Political Contribution Policy
Medtronic encourages the advancement of sound public policy that supports our Mission. Any support for candidates is made in compliance with applicable law. Federal law prohibits corporations from making political contributions to federal candidates or party committees, but corporations may establish political action committees funded solely through voluntary employee contributions. Some jurisdictions permit corporate contributions to state and local candidates.
PAC Contributions
To encourage the advancement of public policy that supports our Mission, Medtronic has established the Medical Technology Fund PAC ("MTF PAC"), an employee-based, voluntary, non-partisan political action committee. The MTF PAC, governed by a Board of Directors comprised of employees and executives of Medtronic, has adopted by-laws and operational guidelines that include criteria for disbursements by the MTF PAC to federal candidates. The following is a summary of the guidelines:
- To determine if a federal candidate is eligible for MTF PAC contributions, the candidate is evaluated against criteria such as key committee assignments, a history of support for Medtronic and industry-related issues, and constituent representation.
- The MTF PAC Board of Directors approves all disbursements.
- The MTF PAC does not support Presidential candidates at any stage in the campaign process.
- The MTF PAC reports all financial activity as required by law to the Federal Election Commission.
AdvaMed is the only national medical device trade association of which Medtronic is a member. Medtronic pays its membership dues with corporate funds. The MTF PAC support of AdvaMed is limited by law to $5,000 per year, which is drawn entirely from the pooled voluntary contributions of Medtronic employees to the MTF PAC. Further, the MTF PAC ensures that congressional candidates that receive AdvaMed PAC support satisfy its own rigorous contribution criteria. Medtronic is also a member of several state-based industry associations, but, except as disclosed, Medtronic has declined to participate in their political action committees.
Corporate Contributions
In jurisdictions that permit corporations to make contributions to campaigns of state and local candidates or party committees, Medtronic uses the same criteria and framework to evaluate such contributions.
Under the Medtronic Corporate Contributions Policy, Medtronic may contribute corporate funds where allowed by law. Under the policy, all corporate political contributions are subject to approval by a three-member Corporate Political Fund Committee to include the Chief Financial Officer, the General Counsel and the Vice President of Government Affairs. The Committee reviews all corporate contribution recommendations based on guidelines consistent with Medtronic’s overall contribution strategy.
Disclosure
Medtronic adheres to all state and federal laws regarding disclosure of corporate contributions for political activities and MTF PAC contributions. In the interest of transparency to our shareholders, we make available semiannually a list of all political contributions made by Medtronic and the MTF PAC. Please use the following links to review our reports:
July 1, 2011 – December 31, 2011
January 1, 2011 – June 30, 2011
Questions about political contributions can be directed to our Vice President, Government Affairs, 950 F Street, NW, Suite 500 Washington, DC 20004.