WELLS FARGO & COMPANY | Report on lobbying at WELLS FARGO & COMPANY

Status
Filed
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
Shareholders 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
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 $72 million from 2010 - 2023 on federal lobbying. This does not include state

lobbying, where WFC also lobbies, spending $3 million on lobbying in California from 2010 - 2023.

Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity.'

WFC fails to disclose its payments to trade associations and social welfare groups, 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 $98 million on 2023 federal lobbying. And WFC's disclosure also leaves out its memberships and payments to social welfare

groups, such as the Bay Area Council, California Taxpayers Association and the Future of Privacy Forum.

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 filed an amicus brief opposing the Securities and Exchange Commission

climate risk disclosure rules and the Chamber opposed the Paris climate accord. An 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. And WFC has attracted negative attention for funding controversial nonprofits like the State Financial

Officers Foundation, which has waged "a coordinated attack on climate policy."

Improved WFC lobbying disclosure will protect the reputation of WFC and preserve shareholder value.

Inflation Reduction Act. And WFC has attracted negative attention for funding controversial nonprofits like the State Financial

Officers Foundation, which has waged "a coordinated attack on climate policy."

Improved WFC lobbying disclosure will protect the reputation of WFC and preserve shareholder value.

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