Visa Inc., its subsidiaries and affiliates participate in the political process in a manner that builds our community, reflects responsible corporate citizenship and fulfills our duties to shareholders, employees and other stakeholders. Since public-sector decisions significantly affect Visa’s business, direction and growth, we facilitate political contributions, communicate with government officials and encourage the civic involvement of our employees.
In October of 2010, the Nominating and Corporate Governance Committee of the Visa Inc. board of directors approved a comprehensive Political Participation, Lobbying and Contributions Policy to (a) promote ethical and transparent political engagement by Visa, (b) ensure that the company’s political spending enhances shareholder value, and (c) facilitate the company’s compliance with applicable laws and reporting requirements. Under the Policy, the Nominating and Corporate Governance Committee must pre-approve the use of corporate funds for political contributions and Visa must annually disclose those contributions on its website. The reports are listed below.
Recipients of political contributions are selected using the following criteria established by Visa’s board of directors:
- The potential contributee’s views, voting record and understanding of policy issues of importance to Visa, its shareholders and other stakeholders;
- The potential contributee’s reputation for integrity;
- The potential contributee’s service in a party or legislative leadership position;
- The potential contributee’s relationship to or representation of a Visa facility or a large concentration of Visa employees; and
- The extent to which the potential contributee shares Visa’s legislative priorities.
Consistent with United States federal law, Visa does not contribute to U.S. federal candidates, national political party committees or other federal political committees. We do make use of corporate funds for contributions to state or local candidates and ballot measures in the United States, where permissible and within the limits designated by state and local laws and regulations. We also make contributions to certain established and recognized associations that are organized under Section 527 of the U.S. federal tax code and are registered with the Internal Revenue Service, Federal Election Commission or a state equivalent regulating entity. Each political contribution is approved by the appropriate Government Relations representative (state, federal or international) where the contribution is made.
While Visa belongs to various trade associations in the United States and abroad and pays regular dues to these groups, we do not normally make additional, non-dues contributions to support such groups’ targeted political campaigns. We also do not regularly sponsor advertisements that qualify as “independent expenditures” or “electioneering communications” under United States federal campaign finance laws. However, in the event we do make such contributions, they must be approved in advance by the Nominating and Corporate Governance Committee and disclosed in our annual contributions report.
In the United States, Visa also sponsors a federal Political Action Committee (PAC) pursuant to the Federal Election Campaign Act, as amended, and the regulations promulgated by the Federal Election Commission. The Visa PAC enables Visa employees to voluntarily pool their financial resources to support federal, state and local political candidates and organizations. Visa PAC contributions and expenditures are publicly disclosed on government-agency websites, including the Federal Election Commission’s website (www.fec.gov). In addition to disclosure of Visa PAC contributions on government websites, interested parties may monitor our federal PAC contributions through the websites of the Center for Public Integrity and the Center for Responsive Politics below.
Contributions from the Visa PAC are reviewed by our PAC Advisory Council or its designee. Under the Policy and Visa’s Code of Business Conduct and Ethics, our directors, officers and employees are prohibited from using company resources to promote their personal political views, causes or candidates.