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.

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

• To determine if a federal candidate is eligible for Medtronic PAC contributions, candidates should first demonstrate behavior consistent with the values outlined in the Medtronic Mission and the principles of American democracy before being evaluated against criteria such as key committee assignments, leadership, a history of support for Medtronic and industry-related issues, and constituent representation.
• The Medtronic PAC Board of Directors approves all disbursements.
• The Medtronic PAC does not support Presidential candidates at any stage in the campaign process.
• The Medtronic PAC 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.

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 and candidate evaluation criteria. In addition, on an annual basis the Nominating and Corporate Governance Committee of the Board of Directors reviews corporate political contributions.

Medtronic adheres to all state and federal laws regarding disclosure of corporate contributions for political activities and Medtronic 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 Medtronic PAC and, commencing in 2012, all dues in excess of $25,000 paid to trade associations and other tax-exempt organizations. Please use the following links to review our reports:

Questions about political contributions can be directed to our Vice President, Government Affairs, 950 F Street, NW, Suite 500 Washington, DC 20004.