This policy addresses contributions and expenditures by United Parcel Service, Inc. ("UPS" or the "Company") as well as UPS lobbying activity. This policy does not apply to the actions of company-sponsored state or federal political action committees, and it does not apply to contributions to political parties, candidates or committees that support elections outside of the United States. The Board of Directors has adopted this policy, which is designed to ensure that contributions to which it applies are made in a manner consistent with the Company's core values and to protect and/or enhance shareowner value, and that the Company’s lobbying activities comply with all applicable laws.
A. Federal elections
1. Corporate Resources: Corporations are prohibited by law from making political contributions to any candidate for federal office. UPS policy is to comply with all federal laws and related regulations regarding the use of corporate resources in connection with federal elections. UPS's resources include, but are not limited to, Company time, funds, facilities, office supplies, letterhead, phones and fax machines. As has been the Company's historical practice, the Company-sponsored political action committee (the United Parcel Service Political Action Committee, or "UPSPAC") makes all legally permissible political contributions and expenditures. UPSPAC contributions can be viewed on the website of the Federal Election Commission at www.fec.gov.
2. Personnel time: UPS policy is to comply with all federal laws and related regulations regarding time spent during work hours in support of or opposition to federal candidates and committees.
A UPS manager may not request junior colleagues or colleagues whose work the manager supervises (including administrative personnel) to assist him or her in campaign fundraising or volunteer efforts. Participation in political activities must be the independent, voluntary decision of each UPS employee.
3. Inadvertent use: If a UPS employee inadvertently uses the Company's resources in connection with a federal campaign, the employee must contact the Public Affairs Group Manager and provide reimbursement to UPS within five business days. Reimbursement must be equal to the fair market value of the item or service provided to the campaign or committee. Public Affairs, in consultation with the Corporate Legal Department, will determine fair market value for reimbursement purposes.
B. State and local elections
UPS does not make corporate contributions to state and local candidates and committees. As has been the Company's historical practice, UPSPAC makes all legally permissible political contributions and expenditures. UPSPAC contributions can be viewed on the website of the Federal Election Commission at www.fec.gov.
C. Authority to make political contribution and expenditure decisions
The Company does not make corporate political contributions or expenditures; all political contributions and expenditures are made only through voluntary employee-funded UPSPAC contributions. The Nominating & Corporate Governance Committee must approve any deviations from this policy. Any corporate contributions or expenditures will be reported as described below. Corporate political contributions and expenditures may be approved only if designed to promote the interests of the Company and its shareowners, without regard for the private political preferences of the Company’s officers.
D. Lobbying activities
UPS exercises its right to participate in the public policy process in order to advance the best interests of the Company and its shareowners. The UPS Public Affairs department is responsible for coordinating the Company’s lobbying activities, including engagements with federal, state, and local governments. All lobbying activities are conducted only with the prior approval of the Company’s Public Affairs department, which works with senior management to focus our involvement at all levels of government on furthering the Company’s business objectives and our goal of protecting and enhancing shareowner value. The President of UPS’s Public Affairs Group regularly reviews all UPS lobbying activities and regularly reports to the board of directors concerning lobbying and political activities.
The Company complies with all current applicable laws and regulations relating to the reporting requirements for political contributions and lobbying activities.
- The Company’s federal lobbying reports can be found on the websites of the Clerk of the House and the Secretary of the Senate, currently located at: http://lobbyingdisclosure.house.gov/ and http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm. The reports provide information on activities associated with influencing legislation through communications with any member or employee of a legislative body or with any covered executive branch official. The reports also provide disclosure on expenditures for the quarter, describe the specific pieces of legislation that where the topic of communications, and identify the individuals who lobbied on behalf of the Company. The Company files similar periodic reports with state agencies reflecting state lobbying activities which are also publicly available.
- On a semi-annual basis, UPS will publish on its website at https://investors.ups.com all federal and state contributions and expenditures made by the Company in the United States pursuant to this policy. For the purpose of this paragraph, the words "contributions" and "expenditures" shall include direct and indirect monetary contributions to candidates, as defined by 26 U.S.C. § 162(e)(1)(B), and contributions to political committees, ballot measures and political parties. The report shall address compliance with this policy.
- UPS will request trade associations that received from UPS total payments of $50,000 or more in a given year to report the portion of UPS dues or payments used for expenditures or contributions that if made directly by UPS would not be deductible under Section 162(e)(1)(B) of the Internal Revenue Code. The Company will disclose such information received from such trade associations semi-annually on the UPS website. Prior to publication, the report shall be presented to the Nominating and Corporate Governance Committee of the UPS Board of Directors.
The policy will be reviewed periodically by the Nominating and Corporate Governance Committee of the UPS Board of Directors. Amendments to this policy must be approved by the Nominating and Corporate Governance Committee.