JPMorgan Chase’s American Security Initiative Has a Carbon Contradiction

As documented in National Legal and Policy Center’s exempt solicitation report supporting Proposal 4 on JPMorgan Chase & Co.’s 2026 proxy ballot, a fundamental conflict sits at the heart of the Company’s capital allocation framework.

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In October 2025, JPMorgan announced its Security and Resiliency Initiative (“SRI”), a $1.5 trillion, ten-year plan to finance industries critical to American economic security — including defense and aerospace, energy independence, critical minerals, advanced manufacturing, shipbuilding, and nuclear energy.¹ NLPC supports the initiative’s premise.

The problem is that JPMorgan simultaneously maintains its Carbon Compass framework, which sets 2030 portfolio-level emissions intensity reduction targets across eight carbon-intensive sectors — all benchmarked to the International Energy Agency’s Net Zero Emissions by 2050 Scenario (“IEA NZE”).² The SRI demands abundant hydrocarbon energy, more mining and mineral processing, expanded steel and cement production, and massive new manufacturing capacity. However, the Carbon Compass framework penalizes those very activities. These two commitments drive in opposite directions.

The mechanism is concrete and consequential. JPMorgan’s Carbon Assessment Framework (“CAF”), by the Company’s own description, provides “decision-makers at the Firm with insights into how the transaction may impact a portfolio’s carbon intensity” for “each new proposed in-scope transaction.”³ In plain English: when a JPMorgan banker evaluates a loan to a steel producer, a cement manufacturer, or a natural gas driller, the CAF assesses whether that transaction moves the portfolio’s carbon intensity in the wrong direction. A transaction that strengthens American manufacturing capacity, energy reliability, or national security faces a structural headwind at the underwriting stage — imposed by JPMorgan’s own internal framework.

The IEA NZE scenario underpinning Carbon Compass is not a forecast. It is a normative aspiration — one that assumes no new oil and gas field approvals beyond 2021, the total phase-out of coal and oil power plants by 2040, and deployment of technologies like green hydrogen at scales that do not currently exist.⁴

The United States has withdrawn from the Paris Agreement. China and India have made no binding commitments to reduce absolute emissions before 2030. The SRI’s vision of American reindustrialization requires expansion of the very energy sources the IEA NZE requires to contract. Yet JPMorgan, after leaving the Net Zero Banking Alliance in January 2025,⁵ kept its IEA NZE-aligned Carbon Compass targets intact.⁶ It dropped the membership and kept the metrics.

JPMorgan’s Board recommends a vote against Proposal 4, claiming our concerns reflect “a fundamental misunderstanding” of the SRI and Carbon Compass.⁷ But this defense is self-defeating. If the two frameworks are genuinely compatible, a brief explanatory report should be trivially easy to produce. The Board’s refusal to produce one — its insistence that a simple reconciliation document would be expensive and provide no meaningful disclosure — suggests the reconciliation is harder than management lets on. When the Board objects to a transparency request about its own flagship initiatives, the resistance is informative.

The strategic incoherence comes as JPMorgan faces compounding political and legal risk. President Trump has reportedly filed a $5-billion civil lawsuit against JPMorgan and CEO Jamie Dimon personally over the closing of more than fifty Trump-affiliated accounts;⁸ JPMorgan has acknowledged in court filings that it did close those accounts.⁹ Separately, the House Select Committee on the Chinese Communist Party subpoenaed Mr. Dimon over JPMorgan’s underwriting of the CATL IPO — a $5.2 billion listing for a battery company the Pentagon has designated as linked to China’s military-civil fusion program.¹⁰ A bank that presents itself as the financier of American reindustrialization while facing a congressional subpoena for underwriting a Chinese military-linked company has a credibility problem.

NLPC urges shareholders to vote FOR Proposal 4 at JPMorgan’s May 19, 2026 annual meeting. Voting is open NOW.

A vote for this Proposal is not a vote against the SRI, nor against JPMorgan’s climate commitments. It is a vote for a straightforward principle: shareholders are entitled to know which framework actually governs capital allocation when two of the Company’s flagship initiatives conflict. Transparency is not an unreasonable demand from the owners of the enterprise.

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Endnotes

1. “JPMorganChase Launches $1.5 Trillion Security and Resiliency Initiative to Boost Critical Industries,” JPMorgan Chase & Co., October 22, 2025. See https://www.jpmorganchase.com/newsroom/press-releases/2025/jpmc-security-resiliency-initiative
2. “Carbon Compass” (accessed April 8, 2026), JPMorgan Chase & Co. See https://www.jpmorgan.com/investment-banking/center-for-carbon-transition/carbon-compass
3. “Climate Report 2024,” JPMorgan Chase & Co. See https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/Climate-Report-2024.pdf
4. “Net Zero by 2050: A Roadmap for the Global Energy Sector,” International Energy Agency, May 18, 2021. See https://www.iea.org/reports/net-zero-by-2050
5. Hollerith, David. “JPMorgan completes Wall Street’s retreat from key climate alliance,” Yahoo Finance, January 7, 2025. See https://finance.yahoo.com/news/jpmorgan-completes-wall-streets-retreat-from-key-climate-alliance-144804740.html
6. “Environmental Sustainability” (accessed April 8, 2026), JPMorgan Chase & Co. See https://www.jpmorganchase.com/impact/environmental-sustainability
7. Annual Meeting of Shareholders/Proxy Statement 2026, “Board response to proposal 4,” (pp. 84-85), JPMorgan Chase & Co., April 6, 2026. See https://jpmorganchaseco.gcs-web.com/static-files/f685e4a4-fdca-42ed-ac58-e98f13121eb9
8. Perlot, Luke. “President Trump Sues JPMorgan Chase and CEO Jamie Dimon for Debanking,” National Legal and Policy Center, January 22, 2026. See https://nlpc.org/featured-news/president-trump-sues-jpmorgan-chase-and-ceo-jamie-dimon-for-debanking/
9. Chesser, Paul. “#WeToldYouSo (and So Did the President): JPMorgan Chase Debanked Trump,” National Legal and Policy Center, February 22, 2026. See https://nlpc.org/corporate-integrity-project/wetoldyouso-and-so-did-the-president-jpmorgan-chase-debanked-trump/
10. Perlot, Luke. “JPMorgan & Bank of America’s China Risk Is Reaching a Boil,” National Legal and Policy Center, July 25, 2025. See https://nlpc.org/featured-news/jpmorgan-bank-of-americas-china-risk-is-reaching-a-boil/

(Post references PX14A6G Notice of exempt solicitation)