IBM 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.
IBM is proud of the consistently high ratings that 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 lobbying activities 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:
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.
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 may occasionally 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 various issues in the areas of: technology policy, including research and 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.
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 US Senate and the Clerk of the US House of Representatives detailing its US federal lobbying activities and expenditures. You can access these report here (link resides outside ibm.com)3. As reflected in these reports, IBM’s total lobbying expenditures for the last six calendar years are as follows:
IBM also files lobbying reports with US state and municipal governments, where required, and with the European Union Transparency Register (link resides outside ibm.com)4. In its most recent filing, IBM’s total spending on lobbying with the EU institutions was between EUR 1.75–2 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.
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 US 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.
IBM is one of the largest technology employers in the United States and has a presence or employees in every US state and territory. IBM has key locations in New York, North Carolina, Massachusetts, Georgia, Texas, Colorado, California, Louisiana, Ohio, Michigan and West Virginia.
IBM’s advocacy work with state governments is accomplished through the IBM network of Senior State and Senior Location Executives 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. Where required by law, IBM files lobbying disclosure reports with state governments.
All links reside outside ibm.com
1 The Center for Political Accountability, in conjunction with the Zicklin Center for Business Ethics Research at The Wharton School of the University of Pennsylvania
2 Transparency International UK
3 Lobbying Disclosure Act (LDA) Reports
4 European Union Transparency Register