Whether it’s what the founding framers envisioned or not, public corporations are a dominant source of political funding today. The 2024 CPA-Zicklin Index of Corporate Political Disclosure and Accountability is the only measure of electoral spending transparency and accountability among the country’s largest public corporations.

Issued annually, it’s produced by the Center for Political Accountability in conjunction with the Zicklin Center for Governance & Business Ethics at The Wharton School at the University of Pennsylvania.

Based on information posted by companies on their websites, the Index measures performance in three areas: disclosure, company political spending decision-making policies, and board oversight and accountability policies.

View the 2024 CPA-Zicklin Index here. The raw data used to compile this report is available here.

How to Get a Perfect Score

Using 24 metrics, or “indicators,” the CPA-Zicklin Index assesses companies’ disclosure practices and spending and accountability policies for spending with corporate or treasury funds to influence elections. It does not address company spending on lobbying or company political action committees. The ideal election-related spending policy explains:

• The company’s process for making contributions or expenditures to influence political and/or ballot measure elections
• How management and the board oversee such decisions
• The public policy considerations that influence such decisions

Below, please find sample disclosure report as well as model policy language from some of the top-scoring companies on the Index. (For more guidance on how the Index is scored, please see the Index Scoring Guidelines.)

Note: Indicators 1-7 concern the company’s disclosure report. View CPA’s Model Election-Related Spending Disclosure Report.

#1 Does the company publicly disclose corporate contributions to political candidates, parties and committees, including recipient names and amounts given?

#2 Does the company publicly disclose payments to 527 groups, such as governors associations and super PACs, including recipient names and amounts given?

#3 Does the company publicly disclose independent political expenditures made in direct support of or opposition to a campaign, including recipient names and amounts given?

#4 Does the company publicly disclose payments to trade associations that the recipient organization may use for political purposes?

#5 Does the company publicly disclose payments to other tax-exempt organizations, such as 501(c)(4)s, that the recipient may use for political purposes?

#6 Does the company publicly disclose a list of the amounts and recipients of payments made by trade associations or other tax exempt organizations of which the company is either a member or donor?

• Consolidated Edison: “In addition to lobbying, some industry groups and trade associations use a portion of Con Edison’s membership dues for election-related purposes. Con Edison is working to obtain this information and will post it to our Political Engagement site if it becomes available.”

#7 Does the company publicly disclose payments made to influence the outcome of ballot measures, including recipient names and amounts given?

#8 Does the company publicly disclose the company’s senior managers (by position/title of the individuals involved) who have final authority over the company’s political spending decisions?

• Ecolab Inc.: “No corporate funds, assets or anything of value may be paid or furnished, directly or indirectly, to a political party, political candidate or incumbent, political action committee, or in support of “soft money” contributions or “issue advocacy” except if legally permissible and if approved in advance in writing by the: Chief Executive Officer; Chief Financial Officer General Counsel.”

#9 Does the company publicly disclose an archive of each political expenditure report, including all direct and/or indirect contributions, for each year since the company began disclosing the information (or at least for the past five years)?

• AT&T: “A centralized location for easy access to current and historical reports that detail the scope of our efforts.”

#10 Does the company disclose a detailed policy governing its political expenditures from corporate funds?

• MSCI: A link to the MSCI 2021 Political Activities Policy Statement

#11 Does the company have a publicly available policy permitting political contributions only through voluntary employee-funded PAC contributions?

• For research purposes only, not scored.

#12 Does the company have a publicly available policy stating that all of its contributions will promote the interests of the company and will be made without regard for the private political preferences of executives?

• Northrop Grumman Corporation: All political activities, including financial contributions, are made in support of company objectives. They are not based on the personal preferences of individual employees, executives, or board members.

#13 Does the company publicly describe the types of entities considered to be proper recipients of the company’s political spending?

• Boeing Co.: “Since 2010, the Company has not made any contributions from corporate funds to state or local candidates or political parties. Also, Boeing has not expended any corporate funds since 2011 in support of or opposition to ballot initiatives, or since 2012 for political contributions to section 527 entities.”

#14 Does the company publicly describe its public policy positions that become the basis for its spending decisions with corporate funds?

• Home Depot, Inc.: “In deciding where we want to focus our advocacy, there are some of our top priorities (2022 ESG Report): Driving sales by ensuring online-only marketplaces follow the same rules on accountability and transparency as interconnected retailers; Supporting our Supply Chain initiative by advocating for funding for roads, ports and bridges and for laws that allow safer, heavier trucks to reduce loads and our environmental footprint; Growing margin dollars by working to get laws passed that target sophisticated, organized retail crime rings to reduce theft and support free trade; Taking care of our people by making sure we have a say in laws that could affect associate flexibility and career growth.”

#15 Does the company have a public policy requiring senior managers to oversee and have final authority over all of the company’s political spending?

• Netflix Inc.: “Our Public Policy team, which reports directly to our Chief Legal Officer, oversees regulatory matters and government affairs, including our direct and indirect advocacy and political contributions in the United States at the federal, state and local levels.”

#16 Does the company have a publicly available policy that the board of directors regularly oversees the company’s corporate political activity?

• Sempra: “The Corporate Governance Committee of our Board of Directors reviews Sempra’s public policy priorities on an annual basis. This committee also reviews the political contributions made during the prior year. While our Board provides oversight, Sempra’s senior vice president, Corporate Affairs, is responsible for the activities, positions and daily decision-making consistent with this oversight.”

#17 Does the company have a specified board committee that reviews the company’s policy on political expenditures?

• Coca-Cola Co.: “The Committee shall review the Company’s public policy advocacy efforts, including all political contributions, to ensure alignment with Company policy and our overall values. This review will occur at least annually.”

#18 Does the company have a specified board committee that reviews the company’s political expenditures made with corporate funds?

• Costco Wholesale Corp.: “The Nominating and Governance Committee of the Board of Directors, which is comprised exclusively of independent directors, reviews the Company’s spending on politics and advocacy.”

#19 Does the company have a specified board committee that reviews the company’s payments to trade associations and other tax-exempt organizations that may be used for political purposes?

• Qualcomm: “The Governance Committee of the Company’s Board of Directors, which consists solely of independent directors, shall be responsible for overseeing the Company’s political activity and contributions, including Political Expenditures to trade associations or other organizations, to ensure consistency with the Company’s business objectives and public policy priorities.”

#20 Does the company have a specified board committee that approves political expenditures from corporate funds?

• General Motors: “The Committee (Governance and Corporate Responsibility Committee) receives regular reports regarding GM’s policy priorities and reviews the company’s political engagement strategy, including political contributions and lobbying expenditures made during the past year, and previews the framework for the coming year. During this review, the Board can seek adjustments to the framework.”

#21 Does the company have a specified board committee, composed entirely of outside directors, that oversees its political activity?

• McKesson Corp.: “The Committee shall consist of three or more directors each of whom has been determined, in the business judgment of the Board, to qualify as an independent director.”

#22 Does the company post on its website a detailed report of its political spending with corporate funds semiannually?

#23 Does the company make available a dedicated political disclosure web page found through search or accessible within three mouse-clicks from homepage?

#24 Does the company disclose an internal process for or an affirmative statement on ensuring compliance with its political spending policy?

• Intel Corp.: Intel’s Global Public Affairs and Global Government Affairs teams analyze Intel’s corporate and IPAC political contributions regularly to ensure contributions made during the year are consistent with these Guidelines.

For inquiries regarding the CPA-Zicklin Index, please contact Dan Carroll, CPA’s VP for Programs and Counsel.

Companies that Prohibit All Corporate-Treasury Funded Election-Related Spending

In the 2022 Index, twenty companies in the S&P 500 earned the distinction as companies that fully prohibit treasury-funded election-related spending.

A company may accomplish this by posting on its website a policy that clearly prohibits each of the six types of election-related spending covered in the Index (Indicators 1-5 and 7). Additionally, such a policy does not necessarily preclude membership in trade associations or support for 501(c)(4) organizations; companies may restrict the use of their trade association dues and payments and payments to 501(c)(4) organizations to non-election related purposes without terminating membership or participation with such organizations. Thirty-nine companies in the 2022 Index prohibited or restricted payments to both trade associations and 501(c)(4) groups.

For examples of policies prohibiting all corporate-treasury funded election-related spending please view the publicly available policies posted by IBM, Ulta Beauty Inc., and United Rentals.

The 2022 Index provides further information on distinguishing organizations that engage in political activities as well as definitions and explanations for direct and indirect spending.

Companies seeking further information should contact CPA’s Vice-President for Programs and Counsel.