HEWLETT PACKARD ENTERPRISE COMPANY | Transparency in Lobbying at HEWLETT PACKARD ENTERPRISE COMPANY

Status
Filed
AGM date
Previous AGM date
Proposal number
6
Resolution details
Company ticker
HPE
Lead filer
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
Technology
Company HQ country
United States
Resolved clause
Resolved, the stockholders of HPE 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 HPE 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. HPE's membership in and payments to any tax-exempt organization that writes and endorses model legislation.
4. Description of management's decision-making process and the Board's 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 HPE 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 Nominating, Governance and Social Responsibility Committee and posted on HPE's website.
Whereas clause
Whereas, we believe in full disclosure of Hewlett Packard Enterprise's (HPE) lobbying activities and expenditures to assess whether HPE's
lobbying is consistent with its expressed goals and stockholder interests
Supporting statement
HPE spent $32 million from 2015 - 2023 on federal lobbying. This does not include state lobbying, where HPE also lobbies but disclosure is uneven or absent. For example, HPE spent over $913,000 on lobbying in California from 2015 - 2023. HPE also lobbies abroad, spending
between €100,000 - 99,999 on lobbying in Europe for 2023.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." Unlike many of its peers, HPE does not disclose its payments to trade associations and social welfare groups, or the amounts used for lobbying, and only discloses four trade association memberships, including the Business Roundtable, which has spent over $400 million on federal lobbying since 1998. The disclosure leaves out trade associations that lobby like the Alliance for Telecom Industry Solutions Standards, Cloud Security Alliance and Silicon Valley Tax Directors Group, and all social welfare groups, like the Public Affairs Council. HPE's lack of disclosure presents reputational risk when its lobbying contradicts company public positions. For example, HPE publicly supports addressing climate change, yet the Business Roundtable filed an amicus brief opposing the Securities and Exchange Commission climate risk disclosure rules and previously opposed the Inflation Reduction Act. And while HPE has attracted scrutiny for moving from California to Texas in part over state taxes, the Business Roundtable has lobbied against a new minimum corporate tax. Thus it will be a best practice for HPE to expand its lobbying disclosure.

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