THE WALT DISNEY COMPANY | Lobbying Expenditures Disclosure at THE WALT DISNEY COMPANY

Status
Withdrawn
AGM date
Previous AGM date
Resolution details
Company ticker
DIS
Lead filer
Mercy Investment Services, Inc.
Co-filers
Missionary Oblates of Mary Immaculate, Daughters of Charity, Province of St Louise, Congregation of St.Joseph (Rocky River)
Resolution ask
Report on or disclose
ESG theme
  • Governance
ESG sub-theme
  • Lobbying / political engagement
Type of vote
Shareholder proposal
Filer type
Shareholder
Company sector
Consumer Discretionary
Company HQ country
United States
Resolved clause
Resolved, shareholders of Disney 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 Disney used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient.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 Disney 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 and Nominating Committee and posted on Disney’s website. 
Whereas clause
Whereas, we believe in full disclosure of Disney’s lobbying activities and expenditures to assess whether Disney’s lobbying is consistent with Disney’s expressed goals and shareholder interests.
Supporting statement
Supporting Statement
Disney spent $46.4 million from 2010 – 2021 on federal lobbying. This does not include state lobbying, where Disney also lobbies but disclosure is uneven or absent. For example, Disney spent $4.45 million on lobbying in California from 2010 – 2021, and Disney’s lobbying in Florida has been described as “the 800-pound mouse.”[1] And Disney also lobbies abroad, spending between €800,000 – 899,999 on lobbying in Europe for 2021.
Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity, and these groups may be spending “at least double what’s publicly reported.”[2] In fact, our company entirely fails to disclose payments to 501(c)4s, also known as social welfare groups. Notably they are major contributors to a group called SOAR which is now the subject of an FBI criminal complaint[3]. Additionally, Disney has drawn negative attention for avoiding federal income taxes,[4] but 501(c)4s like the RATE Coalition, of which they are members, are lobbying against raising corporate taxes to fund health care, education and safety net programs.[5]
Disney’s disclosure is also incomplete for trade associations, failing to disclose a top limit for its payments. Shareholders cannot tell the magnitude of Disney’s payments over $500,000 to groups like the National Cable and Telecommunications Association (NCTA). If Disney’s 2020 NCTA payments were comparable to Comcast, which does disclose, its total payments would have exceeded $25 million.
We are concerned that Disney’s lack of disclosure presents reputational risk when its lobbying contradicts company public positions. This has been seen with climate change as well as voter restrictions[6]. Shareholders need transparency across all Disney’s political spending in order to truly understand what risks we face.  
[1] https://www.politico.com/magazine/story/2015/06/what-works-orlando-disney-politics-119167.
[2] https://theintercept.com/2019/08/06/business-group-spending-on-lobbying-in-washington-is-at-least-double-whats-publicly-reported/.
[3] https://voiceofoc.org/2022/05/how-did-disneylands-main-political-spending-vehicle-land-in-the-middle-of-an-fbi-complaint/
[4] https://prospect.org/economy/corporate-tax-dodging-wont-go-away-until-we-fix-our-tax-code/.
[5] https://www.washingtonpost.com/us-policy/2021/08/31/business-lobbying-democrats-reconciliation/
[6] https://thehill.com/business-a-lobbying/business-a-lobbying/554430-watchdog-group-launches-campaign-to-pressure/?rl=1

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