IBM: Disclose Your Lobbying

International Business Machines Corporation

IBM should increase its transparency and accountability by expanding its lobbying disclosure. IBM's lobbying should be consistent with the company’s expressed goals and in the best interests of shareholders.

we believe in full disclosure of our company’s direct and indirect lobbying activities and expenditures to assess whether our lobbying is consistent with IBM’s expressed goals and in the best interests of shareholders. IBM spent approximately $24.4 million from 2012 - 2016 on federal lobbying (Senate reports).  This total does not include expenditures to influence legislation in states and provides limited information regarding lobbying conducted by third parties.

We commend IBM for its thoughtful policy regarding political spending and the electoral process prohibiting political contributions with company funds. We believe IBM should also establish high standards for evaluating and disclosing company participation and spending in the legislative process through lobbying as well.

IBM does not disclose its memberships in, or payments to, trade associations, or the portions of these payments used for lobbying.  In contrast, competitors Microsoft, Xerox and Intel publicly disclose their indirect lobbying expenditures through their trade associations.

IBM sits on the board of the US Chamber of Commerce, which since 1998 spent approximately $1.4 billion dollars on lobbying. IBM does not disclose its Chamber payments nor the portion used for lobbying.

IBM’s statement on climate change policy states that “IBM recognizes climate change is a serious concern that warrants meaningful action on a global basis to stabilize the atmospheric concentration of greenhouse gases (GHGs).”  In contrast, the Chamber has publicly attacked the EPA and sued to stop climate change solutions. 

IBM is also a member of the Business Roundtable, an organization with approximately 200 CEOs as members.  The BRT is leading an attack against shareholder rights to file resolutions. Yet IBM is justifiably proud of its record of engaging shareholders in constructive conversation.

IMB should disclose the following publicly:

1. Company policy and procedures governing lobbying, both direct and indirect lobbying communications. 2. Payments by IBM 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 the decision making process and oversight by management and Board for lobbying expenditures. 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 any trade association or other organization of which IBM is a member.  Both “direct and indirect lobbying” and “grassroots lobbying communications” include efforts at the local, state and federal levels.