Design Political Activity Disclosure Policy

---
name: design-political-activity-disclosure-policy
description: Use when a company engages in political spending, lobbying, or trade association dues that fund political activity — establishing board-level oversight of this spending and voluntary transparency about it, rather than treating political activity as an operational decision with no defined governance or disclosure structure behind it.
source: Center for Political Accountability (CPA), CPA-Zicklin Index model disclosure and accountability policy
tags: [business, operations, political-activity-disclosure, corporate-governance, lobbying-transparency]
related: [design-esg-oversight-committee, design-conflict-of-interest-policy, design-committee-charter-framework]
---

# Design Political Activity Disclosure Policy

Establish board-level oversight of corporate political spending, lobbying activity, and trade association dues that fund political activity, and adopt voluntary transparency about that spending — rather than treating political activity as an ordinary operational decision with no defined governance or disclosure structure behind it.

## Why This Is Best Practice

**Adopted by:** The Center for Political Accountability's CPA-Zicklin Index — now covering the S&P 500 — tracks corporate political disclosure and accountability practices and has documented a sustained, multi-year trend of increasing voluntary board-level oversight and public disclosure of political spending among major public companies, reflecting sustained institutional investor pressure specifically on this governance dimension.
**Impact:** Companies with weak or no board oversight of political spending are documented to face materially higher reputational and shareholder-proposal risk when spending is later revealed to be inconsistent with the company's publicly stated values or creates unexpected controversy — the CPA-Zicklin Index specifically documents that companies with stronger disclosure and board oversight scores experience fewer of these reputational surprise events.
**Why best:** Political spending decisions made without board awareness or a defined governance process carry the same "unknown until it becomes a problem" risk profile that undefined oversight creates in other spending categories — a company's political spending can create outsized reputational consequences relative to the dollar amounts involved, and board-level oversight combined with voluntary disclosure is specifically what gives the company a chance to identify and address a potential inconsistency or controversy before it becomes public.

Sources: Center for Political Accountability (CPA), CPA-Zicklin Index for Corporate Political Disclosure and Accountability

## Steps

### Step 1: Establish board-level oversight of political spending decisions

Assign board-level oversight of political spending — direct corporate contributions where legally permitted, independent expenditures, and payments to trade associations and 501(c)(4) organizations used partly for political purposes — to a specific committee (often the nominating/governance or ESG committee), rather than leaving these decisions entirely to management with no board visibility.

### Step 2: Require internal review for consistency with stated company values

Require political spending and lobbying decisions to be reviewed for consistency with the company's publicly stated values and positions, since spending inconsistent with a company's public commitments (on environmental policy, social issues, or other stated positions) is a documented common source of reputational controversy when later revealed.

### Step 3: Track indirect political spending through trade associations and dues

Track not only direct political spending but also the portion of trade association dues and 501(c)(4) contributions used for political purposes, since indirect spending through these channels is documented as a common source of "surprise" political activity a company didn't directly control but is still associated with.

### Step 4: Adopt voluntary public disclosure of political spending

Adopt voluntary public disclosure of the company's political spending, lobbying expenditures, and trade association memberships with political activity — consistent with the trend the CPA-Zicklin Index documents among leading companies — since voluntary transparency is documented to reduce (though not eliminate) subsequent shareholder-proposal pressure on this topic.

### Step 5: Review the policy and disclosure practice periodically

Review the political activity policy and disclosure practice periodically as the company's public positions, the political landscape, and institutional investor expectations on this topic continue to evolve.

## Rules

- Assign specific board-level oversight of political spending decisions, not leave this category of spending entirely to management with no board visibility.
- Review political spending and lobbying decisions for consistency with the company's own publicly stated values and positions.
- Track indirect political spending through trade association dues and 501(c)(4) contributions, not only direct spending.
- Adopt voluntary public disclosure of political spending consistent with leading company practice, rather than defaulting to no disclosure.

## Examples

**Board oversight catching a values inconsistency before it becomes public:** A proposed trade association membership renewal is flagged during board-level review as funding lobbying activity inconsistent with a public commitment the company made on a specific policy issue. The company addresses the inconsistency (renegotiating the membership terms or reconsidering the association) before the inconsistency becomes a public controversy — a review only possible because board oversight of this spending category existed in the first place.

**Voluntary disclosure reducing shareholder proposal pressure:** A company that adopts voluntary, detailed disclosure of its political spending and lobbying activity, consistent with leading CPA-Zicklin Index practices, experiences less shareholder proposal pressure on this topic than peer companies with no comparable disclosure, illustrating the documented relationship between voluntary transparency and reduced governance friction on this issue.

## Common Mistakes

- **Leaving political spending decisions entirely to management with no board-level oversight** — this creates the same "unknown until it's a problem" risk profile that undefined oversight creates in other consequential spending categories.
- **Tracking only direct political contributions while ignoring indirect spending through trade associations and 501(c)(4) organizations** — indirect spending is a documented common source of reputational surprise a company didn't directly control but remains associated with.
- **Failing to review spending decisions for consistency with the company's own publicly stated values** — this inconsistency, when later revealed, is a documented common source of reputational controversy.
- **Defaulting to no voluntary disclosure** — companies with stronger disclosure practices are documented to experience less subsequent shareholder-proposal and reputational pressure on this topic.

## When NOT to Use

- For a company with no meaningful political spending, lobbying activity, or trade association dues funding political activity — apply oversight and disclosure proportionate to actual political activity exposure.
- For a private company with no institutional shareholder base for whom this disclosure is a significant governance consideration — the underlying principle may still have reputational value, but the specific investor-driven pressure differs.
- As a substitute for the company's broader ESG governance oversight — political activity disclosure is one specific topic; see `design-esg-oversight-committee` for the broader governance structure it may fall under.