22 Aug 2025 Financial Architecture of Anti-DEI Shareholder Activism

Introduction

Since the murder of George Floyd and the rise of the Black-lives-matter movement in 2020, the US has witnessed the uptake of DEI policies, DEI-linked executive pay compensation plans and increased affirmative action recruiting in large companies such as Microsoft, Apple, and Costco. Pressure has been rising not only from consumers, but also from investors, with activist investors increasingly entering the scene and filing proposals for increased DEI and ESG compliance with the SEC in the years since 2020. Conservative interest groups have long rallied against this behaviour, demanding that the market knows best and denouncing (green) shareholder activism as an unfair tactic that goes against the company’s duty to its shareholders’ best interests.

Over time, the initial opposition faded and a new strategy emerged, with groups such as the NLPC and NCPPR beginning to file their own proposals with the SEC in recent years. The themes of the proposals range from anti-abortion at Eli Lilly in 2023 to anti-electric cars at General Motors in 2025, often citing scepticism toward mainstream climate science and a commitment Christian conservative values.

Mr. Trump’s return to office in 2025 started his task of swiftly taking apart the DEI infrastructure in the US, capitalising on a growing public resistance to DEI topics. Public support for DEI dropped from 56% to 52% among working US adults between 2023 and 2024 alone. While the second Trump administration passed a stack of executive orders retiring affirmative action in public college admissions and requiring DEI programs to be cancelled in federal contractors’ operations, the SEC received an influx of anti DEI shareholder proposals, further adding pressure to public companies to align with the Trump government’s anti-DEI perspective.

When looking at who filed the proposals with the SEC on anti-DEI topics, a few names show up again and again: the American Family Association (AFA), the National Center for Policy and Public Research (NCPPR) and the National Legal Policy Center (NLPC). There are other significant players that this analysis excludes for the time being, sacrificing some breadth for depth of analysis, and focussing on these three key players.

Background

This analysis looks at the publicly available information on funding sources for the AFA, NCPPR and NLPC, as all of them are donor-financed 501(c)(3) charitable organisations . The research shows a web of private foundations giving to donor-advised funds, who then pass the money on to organisations of the donor’s choosing such as the AFA or NCPPR. This grants the donor, oftentimes charitable organisations themselves, anonymity and tax deductible spending, while protecting them from any backlash connected to their spending that could potentially threaten their status as a 501(c)(3). This practice of anonymised giving through Donor-advised Funds leads to millions of dollars moving behind the scenes, and opens the question whether these organisations filing proposals with the SEC, as well as the organisations backing them, can be considered as politically neutral, tax-exempt charitable organisations, adhering to the limits placed on their political lobbying activities, as their 501(c)(3) status suggests.

To understand what is happening in this jungle of transactions, let’s clear some terms:

Charitable organisations denoted as 501(c)(3) are entities that are organized and operated exclusively for religious, charitable, scientific, literary or educational purposes, for testing for public safety, to foster national or international amateur sports competition, or for the prevention of cruelty to children or animals. Status as a 501(c)(3) allows donors to make tax-deductible donations and makes it exempt from income tax. A 503(c)(3) organisation (such as the AFA, NCPPR and NLPC) is  subject to limits on political lobbying. The law states that “no substantial part” of a public charity’s activities can go to lobbying. Charities with large budgets may lawfully expend a million dollars (under the “expenditure” test) or more (under the “substantial part” test) per year on lobbying. There is no law defining precisely what a “substantial part” constitutes in i.e. percent of income (Wikipedia contributors, 2025a). 501(c)(3) organisations are required to publish financial statements once a year to retain their status. Therefore, the financial statements of AFA, NCPPR and NLPC are currently publicly available online for the financial years up to 2023. All three have filed multiple proposals with the SEC on anti-DEI issues in recent years.

A donor-advised fund (DAF) is like a charity-focussed bank account that individual donors have. It allows donors to deposit cash or other securities in the DAF, surrendering ownership and enjoying immediate tax benefits, while retaining advisory benefits on how to disburse the funds in the DAF over time. In the words of environmental sociologist Robert Brulle at Drexel University: “This process ensures that the intent of the contributor is met while also hiding that contributor’s identity. Because contributions to a donor directed foundation are not required to be made public, their existence provides a way for individuals or corporations to make anonymous contributions” (Wikipedia contributors, 2024).

This dynamic points to a regulatory blind spot in U.S. non-profit and tax law, where donor-advised funds are not required to disclose the source of donations or the conditions attached to them. These findings also raise the broader question of whether current definitions of “lobbying” and “substantial part” activity for 501(c)(3) organizations adequately capture modern forms of indirect political influence, such as coordinated shareholder activism.

AFA

Let’s start looking at how this all comes together in the American Family Association (AFA).

AFA is a conservative Christian foundation, describing its mission as “to inform, equip, and activate individuals and families to transform American culture and to give aid to the church, here and abroad, in its calling to fulfill the Great Commission^[1]. “ (American Family Association, no date a).

They host American Family Radio (AFR), a network of 200 owned radio stations (American Family Radio, no date), publish news, organise a Bible Course, and host a resource center on their website (American Family Association, no date c). AFA runs an online shop where supporters can buy anything from ‘he lives’ mugs to a pocket-constitution or a bible. They also sell posters, stickers, buttons, and other merchandise with Christian messaging as well as Christian books and booklets.  AFA is a member of ECFA (financial disclosure for Christian organisations) (ECFA, no date) and has a history of organising boycotts and letter-writing campaigns for Christian values and anti-LGBTQ issues. For example, they have boycotted Target Corporation (Target) since 2016 for trans-inclusive statements, and have just finished the boycott this year when Target dropped their DEI policy (American Family Association, 2025). AFA is also among the organisations involved in Project 2025 (Rahman, 2024). Furthermore, AFA spokespeople repeatedly made statements that are anti-semitist, racist, islamophobic, and anti-LGBTQ (Southern Poverty Law Center, 2025).

AFA has filed a host of proposals with the Securities and Exchange Commission (SEC) in recent years on topic against DEI. For example, AFA filed a proposal against Amazon Inc. on 24 May 2023 (PRI, no date) on the topic of discrimination. The proposal demanded a report from Amazon.Inc “evaluating how it oversees risks related to denying or restricting service to users or customers based on their viewpoint under “hate speech,” “misinformation,” and related policies, other terms of use or content management policies, or any other policies or practices, and how such viewpoint discrimination impacts users, customers, and other individuals’ exercise of their constitutionally protected civil rights” (PRI, no date). AFA filed another proposal with the SEC against the Bank of New York (BNY) on 14 November 2024 (Securities and Exchange Commission, 2024b),  (S&P Capital IQ, 2024), “asking the Company to conduct an evaluation and issue a report within the next year […] evaluating how it oversees risks related to discrimination against individuals based on their race, color, religion, sex, national origin, or political views, and whether such discrimination may impact individuals?” (S&P Capital IQ, 2024). AFA also filed a proposal against Verizon Communications Inc. on January 3, 2025 (Securities and Exchange Commission, 2025h), asking for a report “evaluating how it oversees risks related to discrimination against ad buyers and sellers based on their political or religious status or views” and another one against Deere & Company on January 10, 2025 (S&P Capital IQ, 2025a), requesting again “an analysis of how Company’s contributions impact its risks related to discrimination against individuals based on their speech or religious exercise (S&P Capital IQ, 2025a)”.

Filing these proposals doesn’t come cheap. According to the SEC Exchange Act Rule 14a-8 there are threshold requirements such as owning: USD$2,000 of the company’s stock for at least three years; USD$15,000 of the company’s stock for at least two years; or  USD$25,000 of the company’s stock for at least one year. On top, there are thousands of dollars in legal fees and time and money spent building relevant networks (McGuire, no date).

To understand how the AFA then was able to file multiple proposals within the last three years warrants a look at their funding sources. To retain status as a 501(c)(3) charitable organisation, AFA is required to publish financial statements once a year. The latest financial statement from 2024, covering the fiscal year 2023, stated 19.442.658 dollars in income through donations. There is no complete breakdown of funding sources available, but it is public that 11.9781 were given to AFA in 2023 by the Fidelity Investment Charitable Gift Fund. Remember the name- it will repeat itself as a donor to NCPPR, who also filed anti-DEI proposals in recent years.

Fidelity Investment Charitable Gift Fund is a 501(c)(3) organisation and was the first provider of donor-advised funds (DAFs) in the US, starting in 1991. It was also the largest public charity in the US in 2019. Some observers have raised concerns that private companies and family foundations may be using the Fidelity Investment DAF to anonymously fund organisations such as AFA, which have publicly advocated for the reduction or removal of DEI practices in corporations.

So let’s look at the money going into the Fidelity Investment Charitable Gift Fund, to better understand who might be behind the money given to AFA.

Fidelity Investment Charitable Gift Fund was supported by the Silicon Valley Community Foundation (SVCF) with $153,756,594 in December 2023 and $153,756,594 in July 2025 (CauseIQ, no date d). Together, these donations make up more than 300 Million Dollars. It received a notable contribution from DAFgiving360 with $127,700,997 in June 2024 (CauseIQ, no date d), and was funded by the Morgan Stanley Global Impact Funding Trust with another 120 Million dollars- $120,240,875 exactly, in December 2023 (CauseIQ, no date d). Furthermore, Fidelity Investment Charitable Fund received $48,895,763 from the American Endowment Foundation in November 2024. The American Endowment Foundation, equally a 501(c)(3) donor-advised fund charitable organisation, already gave money to the AFA directly with 95.428 dollars in 2023 and 91.667 dollars in 2025 (CauseIQ, no date d).

Looking at the money trail of donations, it becomes clear that financials flow not just in one direction. For example, Fidelity Investment received $6,887,478 from BNY Mellon Charitable Gift Fund in August 2024 (CauseIQ, no date d) and BNY Mellon again received a 2 million dollar contribution from Fidelity investments in June 2023 (CauseIQ, no date b). BNY Mellon also received $932,176 from the National Philanthropic Trust in June 2023 (CauseIQ, no date b), another conservative charitable organisation.

This flow chart below details the known transactions towards public-facing, proposal-writing AFA, NCPPR and NLPC, and sketches the network of donor-advised funds and family trusts behind the spending. It can be referred to in the course of this article as a visual guide for processes described. Every transaction mentioned in the flow chart has a corresponding in-text source provided. Transactional values are given in Million US dollars. As a starting point, there is the transaction of 0.12 million given by Fidelity Investment Charitable Gift Fund to AFA in 2023.

Figure 1: Flow Chart (no source, based on the research in this paper)

Arrows in red show transactions above one million US dollars. The second flow chart below focuses on these transactions with a large volume.

As this image makes visible, many of the largest recorded transactions appear to originate from companies and family foundations and flow into DAFs, which then direct funds onward—either to other DAFs or to organizations such as AFA, NCPPR, and NLPC. While exact connections between inflows and outflows cannot be confirmed, this illustrates the potential scope of financial movement within the network . Please remember that this is not a comprehensive chart as most information on donors and volume of donation are not public. Please also remember that it is not possible to connect inflows and outflows of money through DAFs- their function is exactly to obscure the origin of the funds that beneficiaries of DAFs, such as the AFA receive. This is indicative of the known transactions, but there are many more, as charitable organisations with the 501(c)(3) status are generally not required to disclose individual donors.

Fig. 2 – Flow chart focus on the higher amount of money

Another such DAF, already touched upon above, is the American Endowment Foundation (AEF). To recapitulate, the AEF gave 95.428 dollars in 2023 and 91.667 dollars in 2025 to AFA (CauseIQ, no date d). The AEF is a charitable foundation, considered a 501(c)(3), putting limits on its scope for lobbying, as described above in “background”. The AEF controls a lot of money; In 2023, total assets were $7,145,882,316 and total giving was $1,229,386,619 (Instrumentl, no date). AEF is one of the 20 largest donor-advised fund providers in the United States (Influence Watch, 2024). In terms of other notable publicly available donations, AEF gave $5,100,906 for the National Philanthropic Trust in 2020 (Influence Watch, 2024), and gave $62,900 for the Heritage Foundation in 2020 (Influence Watch, 2024), both players whose names will be repeated later in this text, and can be found in the flow chart above for illustrative purposes.

Other donors to the AFA included $ 100.00 from the  Co Tua John F. Cuneo Jr. Fund (CauseIQ, no date a), $5,000 from the Odell Foundation on May 2025 (CauseIQ, no date a), and support from Christian  foundations: $11,337 from the Christian Community Foundation of Memphis and the Mid-South on May 2024 (CauseIQ, no date a), $80,000 from the John Calvin Bible Foundation on August 2024 (CauseIQ, no date a) and $352,328 from the National Christian Foundation (Natl Christian Charitable FDN Inc.) on March 2025 (CauseIQ, no date a). The AFA is not a donor-controlled fund, so the control of the donated money depends on the existence or absence of individual agreements tying the contribution to a cause between, for example, the Christian foundations and the AFA.

Moving on, the next focus will be on the NCPPR, already introduced as the recipient of funding from the Fidelity Charitable Gift Fund.

NCPPR

The National Center for Public Policy Research (NCPPR) is a self-described non-partisan, free-market, independent conservative think tank, their mission declared as “grow the freedom movement by taking our message to new constituencies to secure liberty now and for future generations.”(The National Center, 2025). It advertises its significant projects: the Project 21 black leadership network, the Free Enterprise Project, Able Americans and the Environment and Enterprise Institute.

The NCPPR is a former member of the global warming denial organization Cooler Heads Coalition, under the affiliation of which they received funding from other members (Cooler Heads Coalition – Climate Investigations Center, no date). The organisation also hosts a global warming denial website called envirotruth.org (Envirotruth, no date). Other affiliations include their status as former Associate Member of State Policy Network (SPN) (SourceWatch, 2023), and the NCPPR is a member of the advisory board of Project 2025 (Rahman, 2024), like the AFA. NCPPR’s Back to Neutral Coalition, which includes the American Legislative Exchange Council (ALEC), a conservative organisation that proposes draft legislation to state lawmakers across the country with the goal to enact pro-corporate legislation. ALEC chief executive Lisa Nelson is a member of the NCPPR board (Broad, 2023).

 The abovementioned Project 21, a “national leadership network of black conservatives” Since 1992 (Wikiwand, no date), is partly funded by the Bradley Foundation, which has bankrolled studies devoted to the supposed genetic intellectual inferiority of blacks (Schwarz, 2016). Lastly, the NCPPR hosts the campaign “Stop Corporate Tyranny”, which accuses corporations of allowing themselves to be weaponized against “traditional American values” and silencing conservative perspectives (NCPPR, 2023).

The NCPPR is a relevant player in the field of shareholder proposals filed. They have been engaged, together with the NLPC, for years in pushing anti-ESG proposals, and have now picked up increasingly on DEI topics, even as success rates remain low. Many proposals do not even reach a vote and are omitted with approval from the SEC. For example, the NCPPR filed a proposal with the SEC against KrogerCo., a grocery chain, in 2023, which was omitted. (Broad, 2023), (Vinson & Elkins LLP, 2024). The proposal requested a report “detailing the potential risks associated with omitting “viewpoint” and “ideology” from its equal employment opportunity policy.” (Vinson & Elkins LLP, 2024). NCPPR filed a proposal against Home Depot in 2023 (Broad, 2023), (Securities and Exchange Commission, 2023b), “to rescind the 2022 Racial Equity Audit proposal and reject any racially discriminatory practices at the company.” (Securities and Exchange Commission, 2023b), and another proposal specifically naming DEI in 2023 against AT&T (Broad, 2023), (Securities and Exchange Commission, 2024a), requesting a report on “how the Company’s DEI requirements for contractors impacts AT&T’s risks related to discrimination against individuals based on their race, color, religion (including religious views), sex, national origin, or political views. “ (Securities and Exchange Commission, 2024a). The next proposal was filed against Berkshire Hathaway in spring 2025 (Darley, 2025),  (Securities and Exchange Commission, 2025c), which requests “ that the Board of Directors oversee an independent racial discrimination audit analysing Berkshire’s legal and reputational risks stemming from its subsidiaries’ race-based initiatives. “ (Securities and Exchange Commission, 2025c), and the following proposal also in Spring 2025 against JP Morgan Chase (Darley, 2025), (Securities and Exchange Commission, 2025e), to “request that the Company consider abolishing its DEI program, policies, department and goals.” (Securities and Exchange Commission, 2025e). The last proposal by the NCPPR on DEI topics mentioned in this non-exhaustive list is against Apple in Spring 2025 (Darley, 2025), (Johnson, 2025), simply requesting that Apple stop its DEI efforts (Johnson, 2025).

The SEC has limited discretion to reject proposals under Rule 14a-8, but its capacity to assess the political intent behind such filings is constrained. Given the rise of ideologically driven proposals that test the boundaries of corporate governance norms, the role of the SEC in arbitrating these filings may become a focal point of future policy debate.^[2]

The NCPPR is able to afford managing all these proposals in such a short timespan, as its financial records for 2023, filed 2024, show 11.690.949 dollars in donations. In the financial statements filed to retain status as a charitable organisation 501(c)(3) , the yearly income from donations and charitable giving grows from 4 million dollars in 2019, 8 million dollars in 2020, 13 million in 2021, and 12 million again in 2022.

Again there is no individual breakdown of the donations contributing to the financial statement, as it is not required of this legal type of organisation (501(c)(3)). The known transactions provide a glimpse into the types of donors whose interests may align with NCPPR’s shareholder proposal activity. Given the structure of DAFs, it is plausible that donations could originate from parties whose preferences align with these proposals, even if donor identities remain undisclosed.

$417,000 were donated by the influential Donors Capital Fund (DCF) between 2010 and 2020 (SourceWatch, 2024), and $704,221 by the connected Donors Trust (DT) in a similar timespan, between 2010 and 2022 (SourceWatch, 2024). These Funds are both 501(c)(3) organisations, limiting their abilities to do lobbying and granting them tax exemption status. Donor’s Trust  and Donor’s Capital Fund are DAFs, meaning donors retain control of their donation’s recipient, but remain anonymous. Both have a history of bankrolling conservative think tanks, activist groups etc, posing as politically neutral grassroots organisations, but acting with a clear political agenda (SourceWatch, 2023). A former board member is John A. Von Kannon, Vice President at the Heritage Foundation. DT and DCF are deeply entwined with the money of the Koch Brothers: Charles Koch is the right-wing billionaire owner of Koch Industries. “As one of the richest people in the world, he is a key funder of the right-wing infrastructure, including the American Legislative Exchange Council (ALEC) and the State Policy Network (SPN).” (SourceWatch, 2023). The exact sum remains unclear, but the Koch brothers have funneled large sums into the DC and DTF through the obscure Knowledge and Progress Fund, controlled by Charles Koch, which has given exclusively to DT and DCF since 2005, including $1.25 million in 2007, $1.25 million in 2008, and then $2 million in 2010. What sets DT and DCF apart from giving to other foundations is the fixed spending guidelines it offers. Many givers are concerned that their money will not be spent in their interest after their demise, or with a change in leadership in the managing foundation. DT and DCF promise continuity in their conservative value-based giving: “…if a donor names his child a successor advisor, and she wants to give to Greenpeace, we’re not going to be able to do that.”. The DT and DCF have witnessed their share of scandals and accusations, including having been involved in propping up conservative media centers throughout the US though funding 100% of a charity that then in turn established the media centers. Research has been written on this incident by Abowd (2022). The DT and DCF are also big in funding climate change denial and islamophobia (SourceWatch, 2023).

To put it short, DT and DCF are a way for individuals and organisations to give money to ‘controversial or sensitive issues’ without their name on it (SourceWatch, 2023) through the DAF structure of the charity 501(c)(3) funds. DT has given a lot to the State Policy Network  (SPN), of which Charles Koch was a funder: $10 million between 2008 and 2013 (Abowd, 2022). The DT and DCF combined gave $2,279,100 to State Policy Network in 2019 alone (SourceWatch, 2023). Looking the other direction, throughout 2016, DonorsTrust received $3,249,292 from the Lynde and Harry Bradley Foundation (SourceWatch, 2023), which have also given more than 2 million dollars between 2019 and 2023 directly to the NCPPR.

The DT and DCF combined gave $416,718 to the Heritage Foundation in 2019 (SourceWatch, 2023). Money also moved sideways, from DAF to DAF, as the DCF gave $265,000 to the Fidelity Charitable Foundation in 2019 (SourceWatch, 2023). The NCPPR then also received a donation directly from Fidelity Charitable Gift Foundation in June 2023 of $282,050 (CauseIQ, no date f)

Back to the funding sources of NCPPR directly, $550,000 came from the Sarah Scaife Foundation in 2012-2022 (SourceWatch, 2024). Sarah Scaife Foundation is a 501(c)(3) tax-exempt charitable foundation controlled by her son Richard Mellon Scaife, who is heir to the Mellon banking, oil and aluminum fortune. He is the premier financier for right-wing political and policy organizations in the United States. The Mellon family also owns Gulf Oil (SourceWatch, 2018b). He describes his funding strategy as “Our funding is based on our support of ideas like limited government, individual rights, and a strong defense”. In 2020, Sarah Scaife foundation gave $1.3 million to the Heritage Foundation.

The NCPPR received $600,000  by Diana Davis Spencer Foundation in December 2023, and $600,000 again in January 2025 (CauseIQ, no date f). Diana Davis Spencer Foundation is a 501(c)(3) charitable organisation, and as such tax-exempt and limited in political lobbying. To give some interesting facts about the foundation, four of the Diana Davis Spencer Foundation’s six “external advisors” are employees of Graystone Consulting, a financial consulting branch of Morgan Stanley. Another mention goes to Abby Spencer Moffat who was Chief Executive Officer and President as of 2022 at the NCPPR- she is also a former board member of the Heritage Foundation. (Influence Watch, 2023), (SourceWatch, 2024a). Diana Davis Spencer Foundation donated $5,000,000 to DT and $5,000,000 to the Heritage Foundation in December 2023, and $14,000,000 to Donor’s Trust in 2022, as well as $1,500,000 to the heritage foundation in the same year. In 2021, the Diana Davis Spencer Foundation gave $7,250,000  to Donors Trust, in 2021 and $1,500,000 to the Heritage Foundation. They also gave $11,000,000 to DonorsTrust and $2,000,000 to the heritage foundation, and also in 2020, $100,000 to SPN CauseIQ (no date d).

A large sum was donated from a family foundation over the years, detailing most recently $250,000 by the Lynde and Harry Bradley Foundation in December 2023, specifically to support the free enterprise project (CauseIQ, no date f). The total amounted to $2,220,000 between 2019–2023 (SourceWatch, 2024), including 1,000,000 in 2022 (Armiak, 2023). A few words on Lynde and Harry Bradley Foundation: is a charitable private fund denoted as a 501(c)(3), granting it tax exemption status and limiting its scope for lobbying activities. (Wikipedia contributors, 2025b). Harry Bradley was one of the original charter members of the far right-wing John Birch Society, along with another Birch Society board member, Fred Koch, the father of Koch Industries’ billionaire brothers and owners, Charles and David Koch, which are at the head of DT and DCF (see paragraph above on DT and DCF). The Lynde and Harry Bradley Foundation contributed $2,969,292 to Donors Trust and Donors Capital Fund between 2009 and 2013 (SourceWatch, 2025).

The most recent donation to NCPPR mentioned here is the $2,000 from the Crawford Family Foundation in May 2025(CauseIQ, no date f). This is not an exhaustive list, as there is no transparency requirement for the NCPPR to disclose individual funding sources.

NLPC

The National Legal and Policy Center (NLPC) is the last relevant player in the field of anti-DEI proposals filed with the SEC in this analysis. Similar to the NCPPR, the NLPC has a history of shareholder activism against ESG topics, and is now participating in and initiating anti-DEI motivated proposals. The NLPC has another thing in common with the NCPPR, and that is their status as former associate members of the State Policy Network (SPN), which describes itself as a network and service organization for the “state-based free market think tank movement” (SourceWatch, 2018a). The NLPC sponsors the Corporate Integrity project.

In the project description, they stress corporate responsibility towards shareholder interest, reducing the bad effects of government intervention in markets, and “Combating practices that undermine the free enterprise system, including corporate giving to groups hostile to a free economy” (NLPC Staff, 2025b).

The NLPC was very active this year in filing proposals with the Securities and Exchange commission against the DEI topics. The first in took place against PepsiCo in January 2025 (NLPC Staff, 2025a), (Darley, 2025), (Spector, 2025), “calling for the company to stop including representation metrics in executive pay.” (Spector, 2025). It was followed by a proposal against Mastercard in spring 2025 (NLPC Staff, 2025a), (Darley, 2025), (Securities and Exchange Commission, 2025d), with a request to “the Board of Directors’ Human Resources and Compensation Committee to consider eliminating discriminatory DEI and ESG goals from compensation inducements.” (Securities and Exchange Commission, 2025d), and another one in Spring 2025 against coca cola (Chesser, 2025), (Darley, 2025), (Securities and Exchange Commission, 2025g), asking “that the board of directors’ Talent and Compensation Committee revisit its incentive guidelines for executive pay to identify and consider eliminating discriminatory DEI goals from compensation inducements.” (Securities and Exchange Commission, 2025g). The NLPC filed a proposal against Starbucks on March 12th, 2025 (Chesser, 2025), (Securities and Exchange Commission, 2025a), making ““The case for voting FOR Proposal 6 (“Shareholder proposal requesting a report on human rights risks related to labor organizing”) on the 2025 Proxy Ballot” (Securities and Exchange Commission, 2025a). The NLPC kept busy in their anti-DEI efforts, filing a proposal Boeing in Spring 2025 (S&P Capital IQ, 2025b), ““requesting the Company issue a report reviewing the Company’s DEI aspirations, detailing to shareholders the extent of its resources and personnel across its divisions devoted to these aspirations, and analyzing the risks that the Company’s DEI (diversity, equity and inclusion) policies pose to shareholders, including legal liability and a reduced focus on merit, submitted by National Legal and Policy Center at the Company’s annual shareholders meeting scheduled to be held on April 24, 2025.” (S&P Capital IQ, 2025b)”.  Lastly, they moved against financial institutions, with a proposal against Goldman Sachs in Spring 2025 (Refinitiv, 2025), (National Legal and Policy Center, 2024), requesting “the Board of Directors’ Talent and Compensation Committee to revisit its incentive guidelines for executive pay, to identify and consider eliminating discriminatory DEI goals from compensation inducements.” (National Legal and Policy Center, 2024), and a filing against JP Morgan Chase in Spring 2025 (Darley, 2025), stating that the “NCPPR is calling on Goldman to conduct a racial-discrimination audit of its DEI policies.” (Herzlich, 2025).

Considering all these proposals filed within this year, it becomes interesting to address the financials of this charitable 501(c)(3) organisation. According to their legal tax-exempt status, they published their financial statement annually. The most recent statement is from 2024, explaining the financial year 2023, where the NLPC’s income through donations totaled 2.425.319 dollars. Same as the AFA and NCPPR, the NLPC does not disclose details on its income sources. The publicly available information is described below, giving an idea of the donors whose support may help sustain NLPC’s ongoing shareholder engagement activities.

The NLPC received charitable contributions from Family Foundations (501(c)(3)) and donor-advised funds over the years. The Ed Uihlein Family Foundation gave $50,000 in 2020 (Influence Watch, 2025). You might remember the name from the former board member of Lynde and Harry Bradley Foundation, David V. Uihlein, Jr. Ed Uihlein, a major Republican supporter, was the sixth-largest donor to U.S. political campaigns between 2010-18. The New York Times reported in 2020 that Uihlein donated $50 million to political campaigns between 2019-20 (Influence Watch, 2021). The Uhilein foundation also gives to Gunowners of America, a gun lobby group (Influence Watch, 2021).

NLPC also received donations from the Sarah Scaife Foundation, which gave $175,000 in 2020 (Influence Watch, 2025) and $175,000 in 2025 (CauseIQ, no date g). This as well is a familiar name, as the Sarah Scaife Foundation gave $550,000 to the NCPPR between the years 2012 to 2022 (SourceWatch, 2024b). The Carthage Foundationalso gave $125,000 in 2014, $100,000 in 2013 (Influence Watch, 2025). Here it is worth pointing out that the Sarah Scaife Foundation and Carthage Foundation belong to the same person, Richard Mellon Scaife (for more information, see paragraph above on Sarah Scaife Foundation)

DAFgiving360 gave $111,138 to NLPC in June 2024 (CauseIQ, no date g). DAFgiving360 is managing, as the name suggests, a portfolio of donor-advised funds. They received support from another familiar DAF Fund, Fidelity Investments Charitable Fund with a donation of $183,131,878 in June 2023 (CauseIQ, no date c). DAFgiving360 also gave $249,117,686 to the National Philanthropic Trust in June 2024 (CauseIQ, no date c).

 A bit more on the National Philanthropic Trust: There has not been a direct contribution from the National Philanthropic Trust to either the AFA, NLPC or NCPPR, but their name is often under the recipients and donors of organisations that do give money to AFA, NLPC and NCPPR. They have been mentioned before as they received $5,100,906 from the AEF in 2020. The National Philanthropic Trust is funded also by Fidelity investments with $194,975,525 in June 2023 (CauseIQ, no date g) and gave $257,077,976 to the Silicon Valley Foundation in June 2023 (CauseIQ, no date g), who are again funded by Fidelity investment with $15,669,854 in June 2023 (CauseIQ, no date h). The Silicon Valley Foundation gave 10x the amount received back to Fidelity investment in December 2023 ($153,756,594) (CauseIQ, no date h). For more clarity on these transactions, see the flow chart above.

Lastly, Donor’s Trust (DT) donated to NLPC, $68,500 in January 2025 and $68,500 in December 2023 (CauseIQ, no date g). Donor’s Trust has been examined in the paragraph above, as a donor to the SPN, NCPPR, the Heritage Foundation and Fidelity Investments Charitable Giving.

Conclusion

This tentative research of the role of Donor-Advised Funds (DAFs) in facilitating anti-DEI shareholder proposals reveals a complex web of financial transactions that obscure the true sources of support behind conservative, anti-DEI activism targeting large corporations. Key organizations such as the American Family Association (AFA), the National Center for Policy and Public Research (NCPPR), and the National Legal Policy Center (NLPC) file proposals with the SEC and leverage their 501(c)(3) status to keep the sources of funding mostly anonymous, reporting only on overall yearly income. The donors that are known often still retain anonymity through the vehicle of DAFs to hide the identity of the donor behind the DAF while donating money in their interest. This financial structure enables organizations like AFA, NLPC and NCPPR to pursue shareholder proposals challenging DEI initiatives , often aligned with broader political agendas reinforced by influential conservative funders that remain anonymous.

The opaque nature of DAFs allows funnelling substantial sums from wealthy individuals, family foundations, and financial institutions through layers of charitable organizations, anonymously into anti-DEI efforts. This not only challenges the stated political neutrality and charitable obligations inherent in the 501(c)(3) framework of both the frontline players AFA, NLPC and NCPPR as well as the DAF charitable funds behind them, such as DT, DCF and AEF,  but also raises critical questions about transparency and accountability in the intersection of philanthropy, politics, and shareholder activism. This dynamic points to a regulatory blind spot in U.S. non-profit and tax law, where donor-advised funds are not required to disclose the source of donations or the conditions attached to them. ^[3]Unlike Political Action Committees (PACs), DAFs operate in a largely unregulated space^[4] with regard to political influence, raising questions about whether additional disclosure requirements or lobbying definitions are warranted.

In a climate where DEI programs face growing investor, media and governmental resistance, particularly under the Trump administration’s anti-DEI executive orders and general policy, the strategic use of donor-advised funds by potentially politically motivated organizations undermines the accountability mechanisms of corporate governance principles. Understanding the behind-the-scenes financial flows that empower these actors is essential for policymakers, investors, and the public to assess the true influences shaping corporate America’s approach to diversity, equity, and inclusion.

This analysis highlights a great lack of transparency in charitable giving and shareholder activism, manifesting in the case when a network of tax-exempt charitable entities are used to support politically charged agendas. What emerges is an urgent need to re-think financial disclosure and specifics on limits to political lobbying for 501(c)(3) organisations in the US. These findings also raise the broader question of whether current definitions of “lobbying” and “substantial part” activity for 501(c)(3) organizations adequately capture modern forms of indirect political influence, such as coordinated shareholder activism. ^[5]Clarifying these boundaries could help ensure that tax-exempt status remains aligned with nonpartisan public benefit purposes.

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^[1] The biblical mandate for Christians to spread the gospel and make disciples of all nations

^[2] https://www.velaw.com/insights/fifth-circuit-affirms-secs-authority-over-shareholder-proposals

^[3] https://www.proximate.press/latest-stories/whats-next-for-daf-reform

^[4] https://apnews.com/article/donor-advised-fund-irs-hearing-2a3b282a07892c9c74f00dcee4ad6f83

^[5] https://www.oversight.gov/sites/default/files/documents/reports/2021-02/202110013fr.pdf