48.12% votes in favour
AGM date
Previous AGM date
Proposal number
Resolution details
Company ticker
Lead filer
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
Resolved clause
Resolved, the stockholders of IBM 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 IBM 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 IBM 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 Audit Committee and posted on IBM’s website.
Whereas clause
Whereas, full disclosure of IBM’s lobbying activities and expenditures to assess whether IBM’s lobbying is consistent with IBM’s expressed goals and stockholder interests
Supporting statement
Supporting Statement
IBM spent $61 million from 2010-2021 on federal lobbying. This does not include state lobbying expenditures, where IBM lobbied in at least 20 states in 2021 and spent over $810,000 on lobbying in California from 2010-2021. IBM also lobbies abroad, spending between €1,750,000 — 1,999,999 on lobbying in Europe for 2021.
Companies can give unlimited amounts to third party groups that spend millions on lobbying and often undisclosed grassroots activity, and these groups may be spending “at least double what’s publicly reported.”1 IBM fails to disclose its third-party payments to trade associations and social welfare organizations, or the amounts used for lobbying to stockholders.
IBM belongs to the Business Roundtable, and US Chamber Commerce, which together have spent over $2.1 billion on federal lobbying since 1998. And while IBM does not belong to the controversial American Legislative Exchange Council, which is attacking “woke capitalism,”2 it is represented by its trade association, with the Chamber sitting on its Private Enterprise Advisory Council.
IBM’s lack of disclosure presents reputational risk when its lobbying contradicts company public positions. IBM believes in addressing climate change, yet the Business Roundtable lobbied against the Inflation Reduction Act3 and the Chamber opposed the Paris climate accord. IBM is committed to diversity and inclusion, yet the Chamber lobbied against protecting voting rights.4
And while IBM has attracted scrutiny for avoiding federal income taxes,5 the Business Roundtable has lobbied against raising coproate taxes to fund health care, education and safety net programs.6 Reputational damage stemming from these misalignments could harm stockholder value. Thus, I urge IBM to expand its lobbying disclosure.

How other organisations have declared their voting intentions

Organisation name Declared voting intentions Rationale
Rothschild & co Asset Management For
Kutxabank Gestion SGIIC SAU. For
KBI Global Investors For

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