THE BOEING COMPANY | Lobbying Expenditures Disclosure at THE BOEING COMPANY

37.25% votes in favour
AGM date
Previous AGM date
Proposal number
Resolution details
Company ticker
Resolution ask
Report on or disclose
ESG theme
  • Governance
ESG sub-theme
  • Lobbying / political engagement
Type of vote
Shareholder proposal
Filer type
Company sector
Company HQ country
United States
Supporting materials
  • Boeing_Lobbying resolution_Exempt soliciation.pdf Download
Resolved clause
RESOLVED, the shareholders of Boeing request the preparation of a report, updated annually, disclosing:
- Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.
- Payments by Boeing used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient.
- Boeing’s membership in and payments to any tax-exempt organization that writes and endorses model legislation.
- Description of management’s decision-making process and the Board’s oversight for making payments described above.

For purposes of this proposal, a “grassroots lobbying communication” is a communication directed to the general public that (a) refers to specific legislation or regulation, (b) reflects a view on the legislation or regulation and (c) encourages the recipient of the communication to take action with respect to the legislation or regulation. “Indirect lobbying” is lobbying engaged in by a trade association or other organization of which Boeing is a member. Both “direct and indirect lobbying” and “grassroots lobbying communications” include efforts at the local, state and federal levels. The report shall be presented to the Governance & Public Policy Committee and posted on Boeing’s website.
Whereas clause
WHEREAS, we believe in full disclosure of Boeing’s lobbying activities and expenditures to assess whether Boeing’s lobbying is consistent with its expressed goals and shareholder interests
Supporting statement
Boeing spent $192,880,000 from 2010 – 2021 on federal lobbying. This does not include state lobbying, where Boeing also lobbies but on which disclosure is uneven or absent. For example, Boeing spent $1,202,691 on lobbying in California from 2010 – 2021. Boeing also lobbies abroad, attracting scrutiny for funding the EU Reporter, described as “EU lobbying dressed up as journalism.”1
Boeing fails to disclose its payments to trade associations and social welfare organizations, or the amounts used for lobbying, to shareholders. Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity. These groups may be spending “at least double what’s publicly reported.”2 Boeing belongs to the Business Roundtable (BRT), National Association of Manufacturers (NAM) and US Chamber of Commerce, which together spent $110,830,000 on lobbying for 2021, and supports controversial “dark money” social welfare organizations like the American Action Network.3
We are concerned that Boeing’s lack of disclosure presents reputational risk when its lobbying contradicts company public positions. For example, Boeing believes in addressing climate change, yet the BRT lobbied against the Inflation Reduction Act4 and the Chamber opposed the Paris climate accord. While Boeing has previously drawn scrutiny for avoiding federal taxes,5 the BRT lobbied against raising corporate taxes to fund health care, education and safety net programs.6 And while our company does not belong to the American Legislative Exchange Council, which is attacking “woke capitalism,”7 Boeing is represented by its trade associations, as the Chamber and NAM each sit on its Private Enterprise Advisory Council.
1 publicly-reported/.3 roundtable.5 corporate-tax-cut/.6 capitalism-bodily-autonomy-and-more-at-its-annual-meeting/.

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