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Political Accountability
My WordPress Blog
 * CPA-Zicklin Index
   * Past CPA-Zicklin Index Reports
 * News
   * In the News
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   * Press Releases
   * CPA Newsletters
 * Reports
   * CPA Reports
   * Recent Shareholder Engagement
 * TrackYourCompany
   * Why Corporate Political Spending Matters
   * Where Does Our Data Come From?
   * How Companies Rank In The CPA-Zicklin Index
   * Shareholder Engagement History
 * Our Impact
 * About
   * About Us
   * How Companies Spend
   * Citizens United and Dark Money
   * Board of Directors
   * Staff
   * Internships
 * Donate

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 * CPA-Zicklin Index
   * Past CPA-Zicklin Index Reports
 * News
   * In the News
   * Podcasts
   * Press Releases
   * CPA Newsletters
 * Reports
   * CPA Reports
   * Recent Shareholder Engagement
 * TrackYourCompany
   * Why Corporate Political Spending Matters
   * Where Does Our Data Come From?
   * How Companies Rank In The CPA-Zicklin Index
   * Shareholder Engagement History
 * Our Impact
 * About
   * About Us
   * How Companies Spend
   * Citizens United and Dark Money
   * Board of Directors
   * Staff
   * Internships
 * Donate




CPA-ZICKLIN INDEX: A FOCUS ON TRANSPARENCY

Whether it’s what the founding fathers envisioned or not, public corporations
are a dominant source of political funding today. The CPA-Zicklin Index of
Corporate Political Disclosure and Accountability is the only measure of
electoral spending transparency and accountability among the country’s largest
public corporations.

Issued annually, it’s produced by the Center for Political Accountability in
conjunction with the Zicklin Center for Business Ethics Research at The Wharton
School at the University of Pennsylvania.

Based on information posted by companies on their websites, the Index measures
performance in three areas: disclosure, company political spending
decision-making policies, and board oversight and accountability policies.

Click on report image to view the 2020 report. The raw data used to compile this
report is available here.


HOW TO GET A PERFECT SCORE

Using 24 metrics, or “indicators,” the CPA-Zicklin Index assesses companies’
disclosure practices and spending and accountability policies for spending with
corporate or treasury funds to influence elections. It does not address company
spending on lobbying or company political action committees. The ideal
election-related spending policy explains:

 * The company’s process for making contributions or expenditures to influence
   political and/or ballot measure elections
 * How management and the board oversee such decisions
 * The public policy considerations that influence such decisions

Below, please find a sample disclosure report as well as model policy language
from some of the top-scoring companies on the Index. (For more guidance on how
the Index is scored, please see the Index Scoring Guidelines.)

For inquiries regarding the CPA-Zicklin Index, please contact Dan Carroll, CPA’s
Vice President for Programs.

Note: Indicators 1-7 concern the company’s disclosure report. View CPA’s Model
Election-Related Spending Disclosure Report.

#1 Does the company publicly disclose corporate contributions to political
candidates, parties and committees, including recipient names and amounts given?

#2 Does the company publicly disclose payments to 527 groups, such as governors
associations and super PACs, including recipient names and amounts given?

#3 Does the company publicly disclose independent political expenditures made in
direct support of or opposition to a campaign, including recipient names and
amounts given?

#4 Does the company publicly disclose payments to trade associations that the
recipient organization may use for political purposes?

#5 Does the company publicly disclose payments to other tax-exempt
organizations, such as 501(c)(4)s, that the recipient may use for political
purposes?

#6 Does the company publicly disclose a list of the amounts and recipients of
payments made by trade associations or other tax exempt organizations of which
the company is either a member or donor?

#7 Does the company publicly disclose payments made to influence the outcome of
ballot measures, including recipient names and amounts given?

#8 Does the company publicly disclose the company’s senior managers (by
position/title of the individuals involved) who have final authority over the
company’s political spending decisions?

 * Aflac Inc.: “Corporate contributions made by Aflac are reviewed by outside
   legal counsel for compliance with applicable campaign finance and related
   laws, and reviewed and approved by an Aflac Senior Vice President reporting
   directly to Aflac’s General Counsel.”

#9 Does the company publicly disclose an archive of each political expenditure
report, including all direct and/or indirect contributions, for each year since
the company began disclosing the information (or at least for the past five
years)?

#10 Does the company disclose a detailed policy governing its political
expenditures from corporate funds?

#11 Does the company have a publicly available policy permitting political
contributions only through voluntary employee-funded PAC contributions?

#12 Does the company have a publicly available policy stating that all of its
contributions will promote the interests of the company and will be made without
regard for the private political preferences of executives?

 * Freeport-McMoRan Inc.:”FCX’s political spending reflects our interests as a
   company and not those of any individual director, officer or employee.”

#13 Does the company publicly describe the types of entities considered to be
proper recipients of the company’s political spending?

 * Boeing Co.: “Since 2010, the Company has not made any contributions from
   corporate funds to state or local candidates or political parties. Also,
   Boeing has not expended any corporate funds since 2011 in support of or
   opposition to ballot initiatives, or since 2012 for political contributions
   to section 527 entities.”

#14 Does the company publicly describe its public policy positions that become
the basis for its spending decisions with corporate funds?

 * Southwestern Energy Co.: “Political contributions are to be made in
   accordance with the Company’s political contributions policy only as
   permitted under federal, state and local laws to help elect candidates who
   demonstrate integrity and character, support the domestic production of oil
   and natural gas and understand the contribution of the oil and natural gas
   industry to our national economy and national security.”

#15 Does the company have a public policy requiring senior managers to oversee
and have final authority over all of the company’s political spending?

 * United Continental Holdings Inc.: “You may not make political contributions
   on behalf of United, including, but not limited to, monetary or in-kind
   contributions, the use of corporate resources, email, personnel or
   facilities, without obtaining prior approval from Legal and Government
   Affairs.”

#16 Does the company have a publicly available policy that the board of
directors regularly oversees the company’s corporate political activity?

 * BB&T Corp.: “The Nominating and Corporate Governance Committee of the Board
   annually reviews this Statement of Political Activity and receives reports
   that provide information on BB&T’s contributions to trade associations, PACs
   and related lobbying activity.”

#17 Does the company have a specified board committee that reviews the company’s
policy on political expenditures?

 * Coca-Cola Co.: “The Committee shall review the Company’s public policy
   advocacy efforts, including all political contributions, to ensure alignment
   with Company policy and our overall values. This review will occur at least
   annually.”

#18 Does the company have a specified board committee that reviews the company’s
political expenditures made with corporate funds?

 * Costco Wholesale Corp.: “The Nominating and Governance Committee of the Board
   of Directors, which is comprised exclusively of independent directors,
   reviews the Company’s spending on politics and advocacy.”

#19 Does the company have a specified board committee that reviews the company’s
payments to trade associations and other tax-exempt organizations that may be
used for political purposes?

 * United Parcel Service Inc.: “UPS will request trade associations that
   received from UPS total payments of $50,000 or more in a given year to report
   the portion of UPS dues or payments used for expenditures or contributions.
   Prior to publication, the report shall be presented to the Nominating and
   Corporate Governance Committee of the UPS Board of Directors.”

#20 Does the company have a specified board committee that approves political
expenditures from corporate funds?

 * ConocoPhillips: “The Public Policy Committee has authorized a strict process
   for the justification, approval and reporting of any corporate political
   contributions made in states that permit corporate contributions.”

#21 Does the company have a specified board committee, composed entirely of
outside directors, that oversees its political activity?

 * McKesson Corp.: “The Committee shall consist of three or more directors each
   of whom has been determined, in the business judgment of the Board, to
   qualify as an independent director.”

#22 Does the company post on its website a detailed report of its political
spending with corporate funds semiannually?

#23 Does the company make available a dedicated political disclosure web page
found through search or accessible within three mouse-clicks from homepage?

#24 Does the company disclose an internal process for or an affirmative
statement on ensuring compliance with its political spending policy?

 * Altria Group Inc.: “The company conducts regular trainings, compliance system
   reviews, and internal audits to ensure all PAC and corporate political
   contributions are made in accordance with the law and company policies.”

For inquiries regarding the CPA-Zicklin Index, please contact Dan Carroll, CPA’s
VP for Programs.

Whether it’s what the founding fathers envisioned or not, public corporations
are a dominant source of political funding today. The CPA-Zicklin Index of
Corporate Political Disclosure and Accountability is the only measure of
electoral spending transparency and accountability among the country’s largest
public corporations.

Issued annually, it’s produced by the Center for Political Accountability in
conjunction with the Zicklin Center for Business Ethics Research at The Wharton
School at the University of Pennsylvania.

Based on information posted by companies on their websites, the Index measures
performance in three areas: disclosure, company political spending
decision-making policies, and board oversight and accountability policies.

Click on report image to view the 2020 report. The raw data used to compile this
report is available here.


HOW TO GET A PERFECT SCORE

Using 24 metrics, or “indicators,” the CPA-Zicklin Index assesses companies’
disclosure practices and spending and accountability policies for spending with
corporate or treasury funds to influence elections. It does not address company
spending on lobbying or company political action committees. The ideal
election-related spending policy explains:

 * The company’s process for making contributions or expenditures to influence
   political and/or ballot measure elections
 * How management and the board oversee such decisions
 * The public policy considerations that influence such decisions

Below, please find a sample disclosure report as well as model policy language
from some of the top-scoring companies on the Index. (For more guidance on how
the Index is scored, please see the Index Scoring Guidelines.)

For inquiries regarding the CPA-Zicklin Index, please contact Dan Carroll, CPA’s
Vice President for Programs.

Note: Indicators 1-7 concern the company’s disclosure report. View CPA’s Model
Election-Related Spending Disclosure Report.

#1 Does the company publicly disclose corporate contributions to political
candidates, parties and committees, including recipient names and amounts given?

#2 Does the company publicly disclose payments to 527 groups, such as governors
associations and super PACs, including recipient names and amounts given?

#3 Does the company publicly disclose independent political expenditures made in
direct support of or opposition to a campaign, including recipient names and
amounts given?

#4 Does the company publicly disclose payments to trade associations that the
recipient organization may use for political purposes?

#5 Does the company publicly disclose payments to other tax-exempt
organizations, such as 501(c)(4)s, that the recipient may use for political
purposes?

#6 Does the company publicly disclose a list of the amounts and recipients of
payments made by trade associations or other tax exempt organizations of which
the company is either a member or donor?

#7 Does the company publicly disclose payments made to influence the outcome of
ballot measures, including recipient names and amounts given?

#8 Does the company publicly disclose the company’s senior managers (by
position/title of the individuals involved) who have final authority over the
company’s political spending decisions?

 * AFLAC Inc.: “Corporate contributions made by Aflac are reviewed by outside
   legal counsel for compliance with applicable campaign finance and related
   laws, and reviewed and approved by an Aflac Senior Vice President reporting
   directly to Aflac’s General Counsel.”

#9 Does the company publicly disclose an archive of each political expenditure
report, including all direct and/or indirect contributions, for each year since
the company began disclosing the information (or at least for the past five
years)?

#10 Does the company disclose a detailed policy governing its political
expenditures from corporate funds?

#11 Does the company have a publicly available policy permitting political
contributions only through voluntary employee-funded PAC contributions?

#12 Does the company have a publicly available policy stating that all of its
contributions will promote the interests of the company and will be made without
regard for the private political preferences of executives?

 * Freeport-McMoRan Inc.:”FCX’s political spending reflects our interests as a
   company and not those of any individual director, officer or employee.”

#13 Does the company publicly describe the types of entities considered to be
proper recipients of the company’s political spending?

 * Boeing Co.: “Since 2010, the Company has not made any contributions from
   corporate funds to state or local candidates or political parties. Also,
   Boeing has not expended any corporate funds since 2011 in support of or
   opposition to ballot initiatives, or since 2012 for political contributions
   to section 527 entities.”

#14 Does the company publicly describe its public policy positions that become
the basis for its spending decisions with corporate funds?

 * Southwestern Energy Co.: “Political contributions are to be made in
   accordance with the Company’s political contributions policy only as
   permitted under federal, state and local laws to help elect candidates who
   demonstrate integrity and character, support the domestic production of oil
   and natural gas and understand the contribution of the oil and natural gas
   industry to our national economy and national security.”

#15 Does the company have a public policy requiring senior managers to oversee
and have final authority over all of the company’s political spending?

 * United Continental Holdings Inc.: “You may not make political contributions
   on behalf of United, including, but not limited to, monetary or in-kind
   contributions, the use of corporate resources, email, personnel or
   facilities, without obtaining prior approval from Legal and Government
   Affairs.”

#16 Does the company have a publicly available policy that the board of
directors regularly oversees the company’s corporate political activity?

 * BB&T Corp.: “The Nominating and Corporate Governance Committee of the Board
   annually reviews this Statement of Political Activity and receives reports
   that provide information on BB&T’s contributions to trade associations, PACs
   and related lobbying activity.”

#17 Does the company have a specified board committee that reviews the company’s
policy on political expenditures?

 * Coca-Cola Co.: “The Committee shall review the Company’s public policy
   advocacy efforts, including all political contributions, to ensure alignment
   with Company policy and our overall values. This review will occur at least
   annually.”

#18 Does the company have a specified board committee that reviews the company’s
political expenditures made with corporate funds?

 * Costco Wholesale Corp.: “The Nominating and Governance Committee of the Board
   of Directors, which is comprised exclusively of independent directors,
   reviews the Company’s spending on politics and advocacy.”

#19 Does the company have a specified board committee that reviews the company’s
payments to trade associations and other tax-exempt organizations that may be
used for political purposes?

 * United Parcel Service Inc.: “UPS will request trade associations that
   received from UPS total payments of $50,000 or more in a given year to report
   the portion of UPS dues or payments used for expenditures or contributions.
   Prior to publication, the report shall be presented to the Nominating and
   Corporate Governance Committee of the UPS Board of Directors.”

#20 Does the company have a specified board committee that approves political
expenditures from corporate funds?

 * ConocoPhillips: “The Public Policy Committee has authorized a strict process
   for the justification, approval and reporting of any corporate political
   contributions made in states that permit corporate contributions.”

#21 Does the company have a specified board committee, composed entirely of
outside directors, that oversees its political activity?

 * McKesson Corp.: “The Committee shall consist of three or more directors each
   of whom has been determined, in the business judgment of the Board, to
   qualify as an independent director.”

#22 Does the company post on its website a detailed report of its political
spending with corporate funds semiannually?

#23 Does the company make available a dedicated political disclosure web page
found through search or accessible within three mouse-clicks from homepage?

#24 Does the company disclose an internal process for or an affirmative
statement on ensuring compliance with its political spending policy?

 * Altria Group Inc.: “The company conducts regular trainings, compliance system
   reviews, and internal audits to ensure all PAC and corporate political
   contributions are made in accordance with the law and company policies.”

For inquiries regarding the CPA-Zicklin Index, please contact Dan Carroll, CPA’s
VP for Programs.

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your company
spend?

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your company
rank?

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What does
your company
spend?

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How does
your company
rank?

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Do you
have our
new report?

Get It Now >>




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