At John Deere, we believe that participating in the democratic political process to advocate public policy that enables us to complete fairly and freely in the marketplace is of vital importance to our shareholders, employees and customers. For this reason, we and our employees engage in political advocacy in a variety of ways. This engagement may include corporate public policy programs designed to educate elected officials on key policy issues that affect our business; individual, voluntary political contributions by employees through the John Deere Political Action Committee; and membership in trade associations that help advance our business objectives. In whatever form it might take, John Deere’s engagement in the political process is grounded in and guided by our firm commitment to strong corporate governance and global corporate citizenship.
All political spending by John Deere reflects the Company's business interests and is used to further its public advocacy goals, not the personal agendas of its individual officers, directors or employees.
John Deere complies fully with all federal, state and local campaign finance laws and regulations governing political contributions and the disclosure of these contributions.
Consistent with federal law, John Deere does not contribute corporate funds to federal candidates, national political party committees or other federal political committees. Even when permitted by applicable law, for example, in connection with certain state and local elections, John Deere's corporate assets are not typically used to support or oppose any candidate for political office or ballot measure. The Company does, however, reserve the right to make exceptions to this practice so long as any contribution we make is consistent with our public policy agenda, in accordance with our Code of Business Conduct, and previously approved by our Chairman, Chief Executive Officer, Senior Vice President and General Counsel, or Senior Vice President with responsibility for Public Affairs. John Deere does not pay for any independent expenditures or electioneering communications, as those terms are defined by applicable law. In the interest of transparency for our shareholders and other stakeholders, we publicly disclose, and update annually, our corporate political contributions. John Deere did not make any political expenditures out of corporate assets in the 2011 calendar year.
John Deere Political Action Committee
John Deere administers, in compliance with federal and state election laws, the John Deere Political Action Committee (JDPAC), a voluntary, non-partisan group made up of U.S. employees. JDPAC members voluntarily pool their personal financial resources to help elect candidates to federal and state office that understand and support free enterprise and the general business interests of the Company and its employees. Under federal law and Company policy, participation in JDPAC is limited to U.S. administrative and executive-level employees. Except for administration expenses, JDPAC is funded solely by John Deere employees and is not supported by funds from John Deere itself. The Company does not reimburse employees directly or indirectly for political contributions, including contributions to JDPAC.
JDPAC takes no stance on legislative matters and does not engage in lobbying on specific issues. JDPAC contributes to candidates who broadly share the company's pro-business outlook and support of the free enterprise system. It does not seek to influence any particular vote through the giving of contributions. Oversight of JDPAC's contribution activities is exercised by its board of directors, currently consisting of 13 John Deere employees from throughout the Company's various business units.
JDPAC fully discloses all contributions made and received through reports filed with the Federal Election Commission and various state ethics commissions, as required by law. To improve access to information about JDPAC's contributions, John Deere posts an annual report to its website summarizing JDPAC contributions made in the most recent calendar year or election cycle, categorized by state, candidate and amount. To view the annual report for calendar 2011, please click here.
Like most major corporations, John Deere belongs to a number of trade and industry associations and pays regular dues to these groups. We join trade associations in part to join other like-minded companies in engaging in public education and advocacy efforts regarding major issues of common concern to our industries. We do not join trade associations solely for political purposes and we do not expect those associations of which we are a member to make political contributions or to be otherwise engaged in the political campaign process. Although we might not always agree with every position taken by the associations of which we are a member, we believe that engagement on policy issues through groups like these is important to help ensure that our voice is heard. Our participation in trade associations is subject to management approval and oversight. We publicly disclose and update annually a list of those trade associations to which John Deere pays dues or makes other contributions of $50,000 or more, as well as the portion of such dues or payments that are not deductible under Section 162(e)(1) of the Internal Revenue Code. The list for calendar 2011 may be accessed here.