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

Resolved, the shareowners of Honeywell request the preparation of a report, updated annually, disclosing:

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

2. Payments by Honeywell 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 management’s and the Board’s decision making process and oversight 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 Honeywell is a member.

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

The report shall be presented to the Corporate Governance and Responsibility Committee and posted on Honeywell’s website.

Supporting Statement

We encourage transparency in Honeywell’s use of funds to lobby. Honeywell spent $53,160,000 from 2010 – 2018 on federal lobbying. This does not include state lobbying expenditures, where Honeywell also lobbies but disclosure is uneven or absent. For example, Honeywell spent $5,629,576 on lobbying in New Jersey for 2010 – 2018. And Honeywell also lobbies abroad, spending between €500,000 – €599,000 on lobbying in Europe for 2017.

We commend Honeywell for ending its membership in the American Legislative Exchange Council (“Charles Koch Ramps Up Investment in ALEC as the Lobbying Group Loses Corporate Funders over Far-Right Ties,” The Intercept, November 29, 2018). However, serious disclosure concerns remain. Honeywell sits on the board of the Chamber of Commerce, which has spent over $1.5 billion on lobbying since 1998, and belongs to the Business Roundtable, which spent over $50 million on lobbying for 2017 and 2018 and is lobbying against shareholder rights to file resolutions. Unlike its peers Raytheon and United Technologies, Honeywell does not disclose its memberships in, or payments to, trade associations, or the amounts used for lobbying.

We are concerned that Honeywell’s lack of disclosure presents reputational risks when its lobbying contradicts company public positions. For example, Honeywell is committed to reducing global greenhouse gases and signed an agreement to work with United Nations Environment to combat climate change, yet the Chamber undermined the Paris climate accord. As shareowners, we believe that companies should ensure there is alignment between their own positions and their lobbying, including through trade associations.

This proposal received 42.4 percent support in 2019 out of votes cast for and against. We urge Honeywell to expand its lobbying disclosure.