UPS: Disclose Your Lobbying

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

We encourage transparency and accountability regarding staff time and corporate funds to influence legislation and regulation. We appreciate UPS' website disclosure on political contributions, but UPS's lobbying payments through trade associations remain secret.

UPS spent $51.3 million from 2010-2017 on federal lobbying. This total does not include state lobbying expenditures, where UPS also lobbies but disclosure is uneven or absent. A study found UPS spent $1,587,609 lobbying in six states from 2012-2015. [1] 

UPS sits on the board of the Chamber of Commerce, which has spent over $1.4 billion lobbying since 1998, and belongs to the Business Roundtable, which is lobbying against the right of shareholders to file resolutions. UPS does not disclose its memberships in, or payments to trade associations, or the amounts for lobbying. And UPS does not disclose its membership in tax-exempt organizations that write and endorse model legislation, such as sitting on the Private Enterprise Advisory Council of the American Legislative Exchange Council (ALEC).

We are concerned that UPS's lack of trade association and ALEC disclosure presents reputational risks. For example, UPS strongly supports efforts to mitigate the impact of climate change, yet the Chamber opposed the Paris climate accord. We urge UPS as a Board member to challenge the Chamber's negative climate policy And UPS's ALEC membership has drawn press scrutiny [2], while over 100 companies have publicly left ALEC, including 3M, AstraZeneca, McDonalds and Pepsi.

UPS should publicly disclose the following:

1. Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications. 

2. Payments by UPS 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. UPS’s membership in and payments to any tax-exempt organization that writes and endorses model legislation. 

4. Description of the decision making process and oversight by management and the Board for making payments described in section 2 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 UPS is a member.

“Direct and indirect lobbying” and “grassroots lobbying communications” include efforts at the local, state and federal levels. 

[1] "How Leading U.S. Corporations Govern and Spend on State Lobbying," Sustainable Investments Institute, February 2017

[2] "UPS and Pfizer's Dirty Little Secret," Washington Post, December 5, 2017