Oversight, Accountability, and Visa Inc. Political Participation, Lobbying and Contributions Policy
The Board of Directors of Visa Inc., acting through the Nominating and Corporate Governance Committee, is responsible for overseeing our lobbying activities and political contributions. The Nominating and Corporate Governance Committee has approved a comprehensive Political Participation, Lobbying and Contributions Policy to:
- (a) promote ethical and transparent political engagement by Visa,
- (b) ensure that our political spending enhances shareholder value, and
- (c) facilitate our compliance with applicable laws and reporting requirements.
Visa's Government Relations Department is responsible for implementing the Policy, developing and maintaining procedures to support the Policy, and monitoring the operation and effectiveness of the Policy. Download a copy of the Policy.
Under the Policy:
- The Nominating and Corporate Governance Committee must pre-approve the use of corporate funds for political contributions, including contributions made to trade associations to support targeted political campaigns, contributions to tax exempt organizations for political activities, and contributions to organizations registered under Section 527 of the U.S. federal tax code to support political activities.
- Visa's Government Relations Department must prepare and present to the Committee an annual report itemizing our political contributions, and disclose that report on our website. As part of our annual Political Contributions report, the company must make reasonable efforts to obtain from U.S. trade associations whose annual membership dues exceed $25,000 the portion of such dues that are used for political contributions. Links to our current and historical Annual Contributions Reports are available under the heading Political Contributions and Related Activity Disclosure below.
- Visa's Government Relations Department must also prepare and present to the Committee an annual report itemizing our lobbying expenditures, which must include information regarding our memberships in and payments to trade associations and industry groups for lobbying purposes, and tax exempt organizations that write and endorse model legislation. A list of our memberships in tax exempt organizations that write and endorse model legislation is available under the heading Lobbying below.
(We also file quarterly reports disclosing our U.S. federal lobbying activities with the Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate.)
Visa's Policy also prohibits our directors and employees from using company resources to promote their personal political views, causes or candidates, and specifies that the company will not directly or indirectly reimburse any personal political contributions or expenses.
Directors and employees may not lobby government officials on the company's behalf absent the pre-approval of our Government Relations Department. As such, our lobbying and political spending seek to promote the interests of the company and its stockholders, and not the personal political preferences of our directors or employees. Consistent with applicable law, Visa will not take any adverse employment action against an employee on the basis of his or her personal political affiliation or lawful political activity.
Corporate Political Contributions and Related Activity Disclosure
Consistent with U.S. federal law, Visa Inc. does not contribute to U.S. federal candidates, national political party committees or other federal political committees. Visa Inc. may contribute to political candidates outside the U.S. in limited instances.
We make use of corporate funds for contributions to state or local candidates in the United States, where permissible and within the limits designated by state and local laws and regulations. We also make contributions to (a) certain established and recognized associations that are organized under Section 527 of the U.S. Internal Revenue Code and are registered with the Federal Election Commission or an equivalent state regulator, and(b) to support or oppose state or local ballot initiatives or referendums, where doing so would advance our public policy objectives.
Each political contribution must be approved by the appropriate Government Relations representative (state, federal or international) where the contribution is made, to ensure that it aligns with our business interests and policy goals. In selecting recipients of corporate contributions, our Government Relations Department will consider the following factors, among others:
- The potential contributee's views, voting record and understanding of policy issues of importance to Visa, its shareholders and other stakeholders
- The potential contributee's reputation for integrity;
- The potential contributee's service in a party or legislative leadership position;
- The potential contributee's relationship to or representation of a Visa facility or a large concentration of Visa employees;
- The extent to which the potential contributee shares Visa's legislative priorities.
All decisions regarding the recipients of political contributions in the United States are made by the Head of Government Relations for the U.S. Decisions regarding political contributions outside of the United States are made by the Head of Government Relations for Asia-Pacific, which is currently the only other region outside the U.S. where Visa makes corporate contributions.
In addition, under Visa's Political Participation, Lobbying and Contributions Policy, the Nominating and Corporate Governance Committee also must pre-approve the use of corporate funds for political contributions. To meet this requirement, our Government Relations Department annually prepares and presents to the Committee for approval a proposed plan for corporate political giving for the year.
Government Relations also prepares and presents to the Committee a report detailing the company's political contributions for the prior year, which must be publicly disclosed on this website.
Our current and historic Annual Contributions Reports are listed below:
The Annual Contributions Reports include contributions made to state or local candidates and ballot measures in the U.S., trade associations to support targeted political campaigns, organizations registered under Section 527 of the U.S. federal tax code, and political parties and business forums outside of the United States. It is Visa’s policy that this disclosure requirement applies to any payments to other tax exempt organizations engaged in advocacy (including 501(c)(3), (4), and (6) organizations) if it determines that the contribution in question was used for political activities.
We note that we do not regularly sponsor advertisements that qualify as "independent expenditures" or "electioneering communications" under the U.S. federal campaign finance laws, or make contributions to individual political candidates abroad. However, in the event we do make such contributions, they must be approved in advance by the Nominating and Corporate Governance Committee (as well as our Legal Department), and disclosed in our Annual Contributions Report.
We belong to various trade associations in the U.S. and abroad and pay regular dues to these groups. We do not normally make additional, non-dues contributions to support such groups' political activities. However, in those instances where it is in our business interest to do so, the Government Relations Department will obtain the Nominating and Corporate Governance Committee's advance approval and disclose any such contributions in the Annual Contributions Report. As described above, we also will make reasonable efforts to obtain from U.S. trade associations whose annual membership dues exceed $25,000 the portion of such dues that are used for political contributions, and disclose that information in our Annual Contributions Report.
We endeavor to maintain a healthy and transparent relationship with governments around the world by communicating our views and concerns to elected officials and policy-makers. As an industry leader, we encounter challenges and opportunities on a wide range of policy matters at the federal, state and local levels in the United States, as well as internationally. Such issues may include regulations and policies on interchange, cyber security, data security, privacy, intellectual property, surcharging, payroll and prepaid cards, mobile payments, tax, international trade and market access, and financial inclusion, among others.
We engage lobbyists and partner with trade associations and other organizations to assist us in responding to these challenges and opportunities, by:
- providing access to policy-makers, political intelligence, and policy analysis;
- providing a forum for discussing important industry issues and advocating for common business interests;
- helping ensure that we have a voice in the policy-making process, particularly on matters receiving significant support from opposing parties; and
- advancing our global lobbying and advocacy strategies.
Our Government Relations Department must pre-approve these engagements and lobbying activities, and regularly reviews them to ensure that they continue to best serve our business interests and objectives.
In addition, our Government Relations Department annually prepares and presents to the Nominating and Corporate Governance Committee a report regarding the company's lobbying expenditures, which includes information regarding our memberships in and payments to trade associations and industry groups for lobbying purposes, and tax exempt organizations that write and endorse model legislation. While we do not publish this report, we do file quarterly reports regarding our U.S. federal lobbying activities and expenditures with the Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate, as required by the Lobbying Disclosure Act of 1995 and the Honest Leadership and Open Government Act of 2008. These reports are available by searching for "Visa" as a "Registrant" on the U.S. Senate's website.
With regard to tax exempt organizations that write and endorse model legislation, we are not currently a member of any such organization, other than The Council of State Governments. In 2016, Visa contributed $8,500 in membership dues to The Council of State Governments.
Visa Political Action Committee
In the United States, we also sponsor a federal Political Action Committee (PAC) pursuant to the Federal Election Campaign Act, as amended, and the regulations promulgated by the Federal Election Commission. The Visa PAC enables Visa employees to voluntarily pool their financial resources to support federal, state and local political candidates and organizations.
Visa PAC contributions and expenditures are publicly disclosed on government-agency websites, including the Federal Election Commission's website (www.fec.gov). In addition to the disclosure of Visa PAC contributions on government websites, interested parties may monitor our federal PAC contributions through the websites of the Center for Public Integrity and the Center for Responsive Politics below:
Visit Open Secrets website
Visit Public Integrity website
The Visa PAC is governed by its board of directors, which appoints the officers of the PAC and supervises and directs the PAC's administration, solicitation campaigns, contributions, and compliance with applicable law and the PAC Bylaws.
Recipients of Visa PAC contributions are selected based upon the same criteria referenced under Political Contributions and Related Activity Disclosure above, and any other factors the Visa PAC board may develop.