Resolved, shareholders of Apple 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 Apple 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. Apple?s membership in and payments to any tax-exempt organization that writes and endorses model legislation.  4. Description of management 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 Apple 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 Audit and Finance Committee and posted on Apple?s website. Supporting Statement  Full disclosure of Apple?s lobbying activities and expenditures is needed to assess whether its lobbying is consistent with Apple?s expressed goals and shareholders? best interests. Apple spent $76,120,000 on federal lobbying from 2010 ? 2023. This does not include state lobbying, where Apple lobbied in at least 48 states in 2023. Apple also lobbies abroad, spending between ?6,500,000 ? 6,999,999 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 Apple lists support of 42 trade associations for 2022, yet fails to disclose its payments, or the amounts used for lobbying, and fails to disclose social welfare groups (SWGs) it supports. Apple belongs to the Business Roundtable, which has spent over $400 million on lobbying since 1998, and lists memberships in the Center for Global Regulatory Cooperation, Chamber of Progress and TechNet. Apples additionally supports SWGs that lobby like the Bay Area Council, California Taxpayers Association and Future of Privacy Forum.  Apple?s lack of disclosure presents reputational risks when its lobbying contradicts company public positions. On company positions, Apple believes in addressing climate change, yet the Business Roundtable filed an amicus brief opposing the Securities and Exchange Commission climate risk disclosure rules.2 The Chamber of Progress has drawn attention as a ?dark money? group opposing antitrust regulation.3 While Apple left the US Chamber of Commerce over its stance on climate change, it belongs to Center for Global Regulatory Cooperation, which is run by the Chamber of Commerce. And while Apple does not belong to the controversial American Legislative Exchange Council, it is represented by NetChoice,4 which sits on its Private Enterprise Advisory Council.  Apple should expand its lobbying spending disclosure.  1https://theintercept.com/2019/08/06/business-group-spending-on-lobbying-in-washington-is-at-least-double-whats-publicly-reported/. 2https://www.eenews.net/articles/investors-question-business-roundtables-climate-rule-battle/. 3https://www.opensecrets.org/news/2021/06/dark-money-groups-battle-efforts-to-limit-big-tech/. 4https://readsludge.com/2023/10/03/alec-gala-will-face-protest-from-pro-democracy-groups/.