RESOLVED: Shareholders of CenturyLink 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 CenturyLink 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. CenturyLink’s membership in and payments to any tax-exempt organization that writes and endorses model legislation.
4. Description of management’s decision-making process and the Board’s oversight for making payments described in sections 2 and 3 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 CenturyLink 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 CenturyLink’s website.

Supporting Statement: We believe in full disclosure of CenturyLink’s direct and indirect lobbying activities and expenditures to assess whether CenturyLink’s lobbying is consistent with its expressed goals and in shareholders’ best interests. CenturyLink spent $26,430,486 between 2010 and 2018 on federal lobbying.[i] This does not include lobbying expenditures to influence legislation in states where disclosure is uneven or absent. CenturyLink has reportedly lobbied in at least 38 states.[ii]

CenturyLink does not comprehensively disclose its memberships in trade associations nor the amounts of its payments to these trade associations that are used for lobbying. For example, CenturyLink has disclosed $1.4 million in 2019 dues for the USTelecom Association, but did not disclose the portion of these payments that were allocated to non-deductible lobbying and political expenditures.[iii] USTelecom spent $44 million on federal lobbying from 2010 – 2018.[iv]

We are also concerned that CenturyLink’s memberships in and payments to tax-exempt organizations that write and endorse model legislation can also present reputational risks. For example, CenturyLink has participated in the American Legislative Exchange Council (“ALEC”).[v] Over 110 companies have left ALEC following controversies, including Centurylink’s industry competitors AT&T, Sprint, T-Mobile and Verizon.[vi]

For these reasons, we urge you to vote FOR this proposal.

[i] https://www.opensecrets.org/federal-lobbying/clients/summary?id=D000024683

[ii] https://publicintegrity.org/state-politics/here-are-the-interests-lobbying-in-every-statehouse/

[iii]https://www.centurylink.com/asset/aboutus/downloads/regulatory/CenturyLink%20Contribution%20Report%20January%201%20through%20June%2030%202019%20-%20FINAL...pdf

[iv] https://www.opensecrets.org/federal-lobbying/clients/summary?cycle=2005&id=D000000456

[v] https://documented.net/2018/03/revealed-names-alec-lobbyist-legislator-members/

[vi] https://www.prwatch.org/news/2018/11/13428/att-drops-alec-hosting-hate-speech