Political Disclosure and Accountability
We believe that supporting candidates who understand the company’s legislative initiatives and policies is appropriate and is in the best interest of our customers, employees and shareholders.
In connection with this activity, Dell embraces a policy of strict adherence to federal and state campaign finance laws and regulations, governing political contributions, and the disclosure of those contributions. Pursuant to federal law, employees established a separate, segregated fund or political action committee (PAC), which is supported solely by voluntary contributions from eligible employees, spouses of eligible employees and shareholders, who collectively choose to allocate those contributions to federal and state candidates and committees.
Dell and Dell PAC’s political spending reflects company, employee and shareholder interests and not those of our individual officers or directors. This year we posted our U.S. Trade Association Dues for the first time in Dell’s history.
Dell belongs to several trade associations and pays regular dues to these groups. Dell does not normally make additional, nondues contributions to these organizations to support the groups’ political activities. If we make payments to trade associations that are designated for political purposes and are beyond the required annual dues, we disclose such contributions publicly.
Dell will inquire and make a reasonable effort to obtain from the trade associations what portion of the company’s dues or payments were used for lobbying expenditures or political contributions that, if made directly by Dell, would not be deductible under Section 162(e)(1) of the Internal Revenue Code.
For a complete picture of our political spending policy and practices, see our Public Policy information. To access databases of financial contributions to political campaigns and organizations, see the websites of the Federal Election Commission at www.fec.gov, the Center for Responsive Politics at www.opensecrets.org and the Center for Public Integrity at http://www.publicintegrity.org/
Strategic Council on Sustainable Opportunities
Our company’s leadership is strategically implementing a sustainability governance model to ensure executive awareness and alignment around key risk areas. Continuing with the evolving process, the Dell Leadership Team and Board of Directors are kept apprised of the various risks and opportunities.
By using shareholder insight and support, customer feedback and internal policies and procedures, we continue to address the material issues across the business.