THE BOEING COMPANY | Lobbying Expenditures Disclosure at THE BOEING COMPANY

AGM date
Previous AGM date
Proposal number
Resolution details
Company ticker
Resolution ask
Report on or disclose
ESG theme
  • Governance
ESG sub-theme
  • Lobbying / political engagement
Type of vote
Shareholder proposal
Filer type
Company sector
Company HQ country
United States
Resolved clause
"RESOLVED, the shareholders of Boeing request the preparation of a report, updated annually, disclosing:
1.   Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications. 
Payments by Boeing used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient. Boeing’s membership in and payments to any tax-exempt organization that writes and endorses model legislation. Description of management’s decision-making process and the Board’s oversight for making payments described 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 Boeing 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 & Public Policy Committee and posted on Boeing’s website. "
Supporting statement
Full disclosure of Boeing’s lobbying activities and expenditures is needed to assess whether its lobbying is consistent with its expressed goals and shareholder interests. Boeing spent $206,050,000 from 2010 – 2022 on federal lobbying. This does not include state lobbying, where Boeing also lobbies but disclosure is uneven or absent. For example, Boeing spent $1,305,114 on lobbying in California from 2010 – 2022. And Boeing also lobbies abroad, spending between €800,000 – 899,999 on lobbying in Europe for 2022. Boeing has reportedly been rebuilding its lobbying clout lost in 737 MAX crashes.[1]
Companies can give unlimited amounts to third party groups that spend millions on lobbying and undisclosed grassroots activity.[2]Unlike many of its peers, Boeing fails to disclose its payments to trade associations and social welfare groups (SWGs), or the amounts used for lobbying, to shareholders. Boeing belongs to the Business Roundtable (BRT), National Association of Manufacturers and US Chamber Commerce, which have spent over $2.3 billion on federal lobbying since 1998, and supports “dark money” SWGs like the American Action Network.[3]
Boeing’s lack of disclosure presents reputational risk when its lobbying contradicts company public positions. For example, Boeing believes in addressing climate change, yet the BRT lobbied against the Inflation Reduction Act[4] and the Chamber reportedly has been a “central actor” in dissuading climate legislation over a two-decade period.[5] While Boeing has previously drawn scrutiny for avoiding federal taxes,[6] the BRT has lobbied against a new minimum corporate tax.[7] And while Boeing does not belong to the controversial American Legislative Exchange Council, which is attacking “woke” investing,[8] it is represented by the Chamber, which sits on its Private Enterprise Advisory Council.[9]

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