The SEC has just issued an important post-Citizens United no-action letter that will enhance the ability of shareholders to have more of a voice when publicly-traded corporations spend money on politics. In doing so, the SEC recognized that shareholder accountability over corporate political spending is a significant policy issue that can’t be barred from a proxy statement under the ordinary business exclusion.
- the company's policies on electioneering contributions,
- any specific expenditures for electioneering communications known to be anticipated during the forthcoming fiscal year,
- the total amount of such anticipated expenditures,
- a list of electioneering expenditures made in the prior fiscal year, and
- providing an advisory shareholder vote on those policies and future plans.