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AT&T Political Engagement Report

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AT&T Political Engagement Report AT&T Political Engagement Report January–June 2018 © 2018 AT&T Intellectual Property. All rights reserved. AT&T and the AT&T logo are trademarks of AT&T Intellectual Property. AT&T Political Engagement Report Executive Summary AT&T is a proud member of the communities where we live and work. We strive to bring our customers the innovation they demand, provide shareholders value on their investment and be a responsible corporate citizen. A critical component of these efforts is being an active participant in the political process. We do this through corporate political contributions, memberships in trade associations, contributions to other tax-exempt organizations, employee PAC contributions and lobbying expenditures. In this Report we provide important information on how we participate in the political process. Of course, every action we take is in strict compliance with local, state and federal law, but that is only the beginning. We are also guided by our Core Values, our Code of Business Conduct and our Political Engagement Policy. In addition, the Public Policy and Corporate Reputation Committee of the Board of Directors provides effective oversight, and we have a robust internal authorization process for all of these activities. Together, these processes and protections are directed to one purpose: to ensure we have an effective, responsible voice in policy discussions that impact our business, our employees and our customers. This Report provides further information on these and other topics. In accordance with applicable law, campaign finance and disclosure rules, and our own internal policies, we publicly disclose U.S. political contributions twice yearly via this Report. In response to shareholder requests, we also identify organizations that report using some or all of our contributions for lobbying activities. 2 AT&T Political Engagement Report Positions and Policy Public Policy Positions Further, no contributions are made in Public policy creates the “rules of the anticipation of, in recognition of, or in road” for companies like AT&T, and now, return for any act or favor. more than ever, we need these rules to keep pace with the drivers — relentless Additional information on many of AT&T’s innovation and limitless possibilities. public policy positions can be found in the issue briefs located on the Company’s To encourage public policies that help us public policy main page, our corporate deliver the best entertainment and responsibility website and the AT&T communications experiences, AT&T Forum. contributes prudently to state and local candidates and political organizations, as Political Engagement Policy permitted by law, when such contributions Our Political Engagement Policy is publicly advance AT&T’s business objectives and available, and it details how we make the the interest of our shareholders. decision to contribute, to whom we contribute and which corporate leaders Consideration of a contribution is guided approve these expenditures. by our Core Values and is made without regard for the personal political AT&T personnel consult with the AT&T preferences of AT&T’s officers, Legal Department to ensure that executives, or board members. contributions are lawful and consistent with applicable statutes, regulations, limits and guidelines. 3 AT&T Political Engagement Report Contributions Political contributions, where permitted, are Our latest contributions and disclosures an important part of the political process. This can be accessed through the links found Report is intended to provide transparency on in the remainder of this Report. the subject of our corporate contributions, as well as on contributions made by our • State Candidate Contributions employee PACs. To summarize: • State and Local Political Party and • Our employees can participate in the Other Political Group Contributions political process through our employee • Political Action Committee (PAC) PACs. Disbursements by those PACs Contributions support federal and state candidates and • Ballot Measure Contributions are disclosed in this Report. • Where lawful, we make corporate political Trade Association and Other Tax- contributions to state and local candidates, Exempt Organization Contributions political parties, political action AT&T contributes to trade associations committees, and ballot measure and other tax-exempt organizations, committees. Those contributions are including those organized under Internal disclosed in this Report. Revenue Code Section 501(c)(6), that • We do not make corporate political promote matters of importance to the contributions to federal political parties or industry on behalf of their members. We candidates for federal office. disclose organizations to which we • As a general practice, we do not make contributed $50,000 or more where a independent political expenditures or portion of those contributions has been corporate political contributions to identified as used for lobbying. We make independent expenditure committees or to a reasonable effort to obtain from these any non-candidate or non-political party organizations, or through other means, political committee organized under the portion of the Company’s payments Section 527 of the Internal Revenue Code that the organization allocates to (e.g., Super PACs); however, if we do, we lobbying expenditures, and we disclose disclose them in this Report. those amounts. In addition, our disclosures extend beyond political contributions. When a trade • Trade Association and Other association or other tax-exempt organization 501(c)(6) Organization Lobbying uses one or more of our contributions for Disclosures lobbying activities, we disclose them as described below. 4 AT&T Political Engagement Report Contributions Contributions We also contribute to tax-exempt Employee PAC Contributions advocacy organizations that engage in AT&T Employee Political Action Committees political activities, such as those organized (PACs) are voluntary, non- partisan and under Internal Revenue Code Section provide eligible AT&T management 501(c)(4), where those organizations’ employees an opportunity to collectively missions align with our policy interests. If a support public policy positions that are portion of our contribution has been important to AT&T. In all, there are 31 identified as used for lobbying, we identify separate state employee PACs and a federal that organization in our disclosures. We employee PAC. Each AT&T Employee PAC make a reasonable effort to obtain from has a chairman, officers, a committee of these organizations, or through other employees that is engaged in PAC operations means, the portion of the Company’s and Articles of Operation outlining its payments the organization allocates to operating procedures. lobbying expenditures, and we disclose those amounts. Each Employee PAC’s Disbursement Committee, which determines the • Tax-Exempt 501(c)(4) Organization contributions that will be made, is comprised Lobbying Disclosures of management employees from various AT&T business units and management levels AT&T supports organizations that have within the Company. Consideration of a significant public policy positions that are impactful to the industry. We review contribution to a candidate is guided by our differing policy issues, and those are taken Core Values and based on the candidate’s into consideration when determining position on issues of importance to AT&T’s annual membership. Our participation in business and the technology, media and these various industry, trade and advocacy telecommunications industry. groups comes with the understanding that • State PAC Contributions we might not always agree with all • Federal PAC Contributions positions of the larger organization and/or other members, and that we are committed to voicing our concerns as appropriate through the AT&T leaders who interact with these organizations, many of whom serve on the boards and committees of these organizations. 5 AT&T Political Engagement Report Lobbying AT&T is committed to adhering to the AT&T files federal lobbying reports highest ethical standards when quarterly with the Office of the Clerk engaging in any political activities. As of the U.S. House of Representatives such, AT&T complies with all federal and the Secretary of the U.S. Senate, and state laws and regulations for pursuant to the federal Lobby lobbying registrations and reporting. Disclosure Act. To review the quarterly AT&T companies, employees and federal filings, visit the links above and external lobbyists and firms must select “AT&T” in the name search field. register as lobbyists as required by applicable law to represent the AT&T files state lobbying reports with Company’s interests. the appropriate state governing agencies in compliance with the All lobbying registrations and requirements in respective states. expenditures reporting are done in These reports are publicly available in strict compliance with these laws. the respective jurisdictions and disclose the required lobbying information. 6 AT&T Political Engagement Report IV. GOVERNANCE GovernanceGovernance Board of Directors Oversight Trade Associations and Other Tax- Exempt The AT&T Inc. Board of Directors’ Public Organizations Policy and Corporate Reputation A full list of these contributions is shared Committee (PPCRC), comprised entirely of with the PPCRC of the Board and the full outside directors, is responsible for Board on an annual basis for their review oversight of AT&T’s public policy activities and guidance. and corporate
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