Corporate Political Spending | Interfaith Center on Corporate Responsibility

NEW YORK, NY — Nathan Cummings Foundation (NCF) announced earlier this week that it has filed a lawsuit against Axon Enterprise, Inc. (AXON) in the U.S. District Court for the District of Columbia. The suit seeks to prevent AXON from excluding NCF’s shareholder proposal requesting greater transparency around the Company’s political spending.

This filing by NCF comes at a pivotal moment for shareholder rights in the United States. In November 2025, the Securities and Exchange Commission (SEC) announced that it would no longer review company requests to exclude shareholder proposals. For decades, the SEC’s involvement provided meaningful guidance to companies and investors and facilitated a successful private ordering process that often led to productive negotiations between companies and shareholders. In addition to NCF’s lawsuit, four New York City pension funds also recently filed a lawsuit against AT&T regarding that company’s decision to similarly exclude a shareholder proposal.

At the time of the SEC’s announcement last year, corporate governance experts warned that in the absence of the SEC’s guidance, companies could face lawsuits by investors if they were to unilaterally exclude shareholder proposals from the proxy. These recent lawsuits from NCF and the pension funds in New York demonstrate how investors, deprived of a longstanding tool for engagement with corporations, are left with more costly options, such as filing lawsuits, to meaningfully steward their investments.

The proposal calls for AXON to publish a report detailing how it determines when and where corporate funds are used to support or oppose political candidates or influence elections. It also asks AXON to disclose all direct and indirect political contributions and to present the report to the board and make it available on the Company’s website. It is very common for shareholders to request this information from companies to better understand potential risks from election-related spending. Hundreds of companies already report on these metrics.

AXON recently notified the Securities and Exchange Commission (SEC) of its intent to exclude the proposal, asserting that it constitutes “micromanagement.” NCF disputes this claim, noting that SEC staff have consistently rejected similar arguments. Under SEC rules, AXON’s notice triggered NCF’s right to seek a judicial determination, and NCF has elected to do so. The suit requests expedited injunctive relief to ensure the proposal appears in AXON’s 2026 proxy statement, expected to be filed in mid-April.

“Companies should not be allowed to unilaterally determine what issues their shareholders can consider,” said Laura Campos, Senior Director of Economic Justice at NCF. “Upending the shareholder proposal process in this way harms rather than helps the processes by which investors and corporate leadership can work together to create and sustain long-term value. Lawsuits like this one filed against AXON were previously considered a last resort. But now, for many, they’re the only option.”

“The SEC’s retreat from the No Action process is leading to a great deal of uncertainty for both companies and investors,” said Josh Zinner, CEO of the Interfaith Center on Corporate Responsibility. “For shareholders, it could be increasingly difficult to engage with the companies they hold on issues of long-term corporate value. For companies, this abdication by the SEC will create additional legal and financial risk and undermines a long-standing private ordering process that enabled productive communication with their shareholders.

The court has also set a hearing on a preliminary injunction for March 4, 2026, at 3:00 pm.

MEDIA CONTACT:

Alex Tucciarone, atucciarone@iccr.org

Jon Zella, communications@nathancummings.org

Nathan Cummings Foundation (NCF) is a multigenerational family foundation honoring the Jewish tradition of social justice. NCF is working to shift power structures to co-create a more just, vibrant, sustainable, and democratic society. We support movements, change makers, and social entrepreneurs who are crafting solutions that advance racial, economic, and environmental justice.

Topics including plastics GHG emissions, DE&I and human rights have also seen robust support on ballots.

Members of the Interfaith Center on Corporate Responsibility announced they had filed 60 shareholder proposals for the 2025 proxy season calling for increased disclosures and strengthened oversight of corporate political activities at a diverse set of companies and sectors. These proposals included 32 resolutions on lobbying, 23 on political election spending, and five asking companies to assess if their lobbying on climate issues is consistent with their stated climate goals and objectives. You can read more about these proposals in ICCR’s 2025 Proxy Resolutions and Voting Guide.

The vast majority of companies engage in various forms of public policy advocacy to influence legislative and regulatory decisions, primarily through lobbying and campaign contributions. This advocacy takes place at all levels of government, ranging from municipal and state levels to federal legislative and regulatory processes. Open Secrets reported that total annual corporate lobbying expenditures surpassed $5.5 billion in 2024 and $6.2 billion in 2023, with the pharmaceutical, tech, financial services, and oil & gas sectors among the top spenders, either through direct lobbying or indirectly via third-party organizations like the U.S. Chamber of Commerce (Chamber). Additionally, the Chamber alone invested $823 million in lobbying activities from 2015 to 2024.

Through their memberships in trade associations like the Chamber and the National Association of Manufacturers (NAM), and their donations to Super PACs, 527 committees, “social welfare” organizations, and model legislation groups like the American Legislative Exchange Council (ALEC), corporations wield considerable influence on many issues.

“Companies exercise considerable power in their direct lobbying and indirectly through trade associations,” said Matthew Illian, Director of Responsible Investing for the United Church Funds, which held successful dialogues with four companies leading to the withdrawal of their proposals. “Investors are urging full transparency as well as careful evaluation of whether corporate lobbying activities align with a company’s stated values and priorities, as any misalignment may create reputational risk. We are pleased to see a number of companies responding positively to these appeals, resulting in withdrawal agreements and improved corporate responsibility.”

One such company responding positively to investor engagement is AbbVie. “Over the years AbbVie has incrementally added to its lobbying spending disclosure and also did not renew membership in four trade associations. We believe these actions help to address some of the risks, which is our goal as investors, and this year we were pleased to come to a productive agreement and withdrew the resolution,” said Zevin’s Marcela Pinilla, Director of Sustainable Investing.

Said Tim Smith, ICCR’s Sr. Policy Advisor, “Some corporations have significant influence over public policy issues and must evaluate if this advocacy is truly in the public interest. This is particularly true for climate lobbying,” Smith added. “Companies that lobby against sensible climate policy are engaging in short-sighted behavior that delays urgently needed action. Any delay in enacting climate-forward policies will exacerbate its negative impacts and increase the cost to address them.”

“In this political environment where changes in climate policies are coming fast and furious, it’s critical for companies to clearly articulate their climate public policy priorities and harmonize their lobbying activities with protecting those priorities,” said Andrea Ranger, Director of Shareholder Advocacy for Trillium Asset Management. “If they are not doing so, they may be letting trade associations, for example, advocate against the progressive climate laws, regulations, and programs they need to meet their decarbonization goals.”

ICCR members first filed proposals questioning corporate political activity in 1974, and since 2011, investors have submitted approximately 600 proposals seeking expanded lobbying reporting. These proposals generally receive strong shareholder support. This year, investors filed 32 lobbying proposals; however, early in the season, Air Products challenged its resolution at the SEC. Breaking from past practice, the SEC sided with the company and allowed the resolution to be omitted. This decision resulted in a surge of over 13 additional successful challenges by companies citing similar arguments.

However, many companies continued constructive lobbying discussions with shareholder proponents, which led to expanded disclosure and the successful withdrawal of resolutions at eight companies. Moreover, the proposals will appear on the proxy ballots of six companies to be voted on at annual meetings this spring.

Investors have also engaged portfolio companies around their donations to political candidates, citing the danger of corporate capture of government policy- and regulation-making with the potential to favor corporate activities over the interests of the voting public. This year, investors filed 23 proposals seeking increased disclosures around corporate political donations.

“Companies need to pay attention to the impact and risks of their political spending,” said Bruce Freed, President of the Center for Political Accountability (CPA). “CPA has several resources to help guide companies and their investors including its Corporate Underwriters report which examines how company political spending has reshaped state politics and created serious risks for companies, shareholders, and our democracy, and our Guide to Corporate Political Spending and Guide to Becoming a Model Code Company which give management and directors a framework for approaching, governing and assessing political spending to safeguard companies.”

Added Smith, “ICCR members and other responsible investors have long petitioned companies to expand disclosure and oversight and to adopt standards guiding their corporate political activities to ensure they are responsible. As long as companies participate in lobbying and political spending activities, we expect shareholder proposals on these topics will continue to be filed.”

About the Interfaith Center on Corporate Responsibility (ICCR)
The Interfaith Center on Corporate Responsibility (ICCR) is a broad coalition of more than 300 institutional investors collectively representing over $4 trillion in invested capital. ICCR members, a cross-section of faith-based investors, asset managers, pension funds, foundations, and other long-term institutional investors, have over 50 years of experience engaging with companies on environmental, social, and governance (“ESG”) issues that are critical to long-term value creation. ICCR members engage hundreds of corporations annually in an effort to foster greater corporate accountability. Visit our website www.iccr.org and follow us on LinkedIn, Bsky and X.

Corporate America, a few billionaires aside, is staying noticeably quiet with just days to go until the presidential election that’s divided the nation sharply.

The investor-backed Interfaith Center on Corporate Responsibility (ICCR) has called on 200 CEOs to support democratic institutions including free and fair elections and a peaceful transfer of power ahead of the US presidential election. The CEOs targeted are all part of the Business Roundtable (BRT) – a Washington-based lobbyist association representing the chief executives of some of the largest US companies. In the letter, ICCR investor members raised concerns that a destabilised democracy leads to deteriorated economic conditions, creating risks to the public and the economy and hampering the long-term value of investments.

The letter, sent to Business Roundtable executives, urged them to show support of “fair elections and the peaceful transfer of power” prior to the U.S. general election.

Companies should give their workers paid time off to vote in the US presidential election next month, investors that advocate on environmental, social, and governance issues told an influential business group.

NEW YORK, NY, WEDNESDAY, OCTOBER 16, 2024 – The Interfaith Center on Corporate Responsibility (ICCR) today announced they had sent a letter on Friday, October 11th to over 200 CEOs who are members of the Business Roundtable asking them to voice their support for democratic institutions including free and fair elections and the peaceful transfer of power in advance of the national election on November 5th.

As investors, ICCR members are concerned that a destabilized democracy leads to deteriorated economic conditions which create risks to the public and the economy and hamper the long-term value of investments.

Said Josh Zinner, ICCR’s CEO, “Fair elections and a strong rule of law are essential conditions for a flourishing democracy and a stable economy. As businesses participate in our politics via lobbying and political spending, we encourage them to responsibly use their voice and influence to support voting rights, free and fair elections, and a peaceful transfer of power.”

The threat of political violence this election season looms large and is being further fueled by misinformation campaigns and AI “deepfakes” from parties both within and outside the U.S. seeking to pre-emptively delegitimize the election outcome and to sow doubt about the fairness of our elections.

Said Rob Fohr, ICCR’s Board Chair, “As investors, we are concerned about the destabilizing social and economic effects of election misinformation, particularly given the advent of AI, and any restrictions on citizens’ legitimate right to vote. Upholding the rule of law and the right to vote in free and fair elections should be a priority for everyone, including companies and their stakeholders.”

As it did four years ago, ICCR urges the business community to issue public statements and encourage actions in support of democratic norms, including:

Support for free and fair elections including communications to the public and constituents underscoring the importance of voting, along with the provision of voter education resources and the facilitation of voting by employees through paid time off on election day, November 5;
A call for a thorough and complete counting of all ballots whether via mail-in, absentee, or in-person voting, along with a caution to both legislators and the media to delay the announcement of a winner until all votes are fully counted;
A call for all states to ensure a fair election by adopting policies and procedures that promote the right of citizens to vote, including lowering barriers to voter registration, increasing opportunities for early voting, and expanding the number and hours of polling places;
A condemnation of any tactics that could be construed as voter intimidation and support for measures that will ensure voter safety;
Support for the peaceful transfer of power. Endorsement of this principle is critical for the protection of our democracy;
Ensure that political donations and lobbying activities support the above.

ICCR commends the statement released on Tuesday afternoon by BRT’s CEO Joshua Bolten in which he stated, “Voting is a fundamental right of American citizens. The strength of our nation’s democracy and the stability of America’s economy depend on free and fair elections.”

Proactive statements from the individual members of the BRT are urged to help underscore business support for these democratic norms.

Included in the letter are several resources and strategies to help companies take a proactive, principled approach to address enterprise and societal risks in the upcoming election.

“Companies political spending can create serious reputational risk if that election spending is perceived as supporting barriers to voting or to the democratic transfer of power,” said Timothy Smith, ICCR’s Senior Policy Advisor. “We are pleased to include specific tools in our letter to help BRT companies better navigate these risks and thereby model best practices for their peers.”

CONTACT:

Susana McDermott
Director of Communications
Interfaith Center on Corporate Responsibility (ICCR)
201-417-9060 (mobile)
smcdermott@iccr.org

CONTACT:
Susana McDermott
Director of Communications
Interfaith Center on Corporate Responsibility (ICCR)
201-417-9060 (mobile)
smcdermott@iccr.org

NEW YORK, NY, TUESDAY, FEBRUARY 27 2024 – Members of the Interfaith Center on Corporate Responsibility and allied investors announced a slate of 63 shareholder proposals for 2024 proxies at a diverse set of companies across multiple sectors calling for increased disclosures and strengthened oversight of corporate political activities. You can read more about these proposals in ICCR’s Proxy Resolutions and Voting Guide.

The vast majority of companies utilize various forms of public policy advocacy to impact legislative and regulatory decisions mainly through lobbying and campaign contributions. This advocacy occurs at all levels of government, from the municipal and state levels to federal legislative and regulatory processes. Statistica reported total corporate lobbying expenditures exceeding $4 billion annually in 2022 with the pharmaceutical, tech, financial services, and oil & gas sectors among the top spenders either through direct lobbying or indirectly through third-party organizations. Some of the issues that attract significant lobbying dollars include efforts by pharmaceutical companies to protect drug patents resulting in higher drug prices; efforts on behalf of fossil fuel companies and heavy polluters to limit environmental regulation at the state and federal levels; and spending by firearms manufacturers to prevent sensible gun control legislation, among many others.

“ICCR members and other responsible investors have long petitioned companies to expand disclosures and adopt standards since guardrails for corporate political activities are so clearly needed,” said Tim Smith, ICCR’s Senior Policy Advisor. “Some corporations have an outsized influence over public policy issues and they need to evaluate if this advocacy is truly in the public interest.”

Through their memberships in trade associations like the U.S. Chamber of Commerce and the National Association of Manufacturers (NAM), and their donations to Super PACs, 527 committees, “social welfare” organizations, and model legislation groups like the American Legislative Exchange Council (ALEC), corporations have an outsized voice on many issues affecting the public interest. Without robust oversight, investors say these political activities run the risk of inviting corruption, damaging democratic structures, and – when these activities conflict with a company’s stated mission and values – causing reputational damage to participating companies.

“Companies exercise considerable power in their direct and indirect lobbying through trade associations and this year, the issues of political spending and lobbying will once again be a high priority for investors,” said Caroline Boden of Mercy Investment Services. “Investors are urging full transparency in those activities as well as careful evaluation of whether they align with a company’s stated values and priorities as any misalignment may create reputational risk and unwanted controversy. We are pleased to see a number of companies responding positively to these appeals resulting in withdrawal agreements and improved corporate responsibility on this issue.”

Investors say the risks of corporate political activity are heightened in the run-up to a highly consequential national election.

“In 2024, it is essential that companies act as positive forces to protect and preserve democracy,” said Matthew Illian of United Church Funds. “Companies can encourage politicians to support fair and free elections as well as carefully scrutinize whether their corporate and PAC funds are channeled to politicians who advance democratic freedoms. Many companies have added specific restrictions on contributions to trade associations stipulating their dues cannot be used for election purposes.”

Last August, ICCR members sent a letter to CEO members of the Business Roundtable urging them to assess whether their policy advocacy reinforces or undermines democratic principles including free and fair elections and healthy civic engagement.

“Given the stakes of this year’s elections, companies need to pay even greater attention to the impact and risks of their political spending,” said Bruce Freed, President of the Center for Political Accountability (CPA). “CPA has several resources to help guide companies and their investors including Corporate Underwriters and the Democracy Gap which examines how company political spending has reshaped state politics and created serious risks for companies, shareholders, and our democracy, and our Guide to Corporate Political Spending and Guide to Becoming a Model Code Company which give management and directors the framework for approaching, governing and assessing political spending to safeguard companies.”

Since the proposals were filed, there have been constructive discussions with companies and several agreements reached between shareholders and companies allowing the proponents to withdraw the proposals. Among these were negotiated agreements with Starbucks and Boeing, which agreed to provide detailed additions to their lobbying reports. In addition, a resolution at Stride nearly reached a majority vote with 49.5% shareholder support.

ICCR members urge companies to implement the Erb Principles for Corporate Political Responsibility and the CPA-Zicklin Model Code of Conduct for Corporate Political Spending which provide a framework for companies to approach and govern their election-related spending to ensure it is consistent with corporate values and the goal of supporting democratic institutions and the public interest.

About the Interfaith Center on Corporate Responsibility (ICCR)

The Interfaith Center on Corporate Responsibility (ICCR) is a broad coalition of more than 300 institutional investors collectively representing over $4 trillion in invested capital. ICCR members, a cross-section of faith-based investors, asset managers, pension funds, foundations, and other long-term institutional investors, have over 50 years of experience engaging with companies on environmental, social, and governance (“ESG”) issues that are critical to long-term value creation. ICCR members engage hundreds of corporations annually in an effort to foster greater corporate accountability. Visit our website www.iccr.org and follow us on Twitter/X (@iccronline), LinkedIn, and Facebook.

Discover the coalition of shareholder activist groups advocating for enhanced human capital disclosures, the rationale behind the call for transparency, and the potential benefits of a more accountable corporate world.

Nathan Cummings Foundation Files Suit to Prevent Axon from Excluding Shareholder Proposal on Political Spending Transparency