Organization: Franklin Resources Inc.

Year: 2018

Description:  
Whereas, we believe in full disclosure of our company’s direct and indirect lobbying activities and expenditures to assess whether Franklin Resources’s lobbying is consistent with Franklin Resources’s expressed goals and in the best interests of stockholders.
 
Resolved, the stockholders of Franklin Resources, Inc. (“Franklin Resources”) 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 Franklin Resources 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. Franklin Resources’s 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 section 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 Franklin Resources 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 Audit Committee or other relevant oversight committees and posted on Franklin Resources’s website. 
 
Supporting Statement
 
As stockholders, we encourage transparency and accountability in our company’s use of corporate funds to influence legislation and regulation, both directly and indirectly. Franklin Resources spent $1,210,000 in 2016 on federal lobbying (opensecrets.org). This figure does not include lobbying expenditures to influence legislation in states, where Franklin Resources also lobbies but disclosure is uneven or absent. For example, Franklin Resources spent $237,228 lobbying in California for 2015 and 2016. Franklin Resources’s lobbying over debt repayment in Puerto Rico has attracted media attention (“Washington Holds Key for Puerto Rico Bondholders,” Pensions & Investments, April 4, 2016).
 
Franklin Resources is a member of the American Benefits Council and the Investment Company Institute, which together spent over $12.3 million on lobbying in 2015 and 2016. Franklin Resources does not comprehensively disclose its memberships in, or payments to, trade associations, nor the amounts used for lobbying. Transparent reporting would reveal whether company assets are being used for objectives contrary to Franklin Resources’s long-term interests.
 
We urge support for this proposal.