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

RESOLVED, the shareholders of Ford 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 Ford 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 decision-making process and the Board’s 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 Ford 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 Audit Committee or other relevant oversight committees and posted on Ford’s website. 

Supporting Statement: Ford spent $47,193,894 from 2010 – 2018 on federal lobbying. This does not include state lobbying expenditures, where Ford also lobbies but disclosure is uneven or absent. For example, Ford spent $3,227,295 on lobbying in California from 2010 – 2018. 

Ford is a member of the Chamber of Commerce, which has spent more than $1.5 billion on lobbying since 1998, and the Alliance of Automobile Manufacturers, which spent $16,320,000 on lobbying for 2017 and 2018. Although Ford began to disclose its memberships in these organizations in 2019, it does not comprehensively disclose its memberships in, or payments to, trade associations, or the amounts used for lobbying. Though undisclosed, Ford also belongs to the Business Roundtable, which is lobbying to limit the ability of shareholders to file resolutions. 

Ford’s lack of comprehensive disclosure presents reputational risks when its lobbying contradicts company public positions. For example, Ford claims it supports the Paris climate agreement and while Ford has commendably announced it is pursuing a voluntary framework with the State of California for a fuel economy/GHG program, a 2019 InfluenceMap report identified Ford among the strongest opponents lobbying to undermine the Agreement.[1] As shareholders, we believe that companies should ensure there is alignment between their own positions and their lobbying, including through trade associations.

Investors participating in the Climate Action 100+ representing $34 trillion in assets are asking companies to align their lobbying with the goals of the Paris Agreement. Ford uses the Global Reporting Initiative (GRI) for sustainability reporting yet fails to report “any differences between its lobbying positions and any stated policies, goals, or other public positions” under GRI Standard 415

[1] https://www.theguardian.com/environment/2019/oct/10/exclusive-carmakers-opponents-climate-action-us-europe-emissions