33.7% in favor
Proposal requesting the Walt Disney Company prepare a report, updated annually disclosing the company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications. The report should include payments for lobbying activities and a description of management’s decision-making process and the Board’s oversight for making the payments.
Disney filed a no-action request to the SEC that the proposal be excluded on basis of substantially implemented. In its argument, the company notes it has adopted and disclosed its ‘Political Giving and Participation in the Formulation of Public Policy in the U.S.’ and it maintains an archive on its website of contributions amounts and recipients. SEC denied challenge.
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