Public sector decisions significantly affect our business and industry, as well as the communities in which we operate. For this reason, we participate in the political process through regular and constructive engagement with government officials and policy-makers, by encouraging the civic involvement of our employees, and by contributing to state and local candidates and political organizations where permitted by applicable law.
We are committed to conducting these activities in a manner that reflects responsible corporate citizenship and best serves the interests of our shareholders, employees, and other stakeholders. Additional information regarding our political activities and oversight may be found below and by clicking on the links on this page. Learn more about our governance structure and practices.
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:
promote ethical and transparent political engagement by Visa,
ensure that our political spending enhances shareholder value, and
facilitate our compliance with applicable laws and reporting requirements
Visa's Global Government Engagement Department is responsible for implementing the Policy, developing and maintaining procedures to support the Policy, and monitoring the operation and effectiveness of the Policy. Read about 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 Global Government Engagement 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 will provide a list of the names all U.S. trade associations to which Visa pays annual membership dues that are $25,000 or more, and if applicable, we will disclose 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 Global Government Engagement 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 Engagement 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.
The Annual and Semiannual 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 Engagement Department will obtain the Nominating and Corporate Governance Committee's advance approval and disclose any such contributions in the Annual Contributions Report. As part of our annual Political Contributions report, the company will provide a list of the names of all U.S. trade associations to which Visa pays annual membership dues that are $25,000 or more, and if applicable, we will disclose the portion of such dues that are used for political contributions.
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. We also seek to advance policies that expand the use of and access to electronic payments. We devote political resources to many issues that impact the payment industry, including: payment innovation; interchange; cyber security, information sharing, and cyber threats; payment card security, data security, and data breach; privacy and data use; network brand risks; intellectual property; surcharging; payroll and prepaid cards; mobile payments; tax; international trade and market access; small business issues 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 Engagement 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 Engagement 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 2021, Visa contributed $10,000 in membership dues to The Council of State Governments.
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:
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.