U.S. Political Engagement Policy, Oversight, and Disclosure
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U.S. Political Engagement Policy, Oversight, and Disclosure April 2021 Policy Introduction Salesforce’s Government Affairs and Public Policy team works with governments and other stakeholders around the world on issues that impact the lives of our employees, our customers and our company, guided by our four core values: trust, customer success, innovation, and equality. Salesforce’s Government Affairs and Public Policy team is nonpartisan in our work, and we support policies, candidates, and eligible organizations of any party who share our priorities. Salesforce is transparent, publicly disclosing all contributions in the U.S. in reports filed with the Federal Election Commission and with various state campaign finance commissions. Salesforce also participates in a variety of industry organizations, coalitions, and trade associations to advance our public policy interests and business goals. We review these memberships on an ongoing basis. We are committed to complying with all laws, rules and regulations relevant to our political activity. Contribution Eligibility Salesforce is nonpartisan. We support candidates and eligible organizations of any party who share our priorities, even if we don’t agree on every issue. All political contributions are made to promote the interests of the Company, without regard for the private political preferences of individual employees. The Company does not use corporate funds or resources to support federal candidates and exclusively uses the Salesforce.com Inc Political Action Committee, as required by federal law. Where permissible by law, we contribute to state and local candidates and ballot measures through corporate expenditures. We also make corporate expenditures to support our membership in trade associations and contribute to other tax-exempt organizations, which may be used for political purposes. We do not contribute to political parties, Super PACs, or 527 groups, nor do we use corporate treasury funds for independent political expenditures. Political Action Committee Corporations in the United States are not allowed to contribute directly to federal candidates. However, companies can organize and fund the establishment, administration, and solicitation expenses of an employee-funded Political Action Committee (PAC). Many companies in the U.S. choose to have an employee PAC. The Salesforce.com Inc PAC was incorporated in 2012 to support public policies in the U.S. that align with our core company values. Funding comes entirely from voluntary contributions of eligible Salesforce employees. Employees are not reimbursed directly, through compensation increases or any other means, for personal campaign contributions. The Salesforce.com Inc PAC is governed by an internal steering committee. We are committed to complying with FEC rules and regulations for PAC contributions, and we publicly disclose all PAC contributions in reports filed with the Federal Election Commission, as required by law. Corporate Expenditures While corporations cannot support candidates for federal office, many states allow donations from corporate treasury funds to political candidates and ballot measures at the state and local level. Salesforce makes political contributions to support candidates and ballot measures that are aligned with our core values, in a similar manner to the process for PAC contributions. This includes the involvement of our internal steering committee. We abide by the laws of each individual state and jurisdiction in which we do business, and we are committed to complying with their campaign finance rules and regulations. Trade Associations & Social Welfare Organizations Like many corporations, Salesforce supports a variety of tax-exempt organizations, including 501(c)3 charitable organizations, 501(c)4 social welfare organizations, and 501(c)6 trade associations. This includes using corporate treasury funds to pay for memberships in these groups. By law, social welfare organizations and trade associations are permitted to use a portion of membership dues for political activities. Some, but not all, of the groups we belong to engage in political activities. Although we support several groups that further our public policy interests and business goals, we do not always support all of the public positions of those associations or other companies that make up their membership. We review these memberships on an ongoing basis for alignment to our company's core values and priorities. Policy Priorities Selection of issues that are included in our political spending decisions: ○ Artificial intelligence ○ Cross border data flows ○ Cybersecurity ○ Data privacy and protection ○ Digital transformation of industries and public sector ○ Equality ○ Future of Work ○ Sustainability ○ Trade and market access Visit our public policy page on our website. Political Spending Decisions Our internal steering committee makes political spending decisions for PAC and corporate contributions to candidates. The committee includes representatives from business units outside of Government Affairs. Approval requires the support of 75% of the committee. The Executive Vice President for Government Affairs has final authority over all of the Company’s political spending. This position reports to the Company’s President and Chief Financial Officer. The President and Chief Financial Officer shall approve all political contributions prior to disbursement, and the company’s Chief Financial Officer shall approve all political contributions exceeding $50,000. The Nominating and Corporate Governance Committee of our corporate Board of Directors is responsible for regular oversight of our political spending. Lobbying Salesforce files quarterly reports about our federal lobbying activity with the U.S. Senate and the U.S. House of Representatives in compliance with the Lobbying Disclosure Act. In addition, Salesforce files lobbying disclosure reports in each individual state and jurisdiction where we engage in lobbying activity, as local laws require. We are committed to complying with all laws, rules, and regulations relevant to our lobbying activity. Oversight Board of Directors The Nominating and Corporate Governance Committee of our corporate Board of Directors annually reviews our political contributions from corporate treasury funds and the Salesforce PAC. The Committee shall also review our company policy on political expenditures and payments to trade associations and other tax-exempt organizations that may be used for political purposes. The Nominating and Corporate Governance Committee is composed entirely of independent directors. To view the current committee membership, please visit Salesforce Investor Relations. Compliance A detailed report of corporate political spending is available on a dedicated webpage accessible from our corporate homepage. To the best of our abilities, we include five years of historical data related to PAC contributions, corporate contributions, and contributions for memberships in U.S.-based trade associations and social welfare organizations. The Company has put internal processes for political spending in place to ensure that political contributions are made in compliance with our political spending policy. Disclosure PAC Contributions Salesforce.com Inc PAC Contributions Campaign Committee Candidate Level Amount 2020 H2 Schatz for Senate Sen. Brian Schatz (D-HI) Federal $2,500 Friends of Mark Warner Sen. Mark Warner (D-VA) Federal $2,500 Friends of Todd Young Sen. Todd Young (R-IN) Federal $2,500 Capito for West Virginia Sen. Shelley Moore Capito (R-WV) Federal $1,500 Cory Gardner for Senate Sen. Cory Gardner (R-CO) Federal $1,000 Barbara Lee for Congress Rep. Barbara Lee (D-CA-13) Federal $1,000 Pallone for Congress Rep. Frank Pallone (D-NJ-6) Federal $2,500 McNerney for Congress Rep. Jerry McNerney (D-CA-9) Federal $1,000 Schakowsky for Congress Rep. Jan Schakowsky (D-IL-9) Federal $1,000 Jeffries for Congress Rep. Hakeem Jeffries (D-NY-8) Federal $1,000 Robin Kelly for Congress Rep. Robin Kelly (D-IL-2) Federal $1,000 Richard E. Neal for Congress Committee Rep. Richard Neal (D-MA-1) Federal $1,000 Kingzinger for Congress Rep. Adam Kinzinger (R-IN-16) Federal $1,000 Salesforce.com Inc PAC Contributions Campaign Committee Candidate Level Amount 2020 H1 Chris Coons for Delaware Sen. Chris Coons (D-DE) Federal $2,500 Delbene for Congress Rep. Suzane Delbene (D-WA-1) Federal $1,000 BSA | The Software Alliance PAC Business Software Alliance Federal $5,000 ASPIRE PAC Congressional Asian Pacific American Caucus Federal $5,000 ModSquad Moderate Democrats PAC Federal $5,000 Congressional Black Caucus PAC Congressional Black Caucus PAC Federal $5,000 CHC BOLD PAC Congressional Hispanic Caucus Federal $5,000 EDW PAC Elect Democratic Women PAC Federal $5,000 NAM PAC National Assn. of Manufacturers PAC Federal $5,000 Tuesday Group PAC Republican Governance Group Federal $5,000 Value in Electing Women PAC Elect Democratic Women PAC Federal $5,000 New Democrat Coalition Action Fund New Democrat Coalition Federal $5,000 Equality PAC Congressional LGBT Equality Caucus Federal $5,000 ITI PAC Information Technology Industry Association Federal $5,000 Future Forum PAC Future Forum Federal $5,000 Salesforce.com Inc PAC Contributions Campaign Committee Candidate Level Amount 2019 H2 Buck for Colorado Rep. Ken Buck (R-CO) Federal $1,000 Andre Carson for Congress Rep. Andre Carson (D-IN) Federal $1,500 Friends of Jim Clyburn Rep. Jim Clyburn (D-SC) Federal $1,500 Mario Diaz-Balart for Congress Rep. Mario Diaz-Balart (R-FL)