L3Harris Technologies, Inc. | Transparency in lobbying at L3Harris Technologies, Inc.

Status
AGM passed
AGM date
Previous AGM date
Proposal number
4
Resolution details
Company ticker
LHX
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
Industrials
Company HQ country
United States
Resolved clause
L3Harris 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 L3Harris 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. L3Harris’ 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 L3Harris 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 and Governance Committee and posted on L3Harris’ website.
Supporting statement
Full disclosure of L3Harris’ lobbying activities and expenditures is needed to assess whether its lobbying is consistent with its expressed goals and shareholder interests. L3Harris spent $53 million from 2010-2023 on federal lobbying. This does not include state lobbying expenditures, where L3Harris also lobbies but disclosure is uneven or absent. For example, L3Harris’ lobbying over first responder communication systems in Florida has drawn media attention.1

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.”2 Unlike many of its peers, L3Harris fails to disclose its payments to trade associations and social welfare groups (SWG), or the amounts used for lobbying, to shareholders. L3Harris’ trade association disclosure is incomplete, failing to disclose a top limit for its payments over $50,000. L3Harris belongs to the Aerospace Industries Association, which spent $23 million on federal lobbying from 2010 - 2023. L3Harris’ current disclosure leaves out trade associations that lobby like the Alliance for Telecommunications Industry Solutions, General Aviation Manufacturers Association, Internet Security Alliance and Telecommunications Industry Association, and all social welfare groups.

L3Harris’ lack of disclosure presents reputational risks when its lobbying contradicts company public positions or takes controversial positions. L3Harris’ lobbying to get Israeli hacking firm NSO removed from a Commerce Department blacklist has attracted scrutiny.3 L3Harris has reportedly been actively lobbying leaders in the Pentagon and Congress to create a definition of what “resilient communications” means.4 And L3Harris’ lobbying on nuclear deterrence contracting for the annual defense budget has also attracted attention.5

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