On issues for which Xerox’s experience and knowledge add an important perspective to public debate, the company provides input and advice to policy makers, both directly and indirectly, through various coalitions and trade associations. Xerox, primarily through the Office of Global Government Affairs, has interactions with governments and government organizations throughout the U.S. (at the federal, state and local levels) and around the world. We discuss issues that range from legal, trade, tax policy and financial activities to regulatory compliance, intellectual property and procurement.
Trade associations around the world often play an important role in assisting our company with business development opportunities and citizenship activities, as well as in helping Xerox meet certain public policy objectives. Xerox is a member of a wide array of trade associations. Any trade association dues, or portions thereof, that are not deductible for tax purposes are reported in Xerox’s lobbying disclosure reports. Xerox senior managers play a leadership role in various organizations, such as the Business Roundtable, the U.S. Chamber of Commerce and the Technology CEO Council. These organizations develop and promote public policies that are considered important to Xerox’s public policy interests and operations.
Here are examples of public policy issues that Xerox follows closely:Environment
Xerox is a member of the U.S. Environmental Protection Agency’s Climate Leaders Program and the Business Roundtable’s Climate RESOLVE program. Both are voluntary initiatives to help companies develop long-term strategies for climate change. We also helped create and design the ENERGY STAR® program for imaging equipment, which is intended to ensure maximum energy efficiency in imaging products.
Xerox has actively promoted and participated in the creation of the European voluntary agreement to improve the environmental performance of imaging equipment, which commits producers to comply with strict environmental requirements in the design of their products above and beyond legal requirements.
Xerox is also actively engaged with European regulators in the creation of an EU ecolabel for imaging equipment and supplies and in the harmonization of public purchasing requirements for such equipment.Retirement Policy
We believe policy makers should foster a legal and economic framework that encourages employers to maintain and increase the number of workers who have access to employer-provided retirement security. We continue to advocate for legislation and regulation that allow us to meet our obligations to our current and former employees.Dodd-Frank Implementation
Xerox has been working to ensure that new rules implementing the Dodd-Frank law do not harm Xerox’s ability to hedge against interest rate volatility within our pension plans. Xerox takes our commitment to our employees, both current and retired, very seriously and will work to ensure that the implementation of Dodd-Frank does not hinder our ability to meet those commitments.Healthcare Reform
Comprehensive healthcare reform is essential for the long-term vitality of the U.S. economy. While the healthcare law passed in 2010 has some positive elements, significant reform continues to be needed to create a sustainable, high-quality system that is more accessible, less costly and more patient-centered.
- Every citizen having access to quality and affordable health coverage, which is why any reform solution must address the core issues of the growing cost of healthcare by:
– Promoting healthcare systems that are comprehensive, integrated and technologically connected
– Adhering to principles of medical necessity, patient safety, efficacy, efficiency and patient-centeredness
– Empowering individuals with accurate, transparent data on quality, value and prices of providers in order
to make individuals more-informed and responsible consumers
– Maintaining the Employee Retirement Income Security Act (ERISA), which provides employers with the
ability to offer consistent benefits to employees.
As a board member of the following professional organizations and coalitions, Xerox has taken a leadership role in the employer community on efforts to reform the U.S. healthcare system:
Corporate Health Care Coalition (CHCC): CHCC is a coalition of large, multi-state, self-insured companies focused on the implementation of the Affordable Care Act.
American Benefits Council (ABC): ABC is a trade association whose corporate members either sponsor directly, administer or service retirement, health and stock compensation plans covering more than 100 million Americans. It is staffed by a team of professionals in the benefits field with expertise in investments, retirement, health insurance, accounting, actuarial science, banking, law and benefits who represent plan sponsors to Congress, the courts and the regulatory agencies.
ERISA Industry Committee (ERIC): A trade association, ERIC represents the employee benefits and compensation interests of America’s major employers.
Xerox also is involved with several other professional organizations and associations, including:
Business Roundtable: The Business Roundtable has been actively engaged in shaping the debate on corporate tax reform, and is supportive of Xerox’s goals for reform that will enhance the ability of U.S. companies to compete internationally. Xerox participates in the policy formation and advocacy functions for the Business Roundtable’s tax reform efforts. The Roundtable has also focused heavily on developments with the most burdensome of EPA’s proposed regulations covering areas such as ozone, carbon emissions and boiler controls, proposing less-costly methods of achieving EPA’s overall environmental goals.
Consumer Purchaser Disclosure Project (Disclosure Project): Membership in the Disclosure Project is made up of many consumer and purchaser groups whose goal is to bring together the voices of consumers and purchasers to improve healthcare for all.
DigitalEurope: DigitalEurope is the pre-eminent advocacy group of the European digital economy acting on behalf of the information technology, consumer electronics and telecommunications sectors. It is dedicated to improving the business environment and to promoting industry’s contribution to economic growth and social progress in the European Union.
The President’s Export Council (PEC): The PEC is the principal national advisory committee on international trade. The Council advises the President on government policies and programs that affect U.S. trade performance; promotes export expansion; and provides a forum for discussing and resolving trade-related problems among the business, industrial, agricultural, labor and government sectors.
TechAmerica: TechAmerica is the leading voice for the U.S. technology industry, the driving force behind productivity growth and jobs creation in the nation and the foundation of the global innovation economy. It is the technology industry’s only grassroots-to-global advocacy network, with offices and partnerships in state capitals across the country, Washington, D.C., Europe and Asia and around the world. TechAmerica was formed by the merger of AeA (formerly the American Electronics Association), the Cyber Security Industry Alliance (CSIA), the Information Technology Association of America (ITAA) and the Government Electronics & Information Technology Association (GEIA).
Xerox supports open markets and free trade. International trade is a powerful engine of global economic growth; economic growth, in turn, fosters improved living conditions and opportunities around the world. We support government-to-government negotiations aimed at liberalizing trading rules and opening markets, both on a bilateral and multinational basis. We believe that rules based only on fair trade are those that are sustainable, and that all participants must be responsible citizens of the countries in which they do business.
Intellectual Property and Competitiveness
As a participant in the Coalition Against Counterfeiting and Piracy, Xerox plays an active role in combating theft of intellectual property by counterfeiters that manufacture “knock-off” products. The coalition is a strong advocate of stronger laws against dealing in counterfeit goods and has developed best-practice guidelines that help companies protect their supply chains. Through our support of the American Competitive Initiative, which directs more resources to math and science education, Xerox focuses on improving the nation’s ability to compete on the global stage. We also support necessary reforms to the U.S. patent system that serve to reduce the threats to innovation that come from frivolous litigation.
Xerox is working in support of corporate tax reform. The U.S. has the highest tax rates among large, industrialized nations. Such reform is needed if U.S. companies are to be fully competitive in overseas markets, where 95% of the world’s population lives.
Xerox promotes policy positions that make IT more effective in supporting state and local government missions, improve government technology acquisition processes, maximize the positive financial impact of IT investments, and create better outcomes for Americans served by state and local government agencies and programs. Managed by the Office of Global Government Affairs, ACS has established a network of state and local government consultants whose responsibilities includes monitoring legislation and policies that would impact our various government lines of business. Examples of our government business include annual budgets, regulation of credit card fees, health insurance exchanges, statewide and work zone speed enforcement, and electronic toll collections.
Xerox Public Policy Engagement and Political Contributions Policy
We each have an individual responsibility to live up to the highest ethical standards of business conduct. The Xerox Code of Business Conduct contains explicit information on Xerox’s policies governing contact with government agencies, lobbying and political contributions. All Xerox employees are required annually to participate in training on the Code of Business Conduct and must certify adherence to the Code upon the conclusion of the course.
Xerox and its employees have a long-standing tradition of active engagement in the communities in which we live and work. Our participation in the political process and public policy debate reflects our traditions and core values.
For nearly a decade, Xerox has had a long-standing policy that nothing of value may be given, paid, promised or offered – directly or indirectly – to any political party, committee and/or candidate for any federal, state or local government office anywhere around the world. Corporate independent political expenditures in support of or in opposition to political parties or ballot measures are also not permissible under Xerox policy. Consequently, “soft” money corporate contributions are not and have not been permitted at Xerox, even long before recent changes to campaign finance laws. In addition, Xerox does not allow any employee or consultant to provide anything of value to any government employee. This policy, too, was in place long before Congress put the standard into law for all corporations and organizations.
Xerox has an established policy that does not permit any in-kind political contributions. In accordance with our Code of Business Conduct, the only authorized method to make political contributions on behalf of Xerox is through the Xerox Corporation Political Action Committee (XPAC).
Every proposed political contribution undergoes an internal review process to evaluate whether it is legally permissible and in the best interests of our company and our shareholders. In many cases, we may not agree with every position taken by a candidate whom we support. All political spending is overseen by the General Counsel, the Vice President of Global Government Affairs and the Manager of Global Government Affairs at Xerox.
Xerox, like all major corporations, is a member of various 501(c) organizations that may engage in political activities. While Xerox may not necessarily agree with every position taken by each organization to which we contribute, we determine that the intended use of a contribution is consistent with Xerox’s core values before making a contribution to any such group. From our trade associations that receive dues or payments from us of $25,000 or more, Xerox has requested they disclose to us details about their political expenses. We also ask these same organizations to report to us the portion of Xerox dues or payments used for such expenses or contributions that, if they had been made directly by Xerox, would not be deductible under 162(e)(1)(B) of the Internal Revenue Code. To the extent it is reported to us, we disclose the non-deductible portion of our contributions.
Xerox recognizes that the use of company resources in the political process is an important issue for shareholders. Therefore, our Xerox Government Affairs group provides periodic updates on XPAC contributions and public policy issues to our Board of Directors.
Employee Involvement in Political Activities
While we encourage our people to participate in community and political activities, we do not endorse any organization or activity in which employees choose to participate and we do not discriminate in favor of or against employees based on the organizations they choose to support.
Xerox Corporation Political Action Committee
The Xerox Corporation Political Action Committee (XPAC) is supported entirely by voluntary contributions from eligible employees from Xerox and ACS, and all contributions go directly to candidate campaigns for political office. XPAC helps support those leaders and candidates who are dedicated to working with us in positive ways to develop and implement responsible public policy. In Spring 2011, we merged the ACS Good Government Committee (ACS PAC) with XPAC to create an organization for our political giving that reflects the needs of our expanding government business. XPAC contributions will promote the interests of the company and will be made without regard for the private political preferences of company officers and executives.
Every proposed XPAC contribution undergoes an internal review process to evaluate whether it is legally permissible and in the best interests of our company. In many cases, we may not agree with every position taken by a candidate whom we support.
XPAC is non-partisan and supports candidates and elected officials based on the following guidelines:
- The integrity and character of the candidate;
- The candidate’s position on significant policy issues of importance to our company;
- The candidate’s overall support for our company and industry;
- The candidate’s overall support for the free enterprise system and U.S. competitiveness;
- A demonstrated willingness on the part of the candidate to work with our company and industry to achieve responsible public policy solutions;
- The candidate’s representation of a state or district in which our company has a significant number of employees or facilities;
- The candidate holds an important committee assignment on a key committee whose actions could affect our business;
- The candidate holds a leadership position within their political party; or
- Candidate’s electability; and
- Permissibility under applicable law.
In addition, XPAC focuses on contributions that go directly to candidates for office, generally avoiding:
- Out-of-election-cycle contributions;
- Contributions to Presidential candidates at any stage in the campaign process;
- Contributions to leadership PACs;
- Contributions to political parties;
- Independent expenditures in support of or opposition to a political party or ballot measure; and
- Contributions to trade association PACs.
XPAC is led by a Board of Trustees, which includes a cross-section of managers from Xerox and ACS who represent their unique business unit and geographic areas. A Contributions Committee appointed by the XPAC Board of Trustees and consisting of between three and five members is responsible for selecting, by majority vote, the candidates to receive a contribution from XPAC. To view contributions made by XPAC, click here.
In accordance with XPAC’s Articles of Organization, an audit of the accounting books of the XPAC shall be performed at least once during every two-year election cycle to assure compliance with the Federal Election Campaign Act of 1971, as amended, and its regulations and all other applicable laws.
Xerox Contributions to 527s in 2010
The following “527” organizations received support from Xerox in 2010. The name derives from Section 527 of the Internal Revenue Code, under which these organizations are tax exempt. They also have a purely political focus, rather than one supporting an issue or cause. Xerox contributions to 527 organizations are made with corporate – rather than XPAC – funds.
- Democratic Governors Association
- Republican Governors Association
Xerox 501c(4) and 501c(6) Memberships
National trade association memberships and national 501c(4) organizations with payments exceeding $25,000 in 2010 from Xerox include:
- Business Council of New York
- The Business Roundtable
- National Minority Supplier Development Council, Inc.
- National Association of Manufacturers
- Technology CEO Council
- U.S. Chamber of Commerce