Lobbying Expenditures - Climate Policy

2016 – ConocoPhillips



WHEREAS, we believe in full disclosure of our company’s direct and indirect lobbying activities and expenditures to assess whether our lobbying is consistent with ConocoPhillips expressed goals and in the best interests of shareholders.  


RESOLVED, shareholders request the Board prepare a report, updated annually disclosing:


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


2. Payments by ConocoPhillips 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 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 ConocoPhillips is a member.


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


The report shall be presented to the Audit Committee or other relevant oversight committees of the Board and posted on the company’s website. 


Supporting Statement: We encourage transparency and accountability in the use of staff time and corporate funds to influence legislation and regulation both directly and indirectly. The lobbying by oil and gas companies on climate policy is increasingly under scrutiny globally.


This resolution received 27% voting support in 2015.


We appreciate the update on the company website and in its proxy on both political spending and lobbying including expanded management oversight.  However, the responses focused heavily on political spending which is not the subject of this resolution. And the website disclosure is incomplete, omitting lobbying priorities and specific contributions to trade associations and the percent used for lobbying.


ConocoPhillips is on the Board of the United States Chamber of Commerce which is noted as “by far the most muscular business lobby group in Washington” (“Chamber of Secrets,” Economist, April 21, 2012). Since 1998 the Chamber has spent over $1 billion on lobbying. Yet ConocoPhillips does not disclose its Chamber payments nor the portions used for lobbying. 


This is an integrity problem for ConocoPhillips since the Chamber opposes many environmental regulations and actively campaigns against the new EPA Clean Power Plan.


We urge ConocoPhillips to evaluate if their public policy advocacy and lobbying is consistent with positive climate solutions or if their funds are used to oppose climate legislation or regulation. 


ConocoPhillips spent approximately over $32 million between 2011 & 2014 on direct federal lobbying activities, according to Senate Records.  These figures may not include grassroots lobbying to directly influence legislation by mobilizing public support or opposition nor lobbying expenditures in states that do not require disclosure.