Political Activity — Policies, Oversight and Disclosure
In general, employees are free to engage in political activities, in their personal capacity, including making contributions of their own time and money to organizations of their choice (some employees, such as newsgathering employees, may have additional obligations related to contributions and should review their division specific policies). An employee's personal affiliations shall not be the basis of adverse employment action as long as those affiliations are both lawful and fully comply with the Standards of Business Conduct.
Where permitted by law, the Company may contribute directly to state and local candidates, state party committees, and other political entities in order to promote the interests of the Company. All such Company contributions must be approved in advance by Time Warner's Executive Vice President for Global Public Policy. The use of company resources in support of the Company's political activities also requires advance approval by the Executive Vice President for Global Public Policy. Time Warner will semi-annually disclose on its website all Company political contributions and expenditures including, if any, independent political expenditures.
U.S. law permits companies to establish a political action committee to collect employee donations to contribute to federal candidates and other committees regulated by the Federal Election Commission (FEC). The Company has created the Time Warner Inc. Political Action Committee (TWI PAC) for this purpose and contributions to federal candidates and committees are made only through the TWI PAC, in accordance with FEC regulations. The TWI PAC makes bipartisan contributions to political candidates and committees in support of the Company's public policy goals. In making contributions to candidates, the TWI PAC considers, among other factors, the candidate's committee assignments and record of public positions on issues of importance to the Company. To provide funding for the TWI PAC, the Company periodically solicits voluntary contributions from eligible employees, excluding the Company's journalists. The Company fully discloses all TWI PAC activity on reports filed with the Federal Election Commission (FEC), which are publicly available at the FEC website. Additionally, Time Warner will annually disclose on its website all TWI PAC contributions to federal candidates and committees.
For any trade association or other entity organized under 26 U.S.C. Section 501(c)(6) that receives $50,000 or more from Time Warner during a calendar year, and for any entity organized under 26 U.S.C. Section 501(c)(4) that receives funding from Time Warner during a calendar year, the Company will ask those organizations to identify the portion of Time Warner's payments that are used for political expenditures as defined by 26 U.S.C. Section 162(e)(1)(B). Time Warner will annually disclose on its website any amounts reported in response to such requests.
Company executives are required to certify annually that they have read and will comply with the Time Warner Standards of Business Conduct, which includes the Company's policies on political activities.
The Nominating and Governance Committee of the Time Warner Board of Directors is responsible for overseeing the Company's corporate social responsibility and public policy activities, which include policies and practices regarding political contributions and expenditures by the Company, its PAC, and trade associations.