GEO Group Inc. | Interfaith Center on Corporate Responsibility

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<h4>Resolution Details</h4>
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<strong>Company:</strong>
<p>GEO Group Inc.</p>
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<strong>Year:</strong>
<p>2026 </p>
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<strong>Issue Area:</strong>
<p>Human Rights & Worker Rights </p>
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<strong>Focus Area:</strong>
<p>Human Rights, Immigration </p>
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<strong>Status:</strong>
<p>Challenged</p>
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<h2>Resolution Text</h2>
<p>RESOLVED: Shareholders request that the Board of Directors commission an independent third-party report, at reasonable expense and excluding proprietary information, on the effectiveness of GEO Group’s (“GEO’s”) due diligence process to determine whether its services contribute to violations of international human rights law and expose the company to material risks.  </p>
<p>WHEREAS: With shareholder support, GEO adopted a Global Human Rights Policy in 2013, revised in 2025,1 guided by international standards, including the United Nations Guiding Principles on Business and Human Rights (“UNGPs”). <br><br>In the UNGPs, human rights due diligence is one of three requirements of the corporate responsibility to respect human rights.2 Under United Nations (“UN”) conventions, “The widespread or systematic practice of enforced disappearance constitutes a crime against humanity,” and criminal responsibility befalls “Any person who… induces the commission of… is an accomplice to or participates in an enforced disappearance.”3 International standards require parties avoid complicity in enforced disappearances, with consequent criminal liability risk. <br><br>Yet, GEO remains deeply involved in deportation flight operations. For example, GEO’s Northwest Detention Center (NWDC) in Tacoma, Washington has been linked to deportations to El Salvador: the University of Washington’s Center for Human Rights (UWCHR) identified that on “March 8, 2025—11 people were booked out for removal from the NWDC, including six Venezuelan men sent to CECOT prison in El Salvador.”4 UN human rights experts have stated that “deportations [to El Salvador] and related incommunicado detentions appeared to involve enforced disappearances, contrary to international law.”5 GEO assists deportation operations across the U.S., including from its Alexandria, Louisiana facility.6 </p>
<p>Additionally, GEO’s wholly-owned subsidiary, GEO Transport, Inc. (“GTI”), is the largest provider of transportation for U.S. Immigration and Customs Enforcement (“ICE”).7 GTI was awarded a five-year contract to provide air operations support services on behalf of ICE.8 The Air Marshal National Council stated that the federal government contracted GTI to provide security on board ICE deportation flights.9 <br>Department of Homeland Security Transportation Orders obtained by UWCHR instruct GTI buses to pick up detainees at ICE’s Seattle Hold Room and transport them directly to planes via the tarmac of the Seattle-Tacoma International Airport. These orders document GTI as the party responsible immediately prior to deportation flights.  <br><br>GEO and its subsidiary GTI provide transportation to and security on deportation flights, including cases that may “involve enforced disappearances.” Shareholders are concerned that the company is not properly mitigating material human rights risks. <br><br>SUPPORTING STATEMENT <br>Shareholders seek information, at the board and management’s discretion, through a report that could describe GEO’s due diligence process to prevent involvement in cases of enforced disappearance; the board’s role in overseeing the management of risks associated with deportation operations; assessment of international law and material risks to shareholder value; and recommendation of additional measures, if any, to mitigate risks. </p>
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<p>1 https://www.geogroup.com/geo-global-human-rights-policy <br>2 UNGP 15 <br>https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf <br>3 Article 5 and Article 6, https://www.ohchr.org/en/instruments-mechanisms/instruments/international-convention-protection-all-persons-enforced <br>4 https://jsis.washington.edu/humanrights/2025/08/21/gross-human-rights-violations-in-washington-state-enforced-disappearance-and-refoulement/  <br>5 https://www.ohchr.org/en/press-releases/2025/04/un-experts-alarmed-illegal-deportations-united-states-el-salvador <br>6 https://www.theguardian.com/us-news/ng-interactive/2025/sep/12/ice-detention-alexandria-staging-facility <br>7 https://www.brennancenter.org/our-work/analysis-opinion/private-prison-companies-enormous-windfall-who-stands-gain-ice-expands <br>8 https://investors.geogroup.com/news-releases/news-release-details/geo-group-announces-five-year-contract-provide-air-operations <br>9 https://amp.cnn.com/cnn/2025/07/31/politics/ice-deportation-air-marshals </p>

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<h3>Lead Filer</h3>
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<div class=”views-field views-field-nothing”><span class=”field-content”> Bryan Pham</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>USA Northeast Province of the Society of Jesus</span></div>
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<h3>Co-filer</h3>
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<div class=”views-field views-field-nothing”><span class=”field-content”> Tom McCaney</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Sisters of St. Francis of Philadelphia</span></div>
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<div class=”views-field views-field-nothing”><span class=”field-content”> Raymond Burnell</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Christian Brothers Investment Services</span></div>
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<div class=”views-field views-field-nothing”><span class=”field-content”> Karen Watson</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Congregation of St. Joseph, OH*</span></div>
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<div class=”views-field views-field-nothing”><span class=”field-content”> Maxwell Homans</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Daughters of Charity, Province of St Louise</span></div>
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Resolution Details

Company:

GEO Group Inc.

Year:

2024

Issue Area:

Inclusiveness

Focus Area:

Racial Justice

Status:

Filed

Resolution Text

RESOLVED that shareholders of The GEO Group Inc. (“GEO”) urge the Board of Directors to oversee an independent third-party racial equity audit analyzing GEO’s adverse impacts on nonwhite stakeholders and communities of color and GEO’s plans to mitigate any such impacts. Input from civil rights organizations, criminal justice experts, and employees should be considered in determining the speciﬁc matters to be analyzed. A report on the audit, prepared at reasonable cost and omitting conﬁdential and proprietary information, should be disclosed on GEO’s website.

SUPPORTING STATEMENT

Several aspects of GEO’s business and operations suggest that a racial equity audit would be useful. In opposing this proposal last year, GEO emphasized that a substantial proportion of its workforce is nonwhite. This proposal does not aim to obtain diversity data, though; instead, it asks GEO to analyze its entire operation through a racial equity lens to identify adverse racial impacts.

People of color are disproportionately represented in private low and medium security facilities at least in part because contracts tend to exclude elderly and ill inmates who are more likely to be white.1 Immigration enforcement, which has been called “racial discrimination by proxy,”2 plays a key role for GEO, with 43.9% of 2022 revenues derived from contracts with Immigration and Customs Enforcement.3 There is reason to believe that GEO’s operation of immigration detention facilities has racially adverse impacts. For example, GEO’s Aurora immigration detention facility has been the subject of recent administrative complaints, including one alleging that guards made racially derogatory remarks and used excessive force against two black detainees4 and another alleging misuse of solitary conﬁnement.5

A racial equity audit could also examine whether GEO’s political activities have a negative racial impact. According to Open Secrets, in the 2022 and 2024 election cycles, GEO’s political action committee contributed to Members of Congress who objected to certifying the 2020 election results,6 an action some viewed as “a direct attack on the voting rights of people of color.”7 In 2022, GEO spent over $900,000 lobbying at the federal level8 and paid lobbyists in 18 states.9 GEO states that it has not “advocated for or against, nor have we played a role in setting, criminal justice, or immigration enforcement policies, such as whether to criminalize behavior, the length of criminal sentences, or the basis for or length of an individual’s incarceration or detention.”10 While that approach avoids the most obvious conﬂicts of interest, GEO may still take positions on other matters that are harmful to nonwhite stakeholders and communities of color.

Finally, an independent audit would provide objectivity, assurance and specialized expertise beyond what would be possible with an internal analysis. We urge GEO to assess its behavior through a racial equity lens to identify how it contributes to systemic racism, and how it could begin to help dismantle it.

1 journal.radicalcriminology.org/index.php/rc/article/view/44/html

2 scholarship.law.uci.edu/cgi/viewcontent.cgi?article=1044&context=ucilr, n.5

3 https://www.sec.gov/Archives/edgar/data/923796/000095017023004713/geo-20221231.htm#item_1_business, at 31.

4 coloradosun.com/2022/04/14/aurora-detention-center/

5 https://www.americanimmigrationcouncil.org/sites/default/ﬁles/research/misuse_of_solitary_conﬁnement_in_colorad o_immigration_detention_center_complaint.pdf 6 See www.opensecrets.org/orgs/geo-group/recipients?id=D000022003 (contributions); www.vox.com/2021/1/6/22218058/republicans-objections-election-results (election objectors).

7 See www.nytimes.com/2021/01/15/us/politics/lankford-apology-election-biden.html; www.marketwatch.com/story/business-leaders-call-for-action-on-trump-after-mob-siege-at-capitol-11609976655

8 https://www.opensecrets.org/federal-lobbying/clients/summary?id=D000022003

9 www.followthemoney.org/entity-details?eid=1096 10 https://www.geogroup.com/Portals/0/GEO_2022_Political_Activity_and_Lobbying_Report.pdf, at 1.

Resolution Details

Company:

GEO Group Inc.

Year:

2023

Issue Area:

Inclusiveness

Focus Area:

Racial Justice

Status:

Vote

Vote Percentage:

40.30%

Resolution Text

RESOLVED that shareholders of The GEO Group Inc. (“GEO”) urge the Board of Directors to oversee an independent third-party racial equity audit analyzing GEO’s adverse impacts on nonwhite stakeholders and communities of color and GEO’s plans to mitigate any such impacts. Input from civil rights organizations, criminal justice experts, and employees should be considered in determining the specific matters to be analyzed. A report on the audit, prepared at reasonable cost and omitting confidential and proprietary information, should be publicly disclosed on GEO’s website.

SUPPORTING STATEMENT

High-profile police killings of black people have galvanized the movement for racial justice. That movement, and the disproportionate impacts of the pandemic, have focused public attention on systemic racism, environmental racism, racialized violence and racial inequities.

Several aspects of GEO’s business and operations suggest that a racial equity audit would be useful. People of color are disproportionately represented in private low and medium security facilities at least in part because contracts tend to exclude elderly and ill inmates who are more likely to be white.1

Immigration enforcement, which has been called “racial discrimination by proxy,”2 has played an increasingly important role in GEO’s business model, with the proportion of revenues derived from contracts with Immigration and Customs Enforcement reaching 33% in 2021.3 In April 2022, immigrant rights groups filed a complaint with the Department of Homeland Security alleging that guards at a GEO immigration detention facility made racially derogatory remarks and used excessive force against two black detainees.4

A racial equity audit could also examine whether GEO’s political activities have a negative racial impact. According to Open Secrets, in the 2022 election cycle GEO’s political action committee contributed to Members of Congress who objected to certifying the 2020 election results,5 an action some viewed as “a direct attack on the voting rights of people of color.”6 Although disclosure requirements do not permit identification of the lobbying positions GEO has taken, data show that the company has lobbied at the federal level7 and paid lobbyists in 20 states in 2021.8

In 2019, the GEO Group Foundation gave money to over 30 law enforcement-related organizations, including Alhambra Police Foundation and the Houston Metro Fraternal Order of

Police (“FOP”) Lodge 98, a police union. Police foundations bypass normal procurement processes to buy equipment for police departments, including surveillance technology that has been used to target communities of color and nonviolent protestors. Police unions, including the FOP, have opposed reforms aimed at curbing mistreatment of people of color.9

1 journal.radicalcriminology.org/index.php/rc/article/view/44/html
2 scholarship.law.uci.edu/cgi/viewcontent.cgi?article=1044&context=ucilr, n.5.
3 www.sec.gov/ix?doc=/Archives/edgar/data/923796/000156459022007652/geo-10k_20211231.htm, at 33.
4 coloradosun.com/2022/04/14/aurora-detention-center/
5 See www.opensecrets.org/orgs/geo-group/recipients?id=D000022003 (listing contributions); www.vox.com/2021/1/6/22218058/republicans-objections-election-results (listing election objectors).
6 www.nytimes.com/2021/01/15/us/politics/lankford-apology-election-biden.html; w w w . m a r k e t w a t c h . c o m / s t o r y / b u s i n e s s – l e a d e r s – c a l l – fo r – a c t i o n – o n – t r u m p – a ft e r – m o b – s i e g e – a t – c a p i t o l – 1 1 6 0 9 9 7 6 6 5 5
7 www.opensecrets.org/news/2018/06/zero-tolerance-immigration-is-big-money-for-contractors-nonprofits/
8 www.followthemoney.org/entity-details?eid=1096
9 E.g.,www.npr.org/2020/06/08/872470076/the-fraternal-order-of-police-a-union-that-stands-in-the-way-of-police- reforms; www.injusticewatch.org/news/2021/analysis-heres-how-chicagos-most-powerful-police-union-maintains- tradition-of-problematic-leadership/

Assess Effectiveness of Human Rights Policy Implementation

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