Like 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 team works closely with all of our business lines to manage legislative and political activities in a manner consistent with good corporate government practices and in compliance with all legal requirements. The head of Corporate Government and Community Relations reports to the Chief Administrative Officer of Wells Fargo who, in turn, reports to the Chairman and Chief Executive Officer. 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.
Advocacy and lobbying
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 in Washington D.C. and at state capitols to monitor and provide comment on proposed legislation and regulation that may affect how our customers can be served by our more than 90 lines of business. Corporate Government Relations 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.
Campaign finance and PACs
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 Government Relations state and federal directors. All Wells Fargo PACs report to the Federal Elections Committee and/or to state agencies as required by law. PAC contributions are made without regard to the private political preferences of the company’s senior management.
Corporate political spending
Wells Fargo does not use corporate funds for any candidate campaign funds including candidate campaign committees, political parties, caucuses, or independent expenditure committees. The prohibition against using Wells Fargo company funds for electioneering activities includes, but is not limited to, groups organized under IRS Sections 501(c)(4), 501(c)(6), or 527. If, in the future, we change our policy on independent expenditures we will disclose those expenditures in our semiannual report of political disbursements and related activities, and also present them to the Board of Directors for review.
Our prohibition against corporate funds being used for political activity extends to those trade groups of which we are a member. We restrict these organizations from using our membership dues for contributions to candidate committees, independent expenditure committees or other direct or indirect contributions to election campaigns.
Participation in trade association and independent groups
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 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.
View the current list of state and national trade groups (PDF) that received more than $25,000 in dues from Wells Fargo. Because the budget cycles of trade groups are not consistent the figures on the attached spreadsheet should not be taken as definitive. The list of trade association payments is updated semi-annually.
Wells Fargo participates in state and local ballot measures such as initiative and referenda, constitutional amendments, and bond measures that impact our various lines of business. We post contributions over $25,000 in our semiannual report of political disbursements and related activities (PDF).
Wells Fargo’s Government Relations Compliance Policy sets forth requirements for compliance and reputation risk management for activities that stem from political contributions and contact with covered federal officials. The policy is implemented across the enterprise by corporate and business compliance groups and adherence to it is periodically reviewed by corporate audit.
Team member activity
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.