Verizon: Report on Lobbying

Verizon Communications Inc.

We believe in full disclosure of Verizon's direct and indirect lobbying activities and expenditures to assess whether Verizon's lobbying is consistent with its expressed goals and in the best interests of shareholders.

We encourage transparency in Verizon's use of funds to lobby. Verizon has spent $108,430,000 from 2010-2017 on federal lobbying. This figure does not include state lobbying expenditures in the 50 states where Verizon lobbies but disclosure is uneven or absent ("Amid Federal Gridlock Lobbying Rises in the States," Center for Public Integrity, February 11, 2016). For example, a study found Verizon spent $13,662,976 lobbying in six states from 2012-2015 ("How Leading U.S. Corporations Govern and Spend on State Lobbying," Sustainable Investments Institute, February 2017).

We commend Verizon for ending its membership in the American Legislative Exchange Council ("Verizon Dumps ALEC, Denounces Speaker as Racist," PR Watch, September 17, 2018). However, serious disclosure concerns remain. Verizon is a member of the Chamber of Commerce, which has spent over $1.4 billion on lobbying since 1998, and also belongs to the Business Roundtable (BRT), National Association of Manufacturers (NAM) and USTelecom. Both the BRT and NAM are lobbying against shareholder rights to file resolutions. Verizon does not disclose its memberships in, or payments to, trade associations, or the amounts used for lobbying.

We are concerned that Verizon's lack of lobbying disclosure presents reputational risk when it contradicts Verizon's public positions. For example, Verizon states it is committed to an open internet, yet USTelecom is actively fighting against net neutrality ("AT&T/Verizon Lobbyists to 'Aggressively' Sue States that Enact Net Neutrality," Ars Technica, March 27, 2018). As shareholders, we believe that companies should ensure there is alignment between their own positions and their lobbying, including through trade associations.

Therefore, we request that Verizon prepare a report, updated annual, disclosing:

  1. company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications.
  2. Payments by Verizon 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 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 Verizon 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 Corporate Governance and Policy Committee and posted on Verizon's website.