Political and Lobbying Activities
Background and guidelines
Booz Allen engages in U.S. political and lobbying activities in ethical and responsible ways to advocate for the company’s business interests. The personal preferences of individual employees or directors have no bearing on the company’s political and lobbying activities and payments.
Government Relations manages the company’s political and lobbying activities. Booz Allen maintains a robust compliance program with internal controls to ensure political and lobbying activities are conducted and disclosed in compliance with applicable laws and company policies.
Booz Allen’s Board of Directors has oversight of the company’s political and lobbying activities and meets at least annually with the Head of Government Relations. The Nominating and Corporate Governance Committee of the Board of Directors approves the company’s reports on political spending and trade association memberships. The executive-level Enterprise Responsibility & Sustainability Committee, with authorities delegated by the Nominating and Corporate Governance Committee, manages these annual reports and monitors related company policies, practices, and systems.
Company Political Contributions and Expenditures
Booz Allen does not contribute company funds to any political party, committee, or candidate for federal office. Booz Allen does not make independent political expenditures in direct support of, or in opposition to, campaigns, and the company does not make payments to influence the outcome of ballot measures. Booz Allen’s annual political spend report provides a summary of political contributions and expenditures.
Booz Allen Political Action Committee
The Booz Allen Hamilton Inc. Political Action Committee (Booz Allen PAC) is a voluntary, nonpartisan organization that operates in accordance with U.S. campaign finance laws as well as its own bylaws and policies. The Booz Allen PAC is organized to support candidates running for federal office who are aligned with the company’s positions on key issues directly related to our business and industry. The Booz Allen PAC maintains a bipartisan distribution strategy and does not contribute to presidential candidates or to candidates at the state and local levels.
Booz Allen PAC disbursements are funded entirely by voluntary personal contributions from eligible Booz Allen employees and family members, members of the company’s Board of Directors, and company stockholders. Booz Allen uses its general treasury funds to pay the establishment, administration, and fundraising costs of the Booz Allen PAC, as permitted by law, but Booz Allen cannot and does not contribute company funds to the Booz Allen PAC’s disbursement account.
The Booz Allen PAC is managed and governed by its own board of directors, which is chaired by the Head of Government Relations and composed of leaders from across the company. Booz Allen PAC activities are not influenced by direction from company leadership. The Booz Allen PAC’s board of directors meets quarterly and is responsible for ensuring that disbursement recipients meet the Booz Allen PAC’s established support criteria. The Head of Government Relations briefs the company’s Board of Directors annually on Booz Allen PAC activities. Booz Allen PAC disbursements are reported to the Federal Election Commission. These reports are available to the public at http://www.fec.gov.
Company Lobbying Activities
Booz Allen’s Government Relations team represents Booz Allen in direct engagements with members of Congress, Executive Branch officials, and select trade associations to provide meaningful input on policy, regulatory, and legislative issues that affect the company.
In compliance with the federal Lobbying Disclosure Act, Booz Allen reports all lobbying activities and expenses to Congress quarterly. These reports include full lists of federal lobbyists and the issues on which they lobby. They are available to the public via the Office of the Clerk of the U.S. House of Representatives website.
Trade Associations
Booz Allen joins a select number of trade associations in support of our strategic business objectives. Booz Allen employees can maintain individual trade association memberships so long as the association and employee activities comply with company policies.
Company payments to trade associations are typically associated with membership fees or dues, event and program sponsorships, and individual employee memberships and professional development. A trade association payment does not mean Booz Allen agrees with the trade association’s lobbying activities.
Booz Allen publishes annually on our website a report on trade associations for which the company’s annual membership dues totaled $50,000 or more. A trade association may choose to allocate a non-deductible percentage of its membership dues to lobbying activities. Booz Allen discloses this percentage in the report. In accordance with federal law, the company accounts for the non-deductible percentage in quarterly reports to Congress on lobbying expenditures. These are available to the public via the Office of the Clerk of the U.S. House of Representatives website.
Employee Activities
Booz Allen encourages employees to be informed about public policy issues and respects their right to participate in the political process on a personal basis in accordance with all applicable laws and company policies, including the Code of Business Ethics & Conduct and the Political Activities & Lobbying policy. Individual employees may make contributions to candidates, parties, or other political organizations pursuant to applicable federal, state, and local laws or otherwise engage in political activities, but those contributions and activities are private in nature and do not necessarily reflect the perspective of Booz Allen. The company will not take any adverse employment action against an employee based on their personal political affiliation or lawful political activity.
