations-approved emissions targets for their agricultural clients by 2024.xiii

Similar to the disastrous policies in Sri Lanka and elsewhere, nitrogen-based fertilizer use is being heavily targeted in the United States, and farmers are being urged to electrify their equipment as well as curtail meat and dairy production to create products that have

“lower carbon-dioxide footprints,” to name only a few examples.xiv Farmers will soon be under enormous pressure to undertake these “voluntary” changes and reduce their emissions or risk being frozen out of bank financing.xv

A report released in 2024 by Ohio’s Buckeye Institute found that operating expenses for farmers under an ESG reporting system would increase by 34 percent, leading to more expensive groceries.xvi Items like American cheese (79 percent), beef (70 percent), strawberries (47 percent), and chicken (39 percent), just to name a few examples, would increase significantly. Overall, the report estimates a 15 percent total increase in household grocery bills if ESG scoring is implemented.

Ultimately, ESG-driven financial discrimination—whether carried out by investment firms or insurance conglomerates—imposes political orthodoxy at the expense of sound risk assessment, consumer choice, and economic vitality. The common-sense provisions in HF 922 would go far in protecting the Iowa economy and Iowa companies from discrimination and denial of basic financial services. It would also ensure that radical activists, many from outside of the Hawkeye State and outside of this country, will not control the means of production and curtail the freedoms of each and every Iowan. This is why I urge you to vote to pass this bill.

Thank you for your time.

Heartland Impact can send an expert to your state to testify or brief your caucus; host an event in your state; or send you further information on a topic. Please don’t hesitate to contact us if we can be of assistance! If you have any questions or comments, contact us at contact@heartlandimpact.org or 312/377- 4000.

i Alan Rappeport, “Banks Tried to Curb Gun Sales. Now Republicans Are Trying to Stop Them,” New York Times, May 25, 2018, https://www.nytimes.com/2018/05/25/us/politics/banks-gun-sales- republicans.html.

ii Shahien Nasiripour, “Professional Bank joins lenders refusing to do business with the Trump Organization,” Fortune, January 12, 2021, https://fortune.com/2021/01/12/professional-bank- lending-services-business-trump-organization/.

iii How Sustainable Finance is Shaping Change in Banking, Sustainalytics,
2021, https://connect.sustainalytics.com/scs-ebook-how-sustainable-finance-shaping-banking.

iv Eamon Barrett, “Wells Fargo is the last of the Big Six banks to issue a net-zero climate pledge. Now comes the hard part,” Fortune, March 9, 2021, https://fortune.com/2021/03/09/wells-fargo- climate-carbon-neutral-net-zero/.

v ViewpointDiversityScore.org, “Instances of Viewpoint-Based De-Banking,” accessed April 23, 2025, https://www.viewpointdiversityscore.org/resources/instances-of-viewpoint-based-de- banking.

vi Insure Our Future, “Fifty Years of Climate Failure: 2023 Scorecard on Insurance, Fossil Fuels, and the Climate Emergency,” November 2023, https://global.insure-our-future.com/wp- content/uploads/2023/11/IOF-2023-Scorecard.pdf.

vii Kenneth Araullo, “Zurich Insurance stops underwriting new fossil fuel projects,” InsuranceBusinessMag.com, April 8, 2024,

https://www.insurancebusinessmag.com/us/news/environmental/zurich-insurance-stops- underwriting-new-fossil-fuel-projects-484241.aspx.

viii Chubb, “Chubb’s Corporate Climate Underwriting Criteria Summary,” Updated March
2025, https://about.chubb.com/content/dam/chubb-sites/chubb/about- chubb/citizenship/environment/pdf/chubb-corporate-climate-underwriting-criteria-for-high- emitting-industries.pdf.

ix Tyler Kruse, “Chubb Drops Rio Grande LNG Insurance,” Insure Our Future, August 6, 2024, https://us.insure-our-future.com/chubb-drops-rio-grande-lng-insurance.

x Jonathan Walter et al., “Toward Common Metrics and Consistent Reporting of Sustainable Value Creation,” World Economic Forum, September,
2020, http://www3.weforum.org/docs/WEF_IBC_Measuring_Stakeholder_Capitalism_ Report_2020.pdf.

xi Jack McPherrin, “ESG: Negative Effects on Food Supply and Agriculture,” Policy Tip Sheet, The Heartland Institute, September 19, 2022, https://heartland.org/wp- content/uploads/2022/12/PolicyTipSheetESG5.pdf; Jack McPherrin, Environmental, Social, and Governance (ESG) Scores: A Threat to Individual Liberty, Free Markets, and the U.S. Economy, The Heartland Institute, April 26, 2023, https://heartland.org/wp-content/uploads/2023/04/2023- ESG-ReportvWeb-2.pdf.

xii Glasgow Financial Alliance for Net-Zero (GFANZ), “Amount of finance committed to achieving 1.5°C now at scale needed to deliver the transition,” November 3,
2021, https://www.gfanzero.com/press/amount-of-finance-committedto-achieving-1-5c-now- atscaleneeded-to-deliver-the-transition/.

xiii Simon Jessop & Virginia Furness, “Net-Zero Banking Alliance folds after mass exodus by members,” Reuters, October 3, 2025, https://www.reuters.com/sustainability/cop/net-zero-banking-alliance- stop-operations-after-member-vote-2025-10-03/.

xiv Nako Kobayashi and Meryl Richards, “Global Sector Strategies: Recommended Investor Expectations for Food and Beverage,” Climate Action 100+, Ceres, and Principles for Responsible Investment, August 2021, https:// www.climateaction100.org/wp- content/uploads/2021/08/Global-Sector-Strategies-Food-and-Beverage-Ceres-PRIAugust-2021.pdf.

xv Jack McPherrin, “ESG: Financial Discrimination,” Policy Tip Sheet, The Heartland Institute, November 28, 2022, https://heartland.org/wp- content/uploads/documents/PolicyTipSheetESG8src.pdf.

xvi Trevor W. Lewis & M. Ankith Reddy, Net Zero Climate Control Policies Will Fail the Farm, The Buckeye Institute, February 7, 2024, https://www.buckeyeinstitute.org/library/docLib/2024-02-07- Net-Zero-Climate-Control-Policies-Will-Fail-the-Farm-policy-report.pdf.

  • Samantha Fillmore

    Samantha Fillmore is the Senior State Government Relations Manager at Heartland Impact. Samantha specializes in Budget & Tax issues, State of Emergency Statutes, Governor's Powers, Big Tech Censorship, and Free Speech.