On April 10th, 2023, New Hampshire Governor Chris Sununu signed Executive Order 2023-03, which expresses anti-ESG views and mandates that “Executive branch agencies shall prioritize investment decisions that maximize financial returns and minimize risk.” Veris CEO Stephanie Cohn Rupp wrote the following letter to Governor Sununu in response. As of May 16, 2023, we have not yet received a reply. 

Governor Sununu, 

Veris Wealth Partners is a wealth management firm and a long-time employer in Portsmouth, New Hampshire. We also have a 100% focus on impact and ESG investing. We strongly object to Executive Order 2023-03. I wanted to express my concern and offer to meet with you to discuss what ESG investing is and is not. Many Republican officials have been misinformed and do not know that ESG investing can provide a variety of benefits including better corporate governance (and less corporate crises), better long-term financial returns, and better outcomes for the environment. 

I believe you are signing this order at the expense, not only of investors, but all Granite State residents and ecosystems, especially those in coastal communities that are at high risk of damage from climate change driven sea level rise. 

As a firm, Veris believes that the integration of environmental, social, and governance (ESG) principles in portfolio selection can mitigate risk and have a positive impact on investment returns. We serve many New Hampshire residents who want to see their investments help them achieve their financial goals in a way that does not compromise the environment or their values. 

In our view, Executive Order 2023-03 provides no benefit to our state or its citizens and misleads Granite Staters about what it means to consider ESG factors in the investment decision-making process. The Order states the following premises:  

“WHEREAS, fiduciaries’ investment decisions based on non-financial considerations may fail to meet the financial needs of the State and its citizens; and WHEREAS, investment decisions based on non-financial considerations may include environmental, social, and governance (ESG) criteria which have shown to produce lower returns compared to investment decisions based on financial considerations alone; and WHEREAS, the pursuit of ESG goals may result in suboptimal investments that fail to meet the fiduciary obligations that State entities investing taxpayer and beneficiary funds owe to their investors.” 

We believe your presumption that consideration of ESG criteria in the investment making process equates to an abandonment of fiduciary duty that produces “lower returns” is not supported by the preponderance of evidence. I serve on the board of The Forum for Sustainable and Responsible Investment (US SIF), which has a repository of studies showing that, “sustainable investment funds on average over the long-term achieve comparable or even better financial returns than conventional investments.”¹ 

Our firm’s investment philosophy is centered on our belief, based on our own research and experience, that ESG integrated investing is an approach that can yield positive outcomes of a portfolio while achieving the performance of the representative asset class. 

ESG is a lens applied to investment due diligence that integrates real world impacts. New Hampshire’s state retirement system can adhere to its fiduciary duty to obtain market rate returns while also considering the short- and long-term material impacts of those investments on the environment, workers, and members of the communities in which those investable businesses operate. 

It appears that this anti-ESG Executive Order is either based on misunderstandings about the practice of ESG or it is an exercise in partisan politics. Your Order mandates that:

“Executive Branch agencies that are permitted to invest funds shall review their investments and pursue any necessary steps to ensure that no funds or state-controlled investments are invested with firms that invest New Hampshire funds in accounts solely based on ESG criteria. 

The word “solely” seems to have been chosen very carefully here. Considering ESG criteria in the investment decision-making process does not mean an abandonment of traditional quantitative analysis of financial risk and return. There are very few, if any, instances of funds that are assembled solely on the basis of ESG criteria. 

We hope that you reconsider your position on ESG and I invite you to meet with me to discuss this issue. I believe it would be helpful for you to hear perspectives other than those issued by partisan critics. In any case, please look to other states that have already enacted anti-ESG legislation to see what may come of it. The editorial board of the Miami Herald pointed to losses already seen in other states in a recent opinion that called the Florida Governor’s “assault” on ESG investing “exceptionally nonsensical.”² They opined that pending Florida legislation banning local government entities from investing in funds or purchasing bonds based on social, political or ideological interests, “stands to harm Florida pensioners and taxpayers across the board.”³ 

There is already evidence that residents of states that have passed ESG bans are paying a financial cost for the shortsighted actions of their legislators. To cite one example, a recent study found that anti-ESG laws in Texas were linked to higher costs for Texas borrowers in the millions of dollars.4 By banning certain financial options and certain financial firms – Texas decreased competition available to their pension systems and paid a very heavy price. Especially in a State whose motto is “Live Free or Die,” I find it incongruent to ban any financial option, especially one that provides more information on the real-world impacts of finance. You are not banning an ideology – but banning a methodology which is meant to empower investors. 

We hope that New Hampshire does not go down that path. Barring retirement plan fiduciaries from considering ESG factors, as New Hampshire’s House of Representatives just considered, would have likely to expose New Hampshire’s pensioners to risks that may come with a high cost. 

With climate change posing future threats to coastal states, we believe New Hampshire’s pensioners are not the only residents of the state who would be exposed to greater risks in the absence of ESG investing. According to a report by the New Hampshire Coastal Risks and Hazards Commission, the NH seacoast is likely to see its relative sea level rise up to 1.3 feet by 2050 and up to almost 3 feet by 2100 if global greenhouse gas concentrations stabilize.⁵ NH’s own Fish and Wildlife department has published projections that changes due to sea level rise are likely to create more damaging storms that threaten to destroy coastal infrastructure, recreational areas, and opportunities for economic growth through tourism and fishing.⁶

Again, we hope you will think deeply about the long-term implications of what ESG means and reconsider your position. I am available to meet with you to discuss any of the above or answer any questions you may have on the topic of ESG investing. 


Stephanie Cohn Rupp

CEO, Veris Wealth Partners



1 www.ussif.org/performance

2 www.miamiherald.com/opinion/editorials/article273909135.html

3 www.miamiherald.com/opinion/editorials/article273909135.html

4 www.unpri.org/academic-blogs/how-us-anti-esg-laws-raise-borrowing-costs-for-public-finance/11330.article

5 https://scholars.unh.edu/ersc/210/

6  https://www.wildlife.state.nh.us/climate/sea-levels.html