WELLS FARGO & COMPANY | Report on congruency of political spending at WELLS FARGO & COMPANY

Status
28.52% votes in favour
AGM date
Previous AGM date
Proposal number
6
Resolution details
Company ticker
WFC
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
Financials
Company HQ country
United States
Resolved clause
Shareholders request that Wells Fargo report to shareholders annually, at reasonable expense and excluding confidential
information, a congruency analysis between corporate values as defined by Wells Fargo’s stated policies and Company contributions
on electioneering and to any organizations dedicated to affecting public policy. The report should include a list of any such
contributions occurring during the prior year misaligned with stated corporate values, stating the justification for such exceptions.
Whereas clause
Our Company published statements demonstrating that it monitors and works toward
progress on Environmental Social Governance (ESG) challenges, stating it:
Shareholder Proposals
“regularly assesses ESG and sustainability themes...monitors ESG trends ...which inform its strategies, goals, and reporting
priorities ....”1
“believes that it has a role to play in addressing social, economic, and environmental sustainability,”2
“believe[s] that climate change continues to be one of the most urgent environmental and social issues of our time, and [is]
working...to help accelerate the transition to a low carbon economy...”3
Yet, Wells Fargo supports organizations working against ESG investing and climate related financial risk management, including the
State Financial Officers Foundation (SFOF) and the Republican Attorneys General Association.
SFOF has advanced model legislation in at least five states directing state lawmakers and treasurers to cancel state contracts with
companies that address climate risk, stating those institutions are “boycotting” fossil fuel companies.4
Evident conflict for our Company has not gone unnoticed. Congressman Casten and Senator Schatz wrote our CEO, requesting
confirmation of Company plans to withdraw its sponsorship of SFOF, emphasizing SFOF’s approach misrepresents valid steps banks
and asset managers are taking to minimize exposure to climate risks.5
Wells Fargo Political Action Committee (PAC) “Transparency Report” leaked, detailing its contribution criteria. The report notes the
PAC aims to support candidates who “are willing to work in a bipartisan manner... and support diversity, equity, and inclusion.”6 Yet,
some of the PAC’s political contributions contradict this goal.
For example, the PAC donated to members of Congress that voted against certifying the Electoral College, including Kevin
McCarthy, Blaine Luetkemeyer, and David Kustoff.7 Additionally, Texas Governor Abbott received $20,000 from the PAC, despite
launching child abuse investigations into parents of trans youth.
Supporting statement
Proponents recommend, at Board and management discretion, the report also include management’s
analysis of risks to the Company brand, reputation, or shareholder value associated with incongruent expenditures. “Electioneering
expenditures” means spending, from corporate treasury and from the PAC, directly or through a third party, at any time during the
year, on printed, internet, or broadcast communications, which are reasonably susceptible to interpretation as being in support of or
opposition to a specific candidate.

How other organisations have declared their voting intentions

Organisation name Declared voting intentions Rationale
Rothschild & co Asset Management For
Anima Sgr For Given the media attention Wells Fargo has received as a result of its contribution to politicians and organizations, the approval of this proposal would allow shareholders to better evaluate the company's relevant political contributions and policies, as well as the company's risk management and oversight of related risks.

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