May 28, 2013

UCF is the co-leader on a dialog with Corrections Corporation of America regarding political lobbying. Along with the Capuchin Order, another Interfaith Center on Corporate Responsibility (ICCR) member, UCF filed a shareholder resolution asking the company for the following disclosures:

1. Company policy and procedures governing lobbying, both direct and indirect, and grassroots lobbying communications 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 CCA is a member..

2. Payments by CCA 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. CCA’s membership in and payments to any tax-exempt organization that writes and endorses model legislation.

4. Description of the decision making process and oversight by management and the Board for making payments described in section 2 above

After the resolution was filed, UCF and the Capuchins had several conversations with management. After the company agreed to disclose publicly much of the information requested, we withdrew the resolution. (Conversations with the company regarding human rights and the treatment of prisoners are ongoing through another group of ICCR investors.)

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