Integrity Standard - Political Activity
and Community Involvement
Policy:
Federal laws restrict the use of corporate funds in connection
with federal elections, and there are similar laws in many
states. It therefore is the policy of the Company that neither
Company name, the Company funds, nor Company facilities
shall be used directly or indirectly for political purposes
on behalf of candidates for political office, political
parties or elected incumbent office holders at any level,
federal, state or local, except as permitted by law and
the Company’s Political Activity Policy. The Company
will not reimburse employees for contributions to political
candidates or causes.
The Company is committed to playing a leadership
role in fulfilling our social responsibility. Our efforts
to meet our obligations will vary from location to location.
The Company’s local presence and commitment will be
coordinated at the corporate level and shaped by local needs
and opportunities. Employees are encouraged to participate
in community programs.
Employees are encouraged to vote and participate fully
in the political process. However, except as permitted by
Company policy, we cannot use Company resources to vote
and be active in political activities. Employee participation
in non-corporate political activity is strongly encouraged,
but must be done on our own time and at our own expense.
The Company complies with the requirements of all applicable
laws entitling employees to excused “time off”
for voting.
Nothing in this Standard prohibits eligible salaried employees
from voluntarily participating in the Company’s Political
Action Committee (PAC) activities nor does it prohibit the
Company from bearing the administrative expense of establishing
and operating federal or state Political Action Committees
(PACs) in conformance with Company policy and with applicable
federal and/or state legal requirements.
The Company's management may, from time to time, distribute
memos or sponsor activities to bring political and public
policy issues to the attention of employees. These activities
may include participation by public officials or candidates
for public office. Any such activities by the Company shall
be for the purpose of encouraging employee participation
in the public policy dialogue and shall not constitute endorsement
of any particular candidate, officeholder or political party.
Equal opportunity will be afforded all rival candidates
and political parties.
Questions and Answers
Q. Can I, on occasion, do some personal
volunteer work monitoring election practices during various
municipal, state, and federal elections?
A. You may use PTO days to work as a volunteer
in the election-related activities mentioned. However, no
reimbursement will be made by the Company for any expenses
which you incur.
Q. Can I speak at a local club meeting on the issue
of health care reform?
A. Yes, as long as you make it clear that
you are speaking for yourself and not as an official spokesperson
for our Company. If you are asked to represent our Company
in a formal capacity, you should obtain approval from your
EVP/SVP who will advise you whether you need to discuss
the matter and review your proposed presentation with our
Public Affairs Department.
Q. Can our Company pay for the administrative expenses
necessary to establish and operate either a federal Political
Action Committee (PAC) or a state Political Action Committee
(PAC)? May I voluntarily participate in the Company’s
PAC program?
A. Under federal and state laws, the Company
is permitted to pay the costs necessary to establish and
operate federal and state PACs. It is also legally permissible
for Company employees both to voluntarily contribute to
a federal or state PAC and to perform the administrative
tasks necessary to establish and operate a federal or state
PAC.
Q. I just received an e-mail announcing that a candidate
for office will be speaking in our building to employees.
Doesn't that violate our Code by using the building for
political purposes?
A. Provided all rival candidates or political
parties are offered equal access, this does not constitute
endorsement of a particular candidacy and is not a violation
of our Code.
Q. Our Public Affairs Department has sent out an
e-mail urging employees to contact members of the Legislature
in opposition to a specific piece of legislation. They say
the bill would hurt our company. Isn't that a violation
of the Code?
A. No. Public policy issues differ from
political endorsements. The Company's ability to operate
effectively depends upon fair and equitable legislation
and regulation at both the state and federal levels. It
is important that the company and its employees be heard
on these issues. However, while the Company is entitled
under the Code to encourage such employee participation;
it is always voluntary on the part of the employee.
Remember, if you do not understand, or if you have
any questions concerning, this Integrity Standard or any
other part of the Code, contact your Supervisor, a higher
level Supervisor, any of the Corporate Resources or call the Corporate Integrity HOTLINE (1-800-838-2552).
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