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.
Therefore, IBM:
- Does not have a PAC (Political action committee)
- Does not engage in independent or electioneering communications as defined by law
- Does not provide any financial support to political parties or candidates, directly or indirectly
Read IBM’s policies and practices with regard to public policy matters.
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 the annual training on IBM’s Business Conduct Guidelines (BCGs) and certify their compliance.
Employees must at all times comply with IBM’s business conduct and related guidelines. Violation of any IBM guideline is a cause for discipline, including dismissal from the company. Employees should consult their management immediately if they have any questions about 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 are responsible for providing specific instructions regarding business conduct and ethics and, as appropriate, directing periodic reviews, including business conduct guideline certification programs, to help 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 collaborate with IBM is required to comply with IBM PartnerWorld® Code of Conduct.
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. Refer to the next section for an overview of IBM’s key policy positions.
IBM's media-buying and content policies are audience-centric, aiming to reach all consumers authentically, and are viewpoint neutral with respect to political or religious status or views.
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. IBM supports these trade organizations that are directly engaged in US lobbying through annual payments of USD 50,000 or higher:
- Alliance for Competitive Taxation (ACT)
- BSA | The Software Alliance
- Business Roundtable
- Cloud Security Alliance (CSA)
- Information Technology Industry Association
- Institute for Supply Management (ISM)
- Institute of International Finance (IIF)
- Securities Industry and Financial Markets Association (SIFMA)
- Semiconductor Industry Association (SIA)
- Silicon Valley Leadership Group (SVLG)
- Technology CEO Council (TCC)
- The World Travel and Tourism Council (WTTC)
- The United States Chamber of Commerce
Laws and regulations with regard to trade association lobbying disclosure vary by country. In the United States, the Lobbying Disclosure Act1 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 help 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 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.
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. These are described in Section 7 of IBM’s Business Conduct Guidelines.