INTEL CORPORATION | Lobbying Expenditures Disclosure at INTEL CORPORATION

Status
Filed
Previous AGM date
Resolution details
Company ticker
INTC
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, stockholders of Incyte request the preparation of a report, updated annually, omitting any proprietary data and produced at reasonable cost, disclosing: Payments by Incyte used for direct or indirect lobbying, in each indirect case including the amount of the payment and the recipient. For purposes of this proposal, payments used for direct lobbying are the annual aggregate amounts reported at the federal and state levels, broken out by federal and individual state. Payments used for indirect lobbying are payments to trade associations or social welfare groups that are used for lobbying as defined by tax law. Both direct and indirect lobbying include efforts at the state and federal levels. The report shall be posted on Incytes website
Supporting statement
As long-term stockholders of Incyte, we support greater transparency and accountability in corporate lobbying, particularly given the company?s specialty drug profile and regulatory vulnerabilities. Incyte?s own 10-K highlights material risks that directly intersect with public policy. The company discloses: ?We depend heavily on JAKAFI/JAKAVI (ruxolitinib), and if we are not able to maintain revenues from JAKAFI/JAKAVI or those revenues decrease, our business may be materially harmed.? The company further states, ?if we or our collaborators are unable to obtain, or maintain at anticipated levels, coverage and reimbursement for our products from government and other third-party payors, our results of operations and financial condition could be harmed.? Because federal and state policy decisions directly shape reimbursement criteria, coverage determinations, pricing frameworks, and market-access pathways, lobbying on these issues presents material financial and regulatory risk and opportunity for Incyte. Yet stockholders currently lack the information necessary to evaluate whether the company?s lobbying?either direct or indirect?is aligned with its disclosed risks and long-term strategic interests. According to federal disclosure filings, Incyte spent $1,070,000 on federal lobbying in 2024. This does not include state lobbying. This does not include any indirect lobbying conducted through trade associations or social welfare groups. In its Global Sustainability Report [1] , Incyte frequently highlights its partnerships with patient advocacy organizations, yet provides no disclosure of which groups it funds or whether these payments support policy advocacy on pricing, coverage, or reimbursement?an area where patient advocacy groups have increasingly been used across the pharmaceutical industry as indirect, opaque lobbying vehicles. This lack of visibility prevents investors from assessing potential reputational, regulatory, or policy risks arising from these relationships. The International Corporate Governance Network recommends that companies publicly disclose corporate lobbying activities and related expenditures above a de minimis threshold. Many companies already do so. Among Incyte?s peers, Biogen, Moderna, and Sarepta publish annual reports detailing their trade association and social welfare group payments used for lobbying. Because companies already report lobbying information to regulators, providing a consolidated annual report to stockholders is not unduly burdensome. Enhanced disclosure would enable investors to assess whether Incyte?s direct and indirect lobbying is aligned with its disclosed risks and long-term business strategy. We urge Incyte to expand its lobbying disclosure. [1] https://cdn.incyte.com/Assets/INCY25_Global-Responsibility-Report_FINAL_ADA.pdf

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