Our business is subject to extensive laws and regulations at the international, federal, state and local levels, and changes to such laws can significantly affect how we operate, our revenues and the costs we incur. Because of the potential impact public policy can have on our businesses, employees, communities and customers, we engage with policymakers in order to advance and protect the long-term interests of the Firm.
Oversight & Compliance
The Public Responsibility Committee of the Board of Directors (PRC) provides oversight of the Firm’s positions and practices on public responsibility matters. At least once per year the PRC, which is composed entirely of independent outside directors, reviews the Firm's significant policies and practices regarding political contributions, major lobbying priorities and principal trade association memberships, including their continued relevance to the Firm's public policy objectives.
The Firm’s political engagement and public policy activities are managed by global Government Relations and Public Policy (GRPP). Our Code of Conduct requires all Firm-sponsored political activity and expenditures to be pre-approved and managed by GRPP, with guidance from our Legal Department, and to comply with the Code, Firm policies and applicable law. It also requires GRPP to review and approve the retention of outside lobbyists and all employee lobbying other than regulatory meetings and procurement lobbying.
GRPP reports to the Head of Corporate Responsibility, who is responsible for GRPP’s legal compliance and reports regularly to the PRC about the Firm’s political activity, expenditures and engagement. This organization and leadership helps us focus the Firm’s political engagement efforts on those public policy issues most relevant to the long-term interests of the enterprise overall and to our clients and shareholders.
Political Contributions, Expenditures and Payments
The Firm has strict internal policies and compliance processes to ensure adherence to relevant legal and regulatory requirements. We are fully committed to complying with all applicable laws regarding political contributions, such as MSRB Rule G-37, SEC Rule 206(4)-5, CFTC Rule 23.451, FINRA Rule 2030, as well as all national, state and local limits and requirements applicable to our business.
Our policies prohibit the use of corporate funds to contribute to candidates, political party committees and political action committees, including SuperPACs and political committees organized under Section 527 of the Internal Revenue Code (IRC) to promote the election or defeat of candidates for office. The Firm does not use corporate funds to make independent political expenditures or electioneering communications. The Firm restricts trade associations and 501(c)(4) organizations to which we belong from using our membership dues for any such election-related activity.
The Firm may contribute corporate funds for the purpose of supporting or opposing state or local ballot initiatives that may materially affect the Firm or our business operations. When the Firm contributes funds in connection with a ballot initiative we will disclose the amount and recipient of such payment, which may include a 501(c)(4) organization, on our Political Engagement Report.
Employee Political Action Committees
The JPMorgan Chase & Co. Political Action Committees (PACs) are funded entirely by voluntary contributions from eligible employees. They support candidates, parties and committees whose views on specific issues are consistent with the Firm’s priorities, and fund dues payments and ballot contributions to entities organized under Section 527 of the IRC. Contributions are directed by GRPP on a bi-partisan basis and are not made to candidates running for U.S. president. In deciding whom to support, GRPP prioritizes candidates that represent the communities we serve, that serve on relevant committees or in leadership positions and that have shown support for policies and initiatives of importance to the Firm.
The Head of GRPP is responsible for administration and supervision of the PACs, with oversight by the PRC. PAC contributions are reported to and made publicly available by the Federal Election Commission and relevant State or local election authorities in accordance with applicable law. The Firm publishes a summary of our PAC’s contributions on our Political Engagement Report.
Decisions regarding PAC contributions and corporate payments, including those for memberships and ballot initiatives, are made exclusively to promote the interests of the Firm, without regard for the personal political views or interests of senior management. GRPP works closely with our Legal Department to ensure that all PAC contributions and corporate payments are made in accordance with applicable law, Firm policies and this statement.
GRPP represents the Firm’s policy interests before government bodies globally to provide information and perspective on legislative matters of significance to the Firm and our lines of business. On the state and local level, GRPP lobbies primarily in states in which the Firm has a retail presence or other material business operations. Information about our retail locations is linked in our Political Engagement Report.
The Firm complies with all national, state and local laws concerning lobbying registration and reporting by GRPP. The Firm makes quarterly lobbying filings with the U.S. Congress disclosing our lobbyists’ federal lobbying expenditures and the issues on which they have lobbied. GRPP’s state and local lobbying costs are disclosed where and as required by applicable law. A summary of our federal lobbying expenditures and instructions for searching our filings and issues lobbied is available on our Political Engagement Report.
The Firm has not engaged in grassroots lobbying, and does not anticipate doing so. If we do engage in grassroots lobbying in the future, we will disclose such activity where and as required by law.
The Firm belongs to a number of trade associations that advocate on major public policy issues of importance to the Firm and the communities we serve. The Firm’s participation as a member of these associations comes with the understanding that we may not always agree with all the positions of an association or its other members, and that we are committed to voicing our concerns as appropriate through GRPP and the Firm leaders who interact with these associations. A list of the Firm’s principal trade associations, along with the portion of our membership dues attributable to lobbying, is disclosed on our Political Engagement Report.