Subject: File No. 4-637
From: Chris Shaffer

April 24, 2013

I'd like to express support for Petition 4-637: Petition to require public companies to disclose to shareholders the use of corporate resources for political activities.

One of the main arguments that corporate political spending is protected as free speech is predicated upon the fact that a corporation is acting on the behalf of its shareholders. Those shareholders have a right to determine for themselves whether political speech is or is not on their behalf.

As to the argument the Chamber of Commerce makes that "the funds expended by publicly traded companies for political and trade association engagement are immaterial to the company’s bottom line" ...

Elections, and the rules that elected leaders and their appointees make, certainly have an impact on companies' bottom lines - that's why companies spend money to lobby or support particular politicians in the first place - because they think that certain policies will be better for their bottom lines. This argument is completely paradoxical and self-contradictory: "Political speech is irrelevant to a company's bottom line. Also, restricting political speech would be bad for companies' bottom lines."

Even if you were to grant that it's immaterial to earnings, institutional and individual investors frequently make investing decisions based on things immaterial to the bottom line (ex: environmental impact, labor practices, etc.). Let the shareholders decide what uses of their money are and are not appropriate or relevant.

- Chris Shaffer