Huntington Ingalls Industries | Interfaith Center on Corporate Responsibility

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<h4>Resolution Details</h4>
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<strong>Company:</strong>
<p>Huntington Ingalls Industries</p>
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<strong>Year:</strong>
<p>2026 </p>
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<strong>Issue Area:</strong>
<p>Lobbying & Political Contributions </p>
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<strong>Focus Area:</strong>
<p>Lobbying </p>
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<strong>Status:</strong>
<p>Filed</p>
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<h2>Resolution Text</h2>
<p><strong>RESOLVED</strong>: Shareholders of Huntington Ingalls request that the Company provide a report, updated annually, disclosing the Company’s:<br> <br>1.    Policies and procedures for making, with corporate funds or assets, contributions and expenditures (direct or indirect) to (a) participate or intervene in any campaign on behalf of (or in opposition to) any candidate for public office, or (b) influence the general public, or any segment thereof, with respect to an election or referendum.</p>
<p><br>2.    Monetary and non-monetary contributions and expenditures (direct and indirect) used in the manner described in section 1 above, including the identity of the recipient as well as the amount paid to each.<br> <br>The report shall be presented to the board of directors or relevant board committee and posted on the Company’s website. This proposal does not encompass lobbying spending.</p>
<p><strong>SUPPORTING STATEMENT</strong>:</p>
<p dir=”ltr”>Long-term shareholders of HII support transparency and accountability in corporate electoral spending. This includes any activity considered intervention in a political campaign under the Internal Revenue Code, such as direct and indirect contributions to political candidates, parties, or organizations, and independent expenditures or electioneering communications on behalf of federal, state, or local candidates.<br> <br>A company’s reputation, value, and bottom line can be adversely impacted by political spending. The risk is especially serious when giving to trade associations, Super PACs, 527 committees, and “social welfare” organizations – groups that routinely pass money to or spend on behalf of candidates and political causes that a company might not otherwise wish to support.<br> <br>A recent poll of retail shareholders by Mason-Dixon Polling & Research found that 83% of respondents said they would have more confidence investing in companies that have adopted reforms that provide for transparency and accountability in political spending.<br> <br>HII scored 37% out of a possible score of 100% in the 2025 CPA-Zicklin Index of Corporate Political Disclosure and Accountability <https://www.politicalaccountability.net/wp-content/uploads/2025/11/2025-CPA-Zicklin-Index.pdf> <br> <br>This proposal asks HII to disclose all of its electoral spending, including payments to Trade Associations and 501(c)(4) social welfare organizations, which may be used for electoral purposes–and are otherwise undisclosed. This would bring our Company in line with a growing number of leading companies, including Fortive, Marvell Technology, and Micron Technology, which present this information on their websites.<br> <br>Without knowing the recipients of our company’s political dollars HII directors and shareholders cannot sufficiently assess whether our company’s election-related spending aligns with or conflicts with its policies on climate change and sustainability and other areas of concern.</p>

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<h3>Lead Filer</h3>
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<div class=”views-field views-field-nothing”><span class=”field-content”> John Chevedden</span></div><div class=”views-field views-field-title views-field-field-shareholder”><span class=”field-content”>Chevedden Corporate Governance</span></div>
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Resolution Details

Company:

Huntington Ingalls Industries

Year:

2024

Issue Area:

Lobbying & Political Contributions

Focus Area:

Lobbying

Status:

Filed

Resolution Text

RESOLVED, the stockholders of Huntington Ingalls Industries (“HII”) 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 HII 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. HII’ 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 HII 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 and Policy Committee and posted on HII’s website.

SUPPORTING STATEMENT

Full disclosure of HII’s lobbying activities and expenditures is needed to assess whether HII lobbying is consistent with its expressed goals and in stockholder interests. HII spent $57,615,041 from 2011 – 2021 on federal lobbying. This does not include state lobbying expenditures, where HII also lobbies but disclosure is uneven or absent. HII’s lobbying ahead of a recent annual defense budget bill has drawn scrutiny,1 and its 2020 federal lobbying put it in the top ten for federal contractor lobbying.2

Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity.3 HII does not disclose its payments to, trade associations and social welfare groups (SWGs), or the amounts used for lobbying. HII belongs to the Business Roundtable (BRT) and sits on the board of the National Association of Manufacturers (NAM), which together have spent over $600 million on federal lobbying since 1998. HII’s disclosure omits trade association memberships in the Association for Unmanned Vehicles and Virginia Chamber and leaves out all SWGs.

HII’s lack of disclosure presents reputational risks when its lobbying contradicts company public positions. For example, our company notes “congressional actions to reduce the federal debt and resulting pressures on federal spending could adversely affect the total funding of individual contracts” as a business risk in its 2022 annual report, while the BRT and NAM lobbied against raising corporate taxes.4 And while HII does not belong to the controversial American Legislative Exchange Council, which is attacking “woke” investing,5 it was represented by NAM, which previously sat on its Private Enterprise Advisory Council.6

Reputational damage stemming from these misalignments could harm stockholder value. HII should expand its lobbying disclosure

1 https://www.opensecrets.org/news/2023/10/defense-contractors-spent-70-million-lobbying-ahead-of-annual-defense-budget-bill-ndaa/.

2 https://www.politico.com/newsletters/morning-defense/2021/01/29/defense-lobby-spending-totals-for-2020-793059.

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

4 https://www.washingtonpost.com/us-policy/2021/08/31/business-lobbying-democrats-reconciliation/; https://www.washingtonpost.com/politics/2021/09/29/lobbyists-battle-over-democrats-35-trillion-budget-plan/.

5 https://www.wbur.org/hereandnow/2023/03/22/esg-investing-fossil-fuels.

6 https://www.exposedbycmd.org/2023/02/03/alec-expands-private-board-of-directors-with-woke-capitalism-fighters/.