Oracle: Report on Lobbying
We are pleased to report that our proposal received a 28.2% vote in favor—a strong show of support—at Oracle’s annual shareholder meeting last week
We believe in full disclosure of our company’s direct and indirect lobbying activities and expenditures to assess whether Oracle’s lobbying is consistent with its expressed goals and in the best interests of stockholders.
As stockholders, we encourage transparency and accountability in the use of corporate funds to influence legislation and regulation, both directly and indirectly. Oracle spent over $68 million from 2010—2017 on federal lobbying (opensecrets.org). This figure does not include expenditures to influence legislation in states, where Oracle also lobbies but disclosure is uneven or absent. For example, Oracle spent $1,865,597 on lobbying in California from 2010—2017 and reportedly lobbied in 35 different states from 2010 through 2014 (“Amid Federal Gridlock, Lobbying Rises in the States, ”The Center for Public Integrity, February 11, 2016). Oracle’s federal lobbying spending has attracted media scrutiny (“Pentagon Goes Winner-Take-All for CloudAward Worth Billions,”Bloomberg, March 7, 2018), as has its international lobbying (“Oracle and Naspers’ Stealth Lobbying Fight against Google,”Politico Europe, February 16, 2018).
Oracle is a listed as a member of the Business Roundtable, which spent $126.93 million on lobbying from 2010—2017 and is lobbying against the right of shareholders to file resolutions (“U.S. Investor, CEO Groups Set for Lobbying Battle over ProxyChallenges, ”Reuters, March 17, 2017). Unlike many of its peers including Intel and Microsoft, Oracle does not disclose its memberships in, or payments to, trade associations, or the amounts used for lobbying. Absent a system of accountability, company assets could be used for objectives contrary to Oracle’s long-term interests.
Shareholders of Oracle request the preparation of a report, updated annually, disclosing:
- Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.
- Payments by Oracle used for (a) direct or indirect lobbying or (b) grassroots lobbying communications, in each case including the amount of the payment and the recipient.
- Oracle’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 in sections 2 and 3 above.
The report shall be presented to the Audit Committee or other relevant oversight committees and posted on the company’s website.
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 Oracle is a member.Both “direct and indirect lobbying” and “grassroots lobbying communications” include efforts at the local, state and federal levels.