2017 Political Engagement Report
Total Page:16
File Type:pdf, Size:1020Kb
AT&T Political Engagement Report July 2017 – December 2017 1© 2017 AT&T AT&T Inc. Intellectual Property. All rights reserved. AT&T and the AT&T logo are trademarks of AT&TAT&T Intellectual Political Property. Engagement Report Corporate Governance & Board Oversight Policy AT&T values responsible corporate governance and participates in the political process in an effort to formulate policies that benefit consumers, shareholders and the communities in which we operate. One of the many ways we encourage a contribution budgets and tracks spending levels. dynamic public policy debate is by supporting a AT&T built the mechanized system to ensure every wide range of political candidates who are request for a political contribution is legally addressing the issues of greatest concern to reviewed and approved by management in strict the country. While we do not always agree with compliance with its internal policy and procedures every position taken by political candidates and for Corporate Political Contributions. political organizations, we do provide support where they have significant positions that align AT&T ensures compliance with its policies and with our company’s core goals. procedures regarding political activities, contributions and lobbying through regular In making contributions, AT&T is guided by training and reviews, periodic internal audits and strong corporate governance principles and employee acknowledgments regarding compliance practices. We are committed to complying with with AT&T’s policies governing political activities. laws and regulations governing the political process, including campaign finance and Board of Directors Oversight disclosure rules. AT&T has established strict internal policies, processes and compliance The Public Policy and Corporate Reputation measures to ensure adherence to legal and Committee of the Board of Directors is regulatory requirements. responsible for oversight of AT&T’s public policy activities and corporate political fund AT&T complies with its internal political disbursements, and it receives regular reports contributions and funding policy by using a about all contributions made by the Company. mechanized system for requesting, evaluating, processing and authorizing all political contributions. The mechanized system, which requires individual attention to each separate contribution request, also manages political 2 AT&T Inc. AT&T Political Engagement Report Corporate Governance & Board Oversight Policy The Committee in turn provides a full report of Executive Leadership Approval these activities to the Board for its approval. Each year, the Public Policy and Corporate AT&T’s Senior Executive Vice President – Reputation Committee recommends, and the External and Legislative Affairs, who reports Board reviews and approves, a maximum limit directly to AT&T Inc.’s Chairman and Chief on the aggregate amount of political Executive Officer, is responsible for overall contributions that may be made and management and participation in the political authorizes only political contributions that are process. Support for candidates and permitted by, and in strict compliance with, organizations is based on corporate applicable law. The AT&T Political Contribution public policy. Statement is posted externally on AT&T’s public website. AT&T complies with the law and Corporate political contributions are made does not make corporate political without regard for the personal political contributions to candidates for federal office. preferences of AT&T’s officers and executives. Further, no contributions are made in As part of the Board’s oversight of AT&T’s anticipation of, in recognition of, or in return for public policy activities, the Public Policy and any act or favor. AT&T applies a robust Corporate Reputation Committee reviews the authorization process for political federal, state and local lobbying expenditures expenditures. Before any Corporate political on an annual basis. contribution can be presented for approval, it must be reviewed by the company’s attorneys Additional information on many of AT&T’s to confirm that it is lawful. All corporate public policy positions can be found in the issue political expenditures must be approved by the briefs located in the company’s Corporate Chief Executive Officer of the Company making Citizenship and Sustainability Report. the request, or a delegate if the amount is $2,500 or less. A quarterly report of all political contributions, regardless of amount, is reviewed by AT&T Inc.’s Chairman and Chief Executive Officer and annually by the Board. 3 AT&T Inc. AT&T Political Engagement Report Corporate Governance & Board Oversight Policy Political Activity and Lobbying AT&T publicly discloses all political contributions twice a year in the AT&T Political Engagement AT&T is committed to adhering to the highest Report. ethical standards when engaging in any political activities. As such, AT&T complies with all federal Contributions to Industry Associations and state laws and regulations for lobbying and Coalitions registrations and reporting, as well as political contributions. AT&T contributes to industry associations and coalitions — such as the United States Telecom All lobbying registrations and expenditures Association, CTIA-The Wireless Association, the reporting are done in strict compliance with these Alliance for Telecommunications Industry laws. AT&T files federal lobbying reports quarterly Solutions, Satellite Broadcasting & with the Office of the Clerk of the Communications Association of America — and U.S. House of Representatives and the Secretary other industry associations and coalitions that of the U.S. Senate, pursuant to the federal Lobby advocate on matters of importance to the Disclosure Act. To review the quarterly federal industry on behalf of their members. AT&T has filings, visit the links above and select AT&T in the a rigorous approval process for contributions name search field. to industry associations and coalitions. Each proposed contribution must be in the best Also, AT&T files state lobbying reports with interests of the Company and our shareholders the appropriate state governing agencies and must be approved by the Senior Executive in compliance with the requirements in the Vice President – External & Legislative Affairs respective state. These reports are publicly and the Senior Executive Vice President & available in the respective jurisdictions and General Counsel or other senior leaders who disclose the required lobbying information. receive guidance from AT&T’s legal counsel. AT&T companies, employees and external These contributions are discussed with the lobbyists and firms register as lobbyists as Public Policy and Corporate Reputation required by applicable law to represent the Committee of the Board on a regular basis, and company’s interests. both the Committee and full Board are provided with the full list of contributions and 4 AT&T Inc. AT&T Political Engagement Report Corporate Governance & Board Oversight Policy have an opportunity to provide guidance with AT&T encourages its employees’ voluntary, respect to the Company’s contributions. While personal participation in the political process, we may not always agree with every position whether by voting, volunteering time, taken, AT&T supports organizations that have contributing money to the candidates of their important public policy positions that are choice or holding public office. However, there impactful to the industry. In addition, AT&T are strict laws that apply to corporate does review differing policy issues, and those involvement in the political process, and it is important that employees’ personal political are taken into consideration when determining activities are separate from their annual membership. responsibilities to the Company. AT&T has a policy that instructs employees to maintain Code of Business Conduct separation between their personal political activities and their activities on behalf of the AT&T’s Code of Business Conduct includes Company. Employees are advised that personal provisions regarding political activity and political activities must never occur on contributions that provide guiding principles Company time, and no Company resources and practical application for employees. AT&T’s can be used. Code of Business Conduct is reviewed annually by all employees. As an example and as It is the unequivocal policy of AT&T that no outlined in the AT&T Code of Business Conduct, employee will be subject to any form of employees are prohibited from offering favors pressure, coercion or intimidation related to or anything of monetary value, including gifts participation in political activities, nor shall any or loans, to employees and representatives of employee receive compensation or benefits for governmental entities, except as allowed by participating in personal political activities. law under generally narrow circumstances. 5 AT&T Inc. AT&T Political Engagement Report PAC Contributions AT&T’s Employee Political Action Committees (PACs) are voluntary, non-partisan and provide AT&T management employees an opportunity to collectively support public policy positions that are important to AT&T. AT&T has a long history of employee contributions that will be made, is comprised of involvement in the political process through its management employees from various AT&T AT&T Employee PACs. In all, there are 30 business units and management levels within separate state employee PACs and one federal the Company. Consideration