The UTC Board of Directors “reviews and monitor[s] UTC’s conduct of government relations activities, including the activities of any political action committees.” The Governance and Public Policy Committee of the Board of Directors reviews and monitors “UTC’s policies and practices with respect to contributions to charitable, educational and other tax-exempt organizations involved in the arts, civic and community affairs, education and health and human services.” These reviews also include state political activities, 527, 501(c)(4), and similar contribution activities.
UTC’s federal lobbying activities and expenditures can be reviewed in detail via its U.S. Federal Lobbying Disclosure Act filings.
UTC’s state lobbying activities are subject to regulation and reporting in virtually every jurisdiction in which the company or its affiliates do business. As a general rule, the company’s state lobbying efforts are restricted to issues involving building safety and related building codes (e.g., smoke/CO2 detector legislation, elevator and other safety codes); economic development; and various business regulation issues that arise during legislative sessions in key states where the company maintains a substantial business presence (i.e., California, Connecticut, Florida, Georgia, Illinois, Minnesota, New York, Tennessee, Texas and North Carolina). UTC’s lobbying activity reports for these states can be accessed by clicking on the name of each state.
U.S. Federal Contributions
Every day U.S. Government lawmakers make decisions that affect UTC’s businesses, and for this reason, UTC supports candidates for public office who understand the company’s broad business objectives.
UTC does not make political contributions to candidates for a federal Government office. However, under UTC Policy, the United Technologies Corporation Federal Political Action Committee (UTC PAC) supports candidates for federal office through voluntary giving by individual employees. UTC PAC offers employees, regardless of their political affiliations, a legal and ethical way to speak with a unified voice on issues important to our company.
The UTC PAC is nonpartisan. It contributes to candidates supportive of UTC’s corporate business interests and public policy goals, regardless of political party, and also to national political organizations of both major parties. The bylaws of the UTC PAC provide basic organizational material and incorporate Federal Election Commission regulations. A Steering Committee meets regularly to review candidates and approve contributions. The Steering Committee consists of senior employees from UTC’s Global Government Relations organization and each of UTC’s major business units.
In addition to its bylaws, the UTC PAC adheres to the following principles:
- Participation by eligible employees is always voluntary.
- The PAC does not seek, request or expect any specific benefit for its contributions to candidates or for any official act.
- The PAC reports contributions to elected officials and candidates as required by law, and to PAC contributors periodically.
- PAC contributions are intended primarily for individuals seeking federal elective office. Contributions to leadership PACs, multi-candidate PACs, and organizational or association PACs are made only after the most careful and deliberate consideration.
The Steering Committee considers the following factors in deciding the timing and amount of contributions to candidates:
- The candidate’s views (and voting record, in the case of incumbents) on issues critical to UTC’s success;
- The presence of UTC facilities in the candidate’s district;
- The congressional committees on which the legislator serves (in the case of incumbents); and
- The strength of the candidate and the impact a contribution and implied UTC endorsement might have on the race.
U.S. state and local laws may differ, but frequently ban or restrict the amount of political contributions to candidates for state/local office. Accordingly, as a matter of policy, UTC does not make contributions to candidates for state and local office or to state and local party committees.
Section 527 and Section 501(c)(4) Activity
UTC generally does not provide financial or other support to such organizations, except as noted below. In cases where a contribution is made, we require the organization to represent that donations are used solely for operating expenses, with no part being used for political contributions.
UTC has in the past and anticipates that it will continue to make contributions to the Democratic and Republican Governors Associations for membership dues only.
Likewise, UTC has provided financial support to federal and state inaugural committees (typically 501(c)(4) organizations) to help defray the costs of public events (e.g., inaugural events) and not for political purposes.
Compliance with, oversight over and advance approval for such support is provided by the UTC Senior Vice President, Global Government Relations, and the UTC Executive Vice President and General Counsel.
UTC joins trade associations to share with other companies in our industries business, technical and standards expertise, and to be part of an important public education effort regarding major issues of common concern to our industries. We do not join trade associations to advance 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. Our participation in trade associations is subject to management oversight and membership requires management approval. Guidelines on trade association participation are provided in the UTC Code of Ethics and supplements to the Code, and these are available to all UTC employees.
UTC and its operating companies may participate from time to time in formal and informal coalitions or committees to help communicate our views on public policy issues that affect our business. Examples of this include coalitions on tax and international trade issues. This engagement enables us to share our views and help promote discussion of issues related to our businesses. We expect that the coalition(s) we participate in to disclose our support in the same way they would for any other company, and, at a minimum, as required by federal, state or local lobbying laws and regulations.
Electioneering Expenditures and Ballot Measures
The U.S. Supreme Court determined in 2010 that corporations may make unlimited expenditures for communications to the general public that expressly advocate the election or defeat of a clearly identified federal candidate, provided the expenditures are independent of and not coordinated with any individual’s campaign. UTC has not made any such expenditure in the past and has no present plans to spend corporate funds directly on such communications. Lastly, UTC does not provide financial support to support or oppose ballot measures.