Lobbying Expenditures Disclosure

Resolution Text

RESOLVED, stockholders of Alphabet 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 Alphabet 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. Description of management’s and the Board’s decision-making process and oversight for making payments described in sections 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 Alphabet 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 Governance Committee and posted on Alphabet’s website.

SUPPORTING STATEMENT

Full disclosure of Alphabet’s lobbying activities and expenditures is needed to assess whether its lobbying is consistent with Alphabet’s expressed goals and stockholders’ best interests. Alphabet spent

$119,029,000 on federal lobbying from 2015 – 2022. This does not include state lobbying. Alphabet lobbied in at least 39 states in 2022. Alphabet also lobbies abroad, “being accused of shady lobbying”1 and spending between €5,500,000 – 5,999,999 on lobbying in Europe for 2022.

Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity.2 Alphabet lists support of 368 trade associations (TAs), social welfare groups (SWGs) and nonprofits for 2022, yet fails to disclose its payments, or the amounts used for lobbying.

Alphabet belongs to the Chamber of Commerce and Business Roundtable, which have spent over $2.2 billion on lobbying since 1998, supports SWGs that lobby like National Taxpayers Union3 and Taxpayers Protection Alliance,4 and funds controversial nonprofits like the Competitive Enterprise Institute (CEI),5 Federalist Society6 and Independent Women’s Forum, which has drawn scrutiny for “using anti-trans scaremongering” to oppose the Equal Rights Amendment.7

Alphabet’s lack of disclosure presents reputational risks when its lobbying contradicts company public positions or hides payments to SWGs. Alphabet has drawn attention for funding “dark money groups” to oppose antitrust regulation.8 On company positions, Alphabet believes in addressing climate change, yet the Business Roundtable lobbied against the Inflation Reduction Act,9 the Chamber reportedly has been a “central actor” in dissuading climate legislation over a two-decade period,10 and CEI is described as a “climate denialist think tank.”11 And while Alphabet does not belong to the controversial American Legislative Exchange Council,12 it is represented by the Chamber13 and NetChoice,14 which each sit on its Private Enterprise Advisory Council.

Alphabet should expand its lobbying disclosure.

1 https://www.politico.eu/article/big-tech-companies-face-potential-eu-lobbying-ban/ . 

2 https://theintercept.com/2019/08/06/business-group-spending-on-lobbying-in-washington-is-at-least-double-whats-publicly- reported/.

3 https://time.com/6182329/the-strange-coalition-in-congress-poised-to-score-a-major-win-against-big-tech/. 

4 https://www.opensecrets.org/news/2021/06/dark-money-groups-battle-efforts-to-limit-big-tech/. 

5 https://www.nytimes.com/2019/07/10/climate/nyt-climate-newsletter-cei.html. 

6 https://www.cnbc.com/2021/01/15/federalist-society-under-fire-after-leader-spoke-at-pro-trump-rally-before-riot.html. 

7 https://truthout.org/articles/dark-money-womens-groups-are-using-anti-trans-scaremongering-to-oppose-era/. 

8 https://www.opensecrets.org/news/2021/06/dark-money-groups-battle-efforts-to-limit-big-tech/. 

9 https://www.theguardian.com/environment/2022/aug/19/top-us-business-lobby-group-climate-action-business-roundtable. 

10 https://www.washingtonpost.com/politics/2023/08/02/climate-group-pushes-big-tech-exit-nations-largest-business-lobby/. 

11 https://prospect.org/power/2023-07-17-climate-denialist-think-tank-ftc/. 

12 https://www.exposedbycmd.org/2022/07/27/abandoning-free-market-and-liberty-principles-alec-takes-on-woke-capitalism- bodily-autonomy-and-more-at-its-annual-meeting/. 

13 https://ohiocapitaljournal.com/2023/09/06/coming-soon-in-ohio-alec-releases-new-raft-of-model-legislation/. 

14 https://readsludge.com/2023/10/03/alec-gala-will-face-protest-from-pro-democracy-groups/.