While there has been no additional formal legislative action on the Shareholder Protection Act of 201121 since it was referred to House Financial Services Subcommittee on Capital Markets and Government Sponsored Enterprises in August 2011, disclosure of political contributions by publiclytraded companies continues to attract attention. The Center for Political Accountability and the Zicklin Center for Business Ethics Research recently published their Index of Corporate Political Accountability and Disclosure.22 The Index focused on the largest US publicly-traded companies and concluded that voluntary disclosure of political spending is becoming mainstream and a growing number of companies are putting restrictions on their political expenditures.23 In addition, the California Public Employees’ Retirement System (CalPERS) and the California State Teachers’ Retirement System recently adopted standards calling for companies to disclose their political expenditures.24
Given the continuing pressure for disclosure of political contributions, publicly-traded companies, and in particular large publicly-traded companies, should carefully consider whether they should take steps now to be in a position to provide disclosure regarding political contributions if disclosure becomes necessary as a result of regulatory changes or pressure from shareholders.
