WELLS FARGO & COMPANY | Lobbying Expenditures Disclosure at WELLS FARGO & COMPANY

Status
Filed
AGM date
Previous AGM date
Resolution details
Company ticker
WFC
Lead filer
Individual
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
Financials
Company HQ country
United States
Resolved clause
RESOLVED, the shareholders of Wells Fargo & Company (WFC) request the preparation of a report, updated annually, disclosing:
1. Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.
2. Payments by WFC used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient.
3. WFC’s membership in and payments to any tax-exempt organization that writes and endorses model legislation.
4. Description of management’s and the Board’s decision-making process and oversight for making payments described in sections 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 of which WFC 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 Corporate Responsibility Committee and posted on WFC’s website.
Supporting statement
SUPPORTING STATEMENT
Full disclosure of WFC’s lobbying activities and expenditures is needed to assess whether WFC’s lobbying is consistent with its expressed goals and shareholders’ interests. WFC spent $68,100,000 from 2010 – 2022 on federal lobbying. This does not include state lobbying, where WFC lobbied in at least 28 states in 2022 and spent over $2.9 million on lobbying in California from 2010 – 2022.
Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity.1 WFC fails to disclose its payments to trade associations and social welfare groups (SWGs), or the amounts used for lobbying, to shareholders. WFC belongs to the American Bankers Association (ABA), Business Roundtable, and US Chamber of Commerce, which together spent $111,356,000 on federal lobbying for 2022. And while WFC previously dropped2 its membership in the American Legislative Exchange Council, ABA supported its 2022 annual meeting3 and the Chamber sits on its Private Enterprise Advisory Council.4
WFC’s lack of disclosure presents reputational risks when its lobbying contradicts company public positions. For example, WFC publicly supports addressing climate change, yet the BRT lobbied against the Inflation Reduction Act5 and the Chamber reportedly has been a “central actor” in dissuading climate legislation over a two-decade period.6 A recent analysis looking at inconsistencies between banks’ public climate commitments and their direct and indirect climate lobbying practices noted WFC failed to publicly support the Inflation Reduction Act.7 While WFC has opposed voter restrictions,8 the Chamber lobbied against protecting voting rights.9 And WFC has attracted negative attention10 for funding controversial nonprofits like the State Financial Officers Foundation, which is attacking woke capitalism.11
WFC should expand its lobbying disclosure.
1 https://theintercept.com/2019/08/06/business-group-spending-on-lobbying-in-washington-is-at-least-double-whats-publicly-reported/.
2 https://www.prwatch.org/news/2012/09/11740/merck-and-wells-fargo-dump-alec-while-duke-energy-holds-out.
3 https://documented.net/investigations/heres-who-bankrolling-alec-2022-annual-meeting.
4 https://ohiocapitaljournal.com/2023/09/06/coming-soon-in-ohio-alec-releases-new-raft-of-model-legislation/.
5 https://www.theguardian.com/environment/2022/aug/19/top-us-business-lobby-group-climate-action-business-roundtable.
6 https://www.washingtonpost.com/politics/2023/08/02/climate-group-pushes-big-tech-exit-nations-largest-business-lobby/.
7 https://www.ceres.org/news-center/press-releases/new-benchmark-analysis-us-banks-reveals-inconsistencies-between-climate.
8 https://newsroom.wf.com/English/news-releases/news-release-details/2021/Wells-Fargo-Statement-on-Voter-Rights/default.aspx.
9 https://thehill.com/business-a-lobbying/business-a-lobbying/554430-watchdog-group-launches-campaign-to-pressure?rl=1.
10 https://www.responsible-investor.com/us-lawmaker-slams-jpmorgan-wells-fargo-for-involvement-with-anti-esg-body/.
11 https://www.washingtonpost.com/climate-environment/2022/07/12/republicans-threaten-wall-street-over-climate-positions/; https://www.exposedbycmd.org/2022/02/16/republican-group-of-state-financial-officers-takes-on-woke-capitalism/.

Filed by John Chevedden

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