Lobbying Expenditures Disclosure

2018 – Dicks Sporting Goods Inc



WHEREAS, we believe in full disclosure of our company’s direct and indirect lobbying activities and expenditures to assess whether Dick’s Sporting Goods’ lobbying is consistent with the Company’s expressed goals and in the best interests of shareowners.


RESOLVED, the shareowners of Dick’s Sporting Goods (“Dick’s”) 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 Dick’s 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. Dick’s Sporting Goods’ membership in and payments to any tax-exempt organization that writes and endorses model legislation. 


4. Description of management’s and the Board’s decision-making process and 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 Dick’s Sporting Goods 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 Corporate Governance and Responsibility Committee and posted on Dick’s Sporting Goods’ website.  


Supporting Statement: As shareowners, we encourage transparency and accountability in our company’s use of corporate funds to influence legislation and regulation. Dick’s Sporting Goods spent $120 thousand in 2016 on federal lobbying. This figure does not include lobbying expenditures to influence legislation in states, where Dick’s also lobbies but disclosure is uneven or absent.   


Dick’s serves on the board of the National Retail Federation, which has spent over $38 million on lobbying since 2010, and is also a member of the Sports & Fitness Industry Association, formerly the Sporting Goods Manufacturers Association, which has spent more than $1 million on federal lobbying since 2015. Dick’s Sporting Goods does not disclose its memberships in, or payments to, trade associations, e.g. National Shooting Sports Foundation, or the amounts used for lobbying. And Dick’s Sporting Goods does not disclose its membership in or contributions to tax-exempt organizations that write and endorse model legislation, such as the American Legislative Exchange Council (ALEC). More than 100 companies have publicly left ALEC, including 3M, Deere, GE and Wal-Mart. 


We are concerned that Dick’s lack of lobbying and trade association disclosure presents reputational risks. For example, Dick’s lobbying on firearms has drawn media scrutiny (“Pro-gun Interests Hire New Lobbyists,” Sunlight Foundation, February 25, 2013). Absent a system of accountability, company assets could be used for objectives contrary to Dick’s Sporting Goods’ long-term interests.