Intuit is committed to being a responsible and respected corporate citizen and a global thought leader in our engagement in the external public policy process in the countries where we have employees, products, and where public policy affecting our business is created. Our engagement is covered by our Code of Conduct and at all times reflects the principles of Intuit's Corporate Values, beginning with Integrity Without Compromise.
We believe encouraging the development of sound public policy is an important element of good corporate global citizenship so that we can better serve our customers, employees, and shareholders. Our goal is to:
Encourage a positive public policy environment that can advance Intuit's strategic business objectives and enables us to provide innovative products and services to our customers;
Anticipate external public policy challenges and opportunities, and drive strategies to create business advantage and mitigate risk;
Engage in the public policy community to promote an external environment that supports business growth, operational efficiencies and cost minimization; and
Educate and support policy makers who share our vision of responsible protections for individuals and small businesses, balanced with a free and fair competitive marketplace where digital innovation can grow and flourish.
Intuit transparently participates in all aspects of the public policy process including educating agencies and elected officials on our policy positions and their impact to consumers and small businesses, and supporting candidates whose business public policy issue positions align with Intuit's corporate policy interests. Intuit is non-partisan; we participate across the spectrum and believe the best policies that serve the public interest and common good usually represent a thoughtful balance and tend to be forged in the political center through a bipartisan, collaborative political process, an area of focus for Intuit.
We interact with a comprehensive suite of thought leaders across the political spectrum who help shape public opinion and policy. As part of that process Intuit may share information with legislators, regulators, think tanks, policy groups, academic institutions, foundations, other non-governmental organizations and the public via testimony, position papers, public statements, etc.
Process
Intuit and our employees participate in the political process in three ways: as individuals, through the Intuit Political Action Committee in the United States, and via corporate contributions where allowed by law, and in a manner compliant and consistent with the law. All employee participation is voluntary.
In addition, Intuit also engages in lobbying activities, and the costs associated with such activities are reported as provided by applicable federal, state and local laws.
All corporate political contribution requests received by Intuit are reviewed by Corporate Affairs; contributions that are strategic and meet the guidelines of this policy are approved by the Corporate Affairs Director of Government Relations or the Vice President of Corporate Affairs/Chief Public Policy Officer. Political activity outside the United States is governed by this policy and is conducted with the strictest adherence to the U.S. Foreign Corrupt Practices Act and Intuit's Code of Conduct, both of which are the subject of required training for employees.
In the United States Federal law does not permit direct corporate contributions to candidates for Federal office or national party committees. However, under the Federal Election Campaign Act of 1971, as amended, companies are allowed to participate in the political process in defined ways:
Companies may establish Federally regulated Political Action Committees (PACs), which are funded through voluntary contributions from eligible employees. Such PACs may contribute to the political campaigns of candidates for Federal office, national party committees, and other Federal PAC's, and are subject to full reporting and disclosure requirements with the Federal Election Commission. In 2000 Intuit created its employee PAC, The Intuit 21st Century Leadership Fund. At this time, Intuit does not have a State PAC.
Under the U.S. Supreme Court's Citizens United decision, corporations may contribute unlimited funds to Independent Expenditure Committees for or against political candidate campaigns. Intuit does not contribute corporate dollars to such committees.
State laws vary but many do allow corporations to make contributions to candidates for State or Local office, Political Parties, and organizations that engage in political activity. Consistent with law and regulation, including individual State contribution limits and reporting requirements, Intuit may make selective political contributions.
Intuit adheres to all laws and regulations governing political campaign contributions at the Federal, State, and Local levels. We do not favor any particular political party or ideological point of view, and we focus our support decisions on strategic judgments related to how best to further Intuit's positions on strategic business policy issues.
The Intuit 21st Century Leadership Fund PAC, comprised of representatives of Intuit's major businesses and functional groups, meets two times per year to discuss contributions policies and goals for the year; contributions can be approved by the Corporate Affairs Director of Government Relations or the Vice President of Corporate Affairs/Chief Public Policy Officer.
Political Contributions
Intuit's giving is non-partisan and/or bi-partisan depending on the political culture and environment and uses the following criteria to guide our political contribution choices:
Representation of a district of importance to Intuit
Policy position(s) of importance to Intuit and/or the customers that we serve
Leadership role in government or position on relevant legislative committees -
Strong or emerging relationship with high-tech industry
Nature of the opposition/competitive environment
Financial need of campaign for electoral success
We recognize that given the complex nature of politics there may be times when a candidate or organization supports positions that align with most but not all of our policy interests and in those cases we make our choices based on political judgments on the issues that have the greatest impact to our customers, stockholders and key stakeholders.
Transparency
We comply with the spirit and letter of all Federal and State laws governing political contributions and their reporting and disclosure requirements. In the United States our PAC contributions are publicly disclosed on the Federal Election Commission (www.fec.gov) and corresponding State Web sites and are aggregated on Intuit.com annually. Our Political Accountability Policy is posted on Intuit's internal and external Web sites.
We comply with all Federal and State lobbying and reporting requirements and regulations, and our Federal reporting is publicly disclosed on the Lobbying Disclosure Act (LDA) website of the US Congress. Some of the trade associations of which we are members also engage in lobbying and allocate a portion of dues for that purpose. We disclose any such association lobbying costs in our LDA report filings as well.
Employee Participation
Intuit will not reimburse anyone for a political contribution or expenditure. Unless directly authorized in advance by the Vice President Corporate Affairs/Chief Public Policy Officer, and applicable by law, Intuit employees may not offer or make contributions, expenditures, or assistance on behalf of Intuit in connection with public elections or political campaigns.
Intuit encourages personal participation by its employees in the civic and political process of their country outside of working hours. However, employees' political efforts, including but not limited to helping elect candidates to office or holding an appointed or elected position themselves, must be on a purely personal basis and may not in any way imply that such activities are conducted on behalf of, or have the endorsement of, Intuit. Employees with questions or who have been approached to hold or seek a position representing Intuit should seek guidance by submitting an inquiry to Vice President Corporate Affairs/Chief Public Policy Officer via the Ethics & Compliance Program Office.
Employees shall not use their positions or titles with Intuit in their personal political activities nor shall they use corporate stationary, addresses, facilities, resources or Intuit property for any political activity, unless such activities are authorized in advance by the Vice President Corporate Affairs/Chief Public Policy Officer and are permissible under applicable law and regulation.
In the United States, any Intuit employee who is a National Citizen or has a Green Card may voluntarily choose to participate in the Political Action Committee, the Intuit 21st Century Leadership Fund; federal law prohibits foreign nationals from making contributions in connection with any federal, state or local election, including involvement with the administration of the federal PAC. The universe of eligible employees invited to participate may vary from time to time based on management judgment.
Oversight
This policy is reviewed and approved annually by Intuit's Board of Directors and the Nominating and Governance Committee of Intuit's board.
Annually the Nominating and Governance Committee reviews and provides oversight to an annual report of the Company's corporate and PAC political candidate contributions, lobbying allocations and trade association memberships.
An Executive Management Committee, comprised of the General Counsel, Chief Financial Officer and Chief Public Policy Officer, biannually reviews all political candidate contributions made, trade association memberships, lobbying and participation with issue analysis and policy research groups.
Finally, Intuit's Corporate Affairs department is regularly subjected to an Internal Audit review.
Political Accountability Policy
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