Medtronic, Inc. - Corporate Governance - Environmental, Health and Safety 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.

To encourage the advancement of public policy that supports our Mission, Medtronic has established the Medical Technology Fund ("MTF"), an employee-based, voluntary, non-partisan political action committee. The MTF, 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 to federal candidates. The following is a summary of the guidelines:

To determine if a federal candidate is eligible for MTF 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 Board of Directors approves all disbursements.
The MTF does not support Presidential candidates at any stage in the campaign process.
The MTF reports all financial activity as required by law to the Federal Election Commission.

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.

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 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. Further, the MTF 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.

In the interest of transparency to our shareholders, we are making available a list of all political contributions made by Medtronic and the MTF. This list will be updated and made available via this website annually.

Questions about political contributions can be directed to our Vice President, Government Affairs, 1420 New York Ave., NW, Ste. 600, Washington, D.C. 20005.