Resolved, the stockholders of AbbVie 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 AbbVie 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. AbbVie?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 section 2 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 AbbVie 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 Public Policy and Sustainability Committee and posted on AbbVie?s website. Supporting Statement   Full disclosure of AbbVie?s lobbying activities and expenditures is needed to assess whether AbbVie?s lobbying is consistent with its expressed goals and stockholder interests. AbbVie spent $67,530,000 from 2013 ? 2023 on federal lobbying. AbbVie also lobbies at the state level, spending over $2.6 million on lobbying in California from 2013 ? 2023. And AbbVie lobbies abroad, spending between ?1,000,000 ? 1,249,999 on lobbying in Europe for 2023.   Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity.1 AbbVie belongs to the Chamber of Commerce, which has spent over $1.9 billion on lobbying since 1998. AbbVie?s trade association disclosure is incomplete, failing to disclose a top limit for payments over $750,000 and leaving out memberships in trade associations that lobby like the Healthcare Distribution Alliance, Healthcare Institute of New Jersey and HR Policy Association. Unlike Biogen and Vertex, AbbVie?s disclosure critically leaves out its payments to social welfare groups (SWGs), including the Alliance for Patient Access (AfPA), California Taxpayers Association, Patients Rising and Public Affairs Council. AbbVie?s lack of disclosure presents reputational risk when its lobbying contradicts company public positions. On company positions, AbbVie states it supports more affordable medicines, yet drew scrutiny for lobbying ?to kill lower drug prices during pandemic?2 and funds AfPA, a SWG which ?claims to be pro-consumer but consistently advocates against policies to lower drug prices?3 and is described as a foil ?for the pharmaceutical industry instead of advancing patient interests.?4 AbbVie believes in addressing climate change, yet the Chamber opposed the Paris climate accord and sued the SEC over climate risk disclosure rules.5   AbbVie should expand its 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.commondreams.org/news/2022/07/13/big-pharma-has-spent-147-million-kill-lower-drug-prices-during-pandemic. 3 https://prospect.org/power/astroturf-campaign-attacks-discount-drug-program-for-poor/. 4 https://apnews.com/article/7c8d0728c38345cd8dfc0fe1abd456ae. 5 https://www.reuters.com/legal/us-chamber-commerce-sues-sec-over-climate-risk-disclosure-rules-2024-03-14/.