Douglas Emmett, Inc. | Lobbying Expenditures Disclosure at Douglas Emmett, Inc.

32.55% 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
Real Estate
Company HQ country
United States
Resolved clause
Resolved: The stockholders of Douglas Emmett, Inc. ask the Board of Directors to prepare a report, to be updated annually and posted on the Company’s website, disclosing:
-Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.
-Company payments used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient.
-The Company’s membership in and payments to any tax-exempt organization that writes and endorses model legislation.
-Description of management’s and the Board’s decision-making process and oversight for making payments described in section 2 and 3 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 in which Douglas Emmett is a member.
Both “direct and indirect lobbying” and “grassroots lobbying communications” include efforts at the local, state and federal levels.
Supporting statement
Supporting Statement
As a real estate investment trust, Douglas Emmett is in a business that can be affected by decisions of legislative bodies and voter referenda. However, there is no Company policy that explains how the Company decides when, how and to what degree to engage in attempting to influence those decisions, nor is there a policy disclosing how or whether the Board engages in oversight of those activities.
Disclosure is particularly important because the Company can become involved in needless controversy. For example, several years ago the Company received approval from the Los Angeles City Council to construct a 34-story luxury housing development featuring 376 apartment units, only 5% of which were earmarked for affordable housing. Developers may negotiate terms of approval of a project with Los Angeles city officials, and this project drew criticism based on the low number of affordable units at a time of limited options for affordable housing.1
Inadequate disclosure can thus cause reputational injury to a company. Douglas Emmett may file lobbying reports that are legally required, but those reports may not tell the full story. Federal disclosures laws do not require reports of grassroots lobbying expenditures, and disclosure may be uneven or absent at the state and local levels. For example, if the Company makes donations to trade associations, particularly donations above ordinary membership dues, that money can then be used for lobbying without any disclosure of Douglas Emmett’s involvement.
We believe that greater transparency is needed at this Company.
We urge you to vote FOR this resolution.
1 The story refers to 16 units, but later reports indicate that there were 19 units. begins-rise-34-story-landmark-apartment-tower.

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