Here’s an excerpt from this 28-page report on board political activities oversight disclosure penned by Labrador’s Laura Ann Smith (the report contains numerous disclosure examples):
“Companies have moved well beyond mere mention of prohibited political contributions or political activities in the descriptions of their Codes of Ethics or including related policies among their list of key governance documents.
Many companies now list their political contribution and activity policies and/or board oversight of the
company’s political activities among their governance or sustainability highlights in their proxy summary or governance sections. Some are even highlighting the importance of political and public policy experience in the board skills descriptions.
Shareholder engagement sections often highlight these topics as key focus areas for investors, particularly in the year(s) following a shareholder proposal, and speak to the adoption of a related policy or improved disclosures as actions taken in response to shareholder feedback.
Oversight of political contributions and public policy engagement is increasingly included among the enumerated areas of board oversight (alongside other widely discussed topics such as cybersecurity, sustainability, and management succession). In addition, responsibility for such areas have been assigned to specific board committees – ranging from audit committees, governance committees, sustainability committees – and some companies have even started to rename committees to include Public Policy to demonstrate the importance of such oversight. As a result, delegation of such responsibilities also appears in the risk oversight infographic and committee descriptions.
Finally, in a direct effort to be responsive to shareholder concerns, many companies now include a standalone section dedicated to their political activities. Some are solely focused on increased transparency of the company’s reporting on political spending and lobbying activities, while others also include an expanded discussion of board oversight with increased detail on board approach and philosophy, how the board is involved, and frequency of reporting to the board.”
