Our experience has taught us that engagement – reaching out, listening and having authentic dialogue – is the best path to good outcomes. IBM does not espouse a partisan or political point of view. Alone among our major competitors, we do not make political contributions, and we do not endorse candidates for office. We never have.
But if IBM does not have politics, it does have values. IBMers believe in helping our clients succeed beyond even their own expectations; in innovation that matters to the world; in building relationships based on trust and personal responsibility. And we have always led the world of business in diversity, inclusion and tolerance. Inspired by those values and that legacy, I offer every government leader with whom I engage innovative ideas to address national challenges.
This is what we do. It has been our ethos for more than a century.
IBM Chairman, President and CEO
Excerpt from open letter to IBM employees, 2017
IBM’s core values include a commitment to trust and personal responsibility and a pursuit of innovation that matters to our company and the world. Consistent with these principles, IBM is committed to leading on public policy issues that are relevant to IBM and the world. IBM Government and Regulatory Affairs (GRA) provides worldwide leadership and expertise in advocating and advancing the public policy interests of IBM, its shareholders and employees with governments.
IBM also is committed to meaningful management, oversight, and accurate reporting with respect to our engagement with government officials, and we consistently seek to provide our stockholders with relevant data regarding our public policy engagement.
Our values also reflect the corporation’s long-standing policy against political contributions of any kind, even when permitted by law.
- does not have a PAC (Political Action Committee),
- does not engage in independent or electioneering communications as defined by law, and
- does not provide any financial support to political parties or candidates, directly or indirectly.
IBM is proud of the consistently high ratings it has received from independent analysts who examine corporate practices on lobbying and political spending, such as:
Read IBM’s policies and practices with regard to public policy matters, including lobbying activities and expenditures, below.
Business conduct and ethics
IBM is committed to principles of business ethics and lawful conduct. It is IBM’s policy to conduct itself ethically and lawfully in all matters and to maintain IBM’s high standards of business integrity. Every IBM employee worldwide must take annual training on IBM’s Business Conduct Guidelines and certify their compliance. According to IBM’s 2017 Corporate Responsibility Report, 100 percent of IBMers around the world completed the BCG course, currently available in 25 languages.
Employees must at all times comply with IBM’s business conduct and related guidelines. Violation of any IBM guideline is cause for discipline, including dismissal from the company. Employees should consult their management immediately if they have any question whether their actions could violate an IBM guideline.
It is IBM’s practice to voluntarily and promptly disclose known violations of government procurement laws to appropriate officials of government. In the event that IBM benefited economically from such known violations, it is our practice to reimburse the government customer accordingly. IBM employees should immediately make known to appropriate levels of management, either directly or through the Open Door or Speak-Up programs, any and all allegations of violations in connection with any government contract.
The Senior Vice President and General Counsel is responsible for providing specific instructions regarding business conduct and ethics and, as appropriate, directing periodic reviews, including business conduct guideline certification programs, to ensure compliance. Each operating unit or subsidiary is responsible for implementing such instructions, including administering certification programs.
Our commitment to ethics extends to our business partners. Any business that wants to partner with IBM is required to comply with IBM’s PartnerWorld Code of Conduct.
Political campaign contributions and expenditures
IBM has a long-standing policy not to make contributions of any kind (money, employee time, goods or services), directly or indirectly, to political parties or candidates, including through intermediary organizations, such as political action committees, campaign funds, or trade or industry associations. This policy applies equally in all countries and across all levels of government, even where such contributions are permitted by law. This policy is reflected in IBM’s Business Conduct Guidelines.
Contributions which are not permissible either as direct IBM payments or employee expense reimbursements include:
- Campaign contributions to political candidates, their election campaigns, or political parties.
- Contributions to any intermediary organization, including trade and industry associations, where those funds will be provided to candidates for public office, political parties or other intermediaries for the purpose of funding political candidates, their election campaigns, independent expenditures or electioneering communications, or political parties.
- Purchase of tickets or other payment for events where a portion of the funds will be used, directly or indirectly, to fund political candidates, their election campaigns, independent expenditures or electioneering communications, or political parties.
Because of IBM’s policy on political contributions and expenditures, IBM does not have a Political Action Committee and does not engage in independent expenditures or electioneering communications as defined by law.
Public policy expenditures and lobbying
IBM may make expenditures to support or advocate particular viewpoints on public policy issues, including expenditures for intermediaries that advocate on IBM’s behalf. In addition, IBM occasionally may seek the participation of IBM employees, on a voluntary basis, in conveying the IBM position to public officials when the issue may have a significant impact on IBM or its employees and participation is in IBM’s best interest. Public policy advocacy involving expenditures or the participation of IBM employees requires the prior approval of IBM Government and Regulatory Affairs and appropriate legal counsel.
IBM engages in lobbying on issues of importance to its business, clients, shareholders, and employees. IBM’s recent lobbying activities have focused on a variety of issues in the areas of: technology policy, including research & development, cybersecurity, privacy regulation, health-related information technology, and technology procurement; budget and appropriation matters; intellectual property, including patents, copyright, and trademarks; various defense matters; education, workforce training, and related legislative and regulatory matters; financial services regulation; labor, workplace, and benefits policy; domestic and international tax issues, including tax treaties; and various international trade issues, including multilateral and bilateral trade agreements. The Key Issues page of this web site identifies IBM’s current policy priorities.
IBM conducts its lobbying activities in accordance with applicable law and the requirements in Section 6 of IBM’s Business Conduct Guidelines. All IBM lobbying activities require the prior approval of IBM Government and Regulatory Affairs. IBM files periodic reports with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives detailing its U.S. federal lobbying activities and expenditures. These reports are available here. As reflected in these reports, IBM’s total lobbying expenditures for the last three calendar years are as follows:
- 2018: $4,380,000;
- 2017: $5,310,000;
- 2016: $4,040,000; and
- 2015: $4,630,000.
IBM also files lobbying reports with U.S. state and municipal governments, where required, and with the European Union Transparency Register. In its most recent filing, IBM’s total spending on lobbying with the EU institutions was between €1.75 and €2 million.
Periodically, IBM Government and Regulatory Affairs reports to the IBM Board of Directors about the company’s policies and practices in connection with governmental relations, public policy, and related expenditures.
Public policy positions
IBM Government and Regulatory Affairs is a globally integrated corporate function responsible for managing IBM’s public policy issues and government relations worldwide. With dedicated resources in the Americas, Europe, Africa, and Asia, IBM Government and Regulatory Affairs pursues mutual objectives of global consistency and local relevancy in supporting IBM’s growth and business operations. IBM Government and Regulatory Affairs works with governments on key economic, governmental, and societal issues, helping them solve problems and create strategies for the future. An overview of IBM’s key policy positions is available here.
Trade and industry associations
IBM belongs to a number of trade associations worldwide, representing the interests of the technology industry, of industries that are major clients of IBM, and of the broader business community. These organizations work to bring about industry consensus and advocacy on major public policy issues. In the United States, the principal trade associations in which IBM holds membership include:
- Advamed — Advanced Medical Technology Association
- Aerospace Industries Association
- Alliance for Competitive Taxation
- BSA — The Software Alliance
- Business Roundtable
- Coalition of Service Industries
- Council of the Americas
- The ERISA Industry Committee
- Healthcare Information Management and Systems Society
- HR Policy Association
- Information Technology Industry Council
- National Foreign Trade Council
- Retail Leaders Industry Association
- Semiconductor Industry Association
- Technology CEO Council
- US Chamber of Commerce
- US-ASEAN Business Council
- US-China Business Council
- US Council for International Business
Laws and regulations with regard to trade association lobbying disclosure vary by country. In the United States, the Lobbying Disclosure Act requires that IBM include in its LD-2 quarterly filings the amount of IBM’s dues payment to trade associations that is devoted to lobbying expenditures.
Our policy restricts trade and industry associations from using IBM funds to engage in political expenditures. IBM has procedures to ensure that IBM payments to trade or industry associations comply with this policy. These procedures include IBM providing written communication of IBM’s restrictions to the association.
IBM joins trade and industry associations that add value to IBM, its stockholders and employees. These groups have many members from a wide variety of industries, and cover very broad sets of public policy and industry issues. As a result, there may be occasions where the views of a particular association on one or more specific issues are different than IBM’s views. On these occasions, IBM regularly shares its dissenting views within its trade associations and, when helpful to the policy debate, in public fora.
Employee public service and political activity
IBM encourages all employees to pursue personal interests, including active participation in their communities. If IBM employees choose to participate in political activity, they do so as individuals and not company representatives. IBM will make reasonable accommodations for employees to take vacation or reasonable time off without pay to pursue such activity. Because IBM does business with many levels of government, we have instituted policies and procedures designed to avoid conflict of interest situations for IBM employees engaged in public service, as described in Section 7 of IBM’s Business Conduct Guidelines.
For more than a century, IBM has been an employer and investor in the countries and communities where it does business, including in the United States. As part of its public policy advocacy, IBM maintains a network of Senior State and Senior Location Executives in most every U.S. state and territory who, in addition to their normal business responsibilities, also help to represent IBM in the communities where we operate.
Working under the direction of IBM Government and Regulatory Affairs and IBM Corporate Citizenship, these executives may represent the company at local community events, in state and local business organizations, and with state and local government officials. At least once a year, the Senior State and Senior Location Executives are invited to Washington to participate in a two-day advocacy event organized by IBM Government and Regulatory Affairs, where they are briefed on public policy issues and hold meetings with Members of Congress from their home states and districts.
From time to time, these executives will work with IBM Government and Regulatory Affairs to host elected officials at IBM facilities across the United States to be briefed on the company’s business activities or technology developments. However, as specified in Section 6.6 of the Business Conduct Guidelines, political campaigning or electioneering is not permitted on IBM property. The time and expenses of IBM personnel who engage in grassroots lobbying are tracked by IBM Government and Regulatory Affairs and included in IBM’s quarterly Federal lobbying reports.
U.S. state government lobbying
IBM is one of the largest technology employers in the United States and has a presence or employees in every U.S. state and territory. IBM has key locations in New York, North Carolina, Massachusetts, Georgia, Texas, Colorado, California, Iowa, Missouri, Louisiana, Ohio, Arizona, Michigan, and West Virginia. The company has a single state government affairs leader, based in Chicago, who monitors and coordinates IBM advocacy with state governments across the United States. This is chiefly accomplished through the IBM network of Senior State and Senior Location Executives mentioned above, and through law firms or external lobbying firms contracted by IBM and located in state capitals.
The range of public policy issues that IBM has addressed at the state level in recent years has included taxation, employment law, technology regulation, economic development, and government procurement. For example, in recent years the company has taken an active role in lobbying legislatures in Texas, North Carolina and other states against proposed legislation that would discriminate against individuals based on gender identity. Where required by law, IBM files lobbying disclosure reports with state governments.