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Página principalLike many companies, Wells Fargo engages in public policy advocacy on issues that impact our business at the local, state and federal levels. We believe that participating in the legislative process helps protect our customers, employees and businesses, and is an important part of responsible corporate citizenship.
The Wells Fargo Government Relations and Public Policy team works closely with all of our business lines to manage legislative and political activities in a manner consistent with good corporate governance practices and in compliance with all legal requirements. The head of Government Relations and Public Policy reports to the Vice Chairman of Public Affairs who, in turn, reports to the Chief Executive Officer of Wells Fargo. The Corporate Responsibility Committee of the Wells Fargo Board of Directors oversees all of the Company’s government relations activities and public advocacy policies and programs, and at least annually receives reports from management on political and lobbying activities, including payments made by Wells Fargo to trade associations.
Wells Fargo participates in the public policy arena on a wide range of issues that may impact the company and our business lines. We utilize on-staff government relations professionals, contract lobbyists, and trade associations to monitor and provide comment on proposed legislation and regulation that may affect how our customers can be served by our business lines. Corporate Government Relations and Public Policy must approve any use of company funds for lobbying. All federal lobbying activities are disclosed under the Lobbying Disclosure Act (LDA), which requires that reports be filed quarterly with the United States Congress. The LDA reports are available for review on the U.S. House website.
Wells Fargo’s political action committees (PACs) are funded entirely through voluntary contributions by our eligible exempt team members. Decisions about which candidates get support are made by the Government Relations and Public Policy team. All Wells Fargo PACs report to the Federal Elections Committee and/or to state agencies as required by law. Contributions are made without regard to the private political preferences of the company’s senior management.
View a list of the most recent campaign disbursements (PDF) of the Wells Fargo Employee PACs, which is updated semi-annually.
Wells Fargo does not use company money or resources to influence any U.S. domestic or foreign candidate elections, including assisting candidate campaign committees, political parties, caucuses or independent expenditure or other political committees, or any other type of election-related activity. If, in the future, we change our policy on independent expenditures we will disclose those expenditures on our website, and also present them to our Board of Directors for review.
Wells Fargo may contribute to entities organized under Section 527 of the Internal Revenue Code (“527 organizations”) but payments may only be used for operational and administrative purposes, not to support or oppose any candidate for U.S. federal, state, or local office, or to support or oppose any ballot initiatives. Additionally, payments to 527 organizations may not be transferred to any federal, state, or local PAC, any other form of political committee, or any other entity for the purpose of making contributions or expenditures, independent or otherwise, to support or oppose any candidates for U.S. federal, state, or local office, or to support or oppose any ballot initiatives. View the current list of contributions to 527 organizations (PDF), which is updated semi-annually.
Additionally, Wells Fargo may make contributions for ballot initiatives that could affect its business operations. When Wells Fargo makes these types of ballot initiative contributions, it does so to promote the interests of the company without regard to the private political preferences of Wells Fargo’s executives. On a periodic basis Wells Fargo will disclose the amount and recipient of ballot initiative contributions over $25,000, which may include a 501(c)(4) organization. View the list of contributions for ballot initiatives over $25,000 (PDF).
Wells Fargo is active in many financial services industry and general business trade associations. Trade groups often determine industry public policy consensus but our participation in these groups comes with an understanding that we may not always agree with every position taken. Decisions about our involvement with trade groups are made by the line of business managers and local bank leadership in conjunction with Corporate Government Relations and Public Policy and other corporate staff groups.
We prohibit trade associations and groups of which we are a member from using our corporate funds for campaign and election activities. We inform these organizations of our policy prohibiting the use of membership dues and fees for contributions to candidate committees, independent expenditure committees, or other direct or indirect contributions to election campaigns, and expect them to adhere to it. We are not members of any tax-exempt organization in the U.S. that is primarily organized to write, endorse and promote model legislation.
Below is a list of the principal financial services industry trade associations that received membership dues from Wells Fargo and its subsidiaries. Based on information reported to us, the amount of dues designated by the organizations as attributable to Wells Fargo and used for lobbying was approximately $2.0 million during the most recent membership period.
Wells Fargo is committed to complying with all applicable laws regarding political contributions, including MSRB Rule G-37, SEC Rule 15Fh-6, SEC Rule 206(4)-5, CFTC Rule 23.451 and applicable state and local restrictions and limits. We have policies and procedures in place consistent with this commitment. Wells Fargo maintains compliance processes intended to ensure that its activities are conducted in accordance with those policies, our Code of Ethics and Business Conduct, and with all relevant laws governing political contributions and lobbying activities.
Wells Fargo’s Code of Ethics encourages team members to engage in civic and political activities on their own time based on their individual desires and political preferences but not representing Wells Fargo. Team members may not engage in any political activity during work time or using Wells Fargo property to conduct such activity, and they cannot be reimbursed for any campaign contributions made from personal funds. Team members are free to make personal contributions on their own behalf to candidates and related political entities of their choice as long as they comply with the Code of Ethics and any policies of their business line. Personal political contributions made by team members reflect their own beliefs and not those of Wells Fargo.
As of November 30, 2022
QSR-0123-02624
LRC-0123
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