Political Engagement Report

AT&T is a proud member of the communities where we live and work.  We strive to bring our customers the innovation they demand, provide shareholders value on their investment, and be a responsible corporate citizen.

 

A critical component of these efforts is actively participating in the political process.  We do this through corporate political contributions, memberships in trade associations, contributions to other tax-exempt organizations, employee political action committee (PAC) contributions, and lobbying expenditures.

In this Report, we provide important information on how we participate in the political process.  Every action we take is in strict compliance with local, state and federal law, but that is only the beginning.  Our decisions are grounded in AT&T’s public policy positions and the best interests of our business and our employees, without regard to political party affiliation and always mindful of our Core Values, our Code of Business Conduct, and our Political Engagement Policy.  In addition, the Public Policy and Corporate Reputation Committee of the Board of Directors provides effective oversight, and we have a robust internal authorization process for all of these activities.  Together, these processes and protections are directed to one purpose: to ensure we have an effective, responsible voice in policy discussions that impact our business, our employees, and our customers.

Twice yearly, in accordance with applicable law, campaign finance and disclosure rules, and our own internal policies, we publicly disclose U.S. political contributions via this Report.  We also identify organizations that report using some or all of our contributions for lobbying activities.

This Report provides historical information for the applicable period.  Past support of a candidate or an organization does not mean that the Company and/or its employee PACs are providing similar support today.  The Company and its employee PACs reserve the right to discontinue support of any recipient and have discontinued giving to some recipients listed in this Report.

To view our full contributions report, see the contributions section below.
 

Past Reports
 

We maintain an archive that includes political contribution reports for the past 5 years. They can be found in our Social Responsibility Reporting Library and Archive.

 

 

Positions and Policy

 

Public Policy Positions

 

Public policy creates the “rules of the road” for companies like AT&T, and now, more than ever, we need these rules to keep pace with the drivers — relentless innovation and limitless possibilities.

To encourage public policies that help us deliver the best entertainment and communications experiences, AT&T contributes prudently to state and local candidates and political organizations, as permitted by law, when such contributions advance AT&T’s business objectives and the interest of our shareholders.

Officers, executives or committee members making contribution decisions are mindful of our Core Values and make recommendations and decisions without regard for personal political preferences.  

Further, no contributions are made in anticipation of, in recognition of or in return for any act or favor.

Additional information on many of AT&T’s public policy positions can be found in the issue briefs located on the Company’s public policy main page, our corporate responsibility website and the AT&T Forum.

 

Political Engagement Policy

 

Our Political Engagement Policy is publicly available, and it details how we make the decision to contribute, to whom we contribute and which corporate leaders approve these expenditures.

AT&T personnel consult with the AT&T Legal Department to ensure that contributions are lawful and consistent with applicable statutes, regulations, limits and guidelines.

Related Quick Links
 

Contributions
 

Corporate Political Contributions
 

Political contributions, where permitted, are an important part of the political process. This Report is intended to provide transparency regarding our corporate contributions, as well as contributions made by our employee PACs. To summarize:

  • Our employees can participate in the political process through employee PACs. PAC disbursements support federal and state candidates and are disclosed in this Report.
  • Where lawful, we make corporate political contributions to state and local candidates, political parties, PACs and ballot measure committees. Those contributions are disclosed in this Report.
  • We do not make corporate political contributions to federal political parties or candidates for federal office.
  • As a general practice, we do not make independent political expenditures or corporate political contributions to independent expenditure committees or to any non-candidate or non-political-party political committee organized under Section 527 of the Internal Revenue Code (e.g., Super PACs); however, if we do, we disclose them in this Report.

In addition, our disclosures extend beyond political contributions. When a trade association or other tax-exempt organization uses our contributions for lobbying activities, we disclose them as described below.

Our latest contributions and disclosures can be accessed through the links found in the remainder of this Report.

AT&T  

WarnerMedia  


Trade Association and Other Tax-Exempt Organization Contributions
 

AT&T contributes to trade associations and other tax-exempt organizations, including those organized under Internal Revenue Code Section 501(c)(6), that promote matters of importance to the industry on behalf of their members. We disclose organizations to which we contribute $50,000 or more where a portion of those contributions has been identified as used for lobbying.

We make a reasonable effort to obtain from these organizations, or through other means, the portion of the Company’s payments that the organization allocates to lobbying expenditures, and we disclose those amounts.

AT&T

WarnerMedia
We also contribute to tax-exempt advocacy organizations that engage in political activities, such as those organized under Internal Revenue Code Section 501(c)(4), where those organizations’ missions align with our policy interests. If a portion of our contribution has been identified as used for lobbying, we identify that organization in our disclosures. We make a reasonable effort to obtain from these organizations, or through other means, the portion of the Company’s payments the organization allocates to lobbying expenditures and we disclose those amounts.

AT&T
WarnerMedia


AT&T supports organizations that have significant public policy positions that impact our industry. We review differing policy issues and those are taken into consideration when determining annual membership. Our participation in these various industry, trade and advocacy groups comes with the understanding that we might not always agree with all positions held by the larger organization and/or other members, and that we are committed to voicing our concerns as appropriate through the AT&T leaders who interact with these organizations, many of whom serve on the boards and committees of these organizations.


Employee PAC Contributions
 

AT&T employee PACs are voluntary and non-partisan and provide eligible AT&T management employees an opportunity to collectively support public policy positions that are important to AT&T. In all, there are 30 separate state employee PACs and a federal employee PAC. Each AT&T employee PAC has a chairman, officers, a committee of employees who are engaged in PAC operations and Articles of Operation outlining its operating procedures.

Employee PAC contribution and expenditure decisions are made by committees comprised of employees across the business. The employee PAC committees’ decisions are based on AT&T’s public policy positions and the best interests of the business and our employees. At the same time, our committees and those who make recommendations to our committees are mindful of our Core Values, our Code of Business Conduct, and our Political Engagement Policy.  All recommendations and decisions are made without regard to political party affiliation.

AT&T  

WarnerMedia

AT&T Contribution Downloads






 

WarnerMedia Contribution Downloads
 

Lobbying
 

AT&T is committed to adhering to the highest ethical standards when engaging in any political activities. As such, AT&T complies with all federal and state laws and regulations for lobbying registrations and reporting. AT&T companies, employees and external lobbyists and firms must register as lobbyists as required by applicable law to represent the Company’s interests.

All lobbying registrations and expenditures reporting are done in strict compliance with these laws.

AT&T and WarnerMedia file federal lobbying reports quarterly with the  Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate, pursuant to the federal Lobby Disclosure Act. To review the quarterly federal filings, visit the links above and select “AT&T” or “Time Warner” in the name search field.

AT&T and WarnerMedia file state lobbying reports with the appropriate state governing agencies in compliance with the requirements in respective states. These reports are publicly available in the respective jurisdictions and disclose the required lobbying information.

Related Quick Links
 

 

Governance
 

Board of Directors Oversight
 

The AT&T Inc. Board of Directors’ Public Policy and Corporate Reputation Committee (PPCRC), comprised entirely of outside directors, is responsible for oversight of AT&T’s public policy activities and corporate political disbursements. As part of the PPCRC’s oversight of AT&T’s public policy activities, the PPCRC annually reviews the Company’s policies, practices and expenditures related to political contributions, as well as contributions to trade associations and other tax-exempt and similar organizations that may engage in public policy initiatives.

Corporate Political Contributions

Each year, the PPCRC recommends, and the AT&T Inc. Board of Directors authorizes, a maximum aggregate limit for contributions that can be made by AT&T for the purpose of supporting or opposing any party, candidate, political committee, ballot measure, or any political purpose connected to the same. Contributions must be permitted by, and in strict compliance with, applicable law. For 2018, this amount is $6 million. The PPCRC receives annual reports about all political contributions made by the Company, offers guidance and provides a full report of these activities to the Board.

Trade Associations and Other Tax- Exempt Organizations

A full list of these contributions is shared with the PPCRC of the Board and the full Board on an annual basis for their review and guidance.


Executive Leadership Approval
 

AT&T’s Senior Executive Vice President and General Counsel, who reports directly to AT&T Inc.’s Chairman and Chief Executive Officer, is responsible for overall management and participation in the political process. Support for candidates and organizations is based on corporate public policy.

Corporate Political Contributions

AT&T personnel consult with the AT&T Legal Department to ensure that proposed contributions are lawful and consistent with applicable statutes, regulations, limits and guidelines. Political contributions are reviewed and approved as to lawfulness by the AT&T Legal organization prior to being authorized.

All corporate political contributions must be approved by the Chief Executive Officer of the operating company making the request, or by a delegate if the amount is $2,500 or less.

Similarly, the Chief Executive Officer of AT&T Inc., or a delegate if the amount is $2,500 or less, must approve all corporate political contributions requested by AT&T Inc. A report of all political contributions, regardless of amount, is reviewed quarterly by AT&T Inc.’s Chairman and Chief Executive Officer and annually by the Board.

Trade Associations and Other Tax-Exempt Organizations

AT&T has a rigorous approval process for contributions to trade associations and other tax-exempt advocacy organizations. Each proposed contribution must be in the best interests of the Company and our shareholders.

These contributions must be approved by the Senior Executive Vice President and General Counsel or other senior leaders. A full list of these contributions is shared with the PPCRC of the Board and the full Board on an annual basis for their review and guidance.


Compliance
 

AT&T has established strict internal policies, processes and compliance measures to ensure adherence to legal and regulatory requirements.

We employ a rigorous system for requesting, evaluating, processing and authorizing all contributions. This mechanized system, which requires individual attention to each separate contribution request, manages contribution budgets and tracks spending levels to ensure compliance. 

Every political contribution request is legally reviewed and all contributions are approved by management in strict compliance with our policy and procedures for contributions.

AT&T facilitates compliance with our policies and procedures regarding political activities, contributions and lobbying through regular training and reminders, periodic internal audits, and employee acknowledgments regarding compliance with AT&T’s policies governing political activities.

Specifically, the Code of Business Conduct includes provisions regarding political activity and contributions that provide guiding principles and practical application for employees. The Code of Business Conduct is available and reviewed by employees.

AT&T encourages our employees’ voluntary, personal participation in the political process, whether by voting, volunteering time, holding public office or contributing money to the candidates of their choice.

However, there are strict laws that apply to corporate involvement in the political process, and it is important that employees’ personal political activities are separate from their responsibilities to the Company.

AT&T has a policy that instructs employees to maintain separation between their personal political activities and their activities on behalf of AT&T. Employees are advised that personal political activities must never occur on Company time, and no Company resources can be used.

It is the unequivocal policy of AT&T that no employee will be subject to any form of pressure, coercion or intimidation related to participation in political activities, nor shall any employee receive compensation or benefits for participating in personal political activities.


Past Reports

 

We maintain an archive that includes political contribution reports for the past 5 years. They can be found in our Social Responsibility Reporting Library and Archive.