CVS Health participates in the political process to help shape public policy and address legislation that has a direct impact on the company. The engagement ensures that the interests of our business, customers, shareholders and employees are fairly represented at all levels of government.
It is CVS Health’s policy that the CEO and the Board are responsible for determining the company’s policy and political interests, and how to further those interests in a manner consistent with applicable laws. Specifically, the Nominating and Corporate Governance Committee regularly reviews and considers the Company’s policies and practices, including expenditures, regarding political contributions, and direct and indirect lobbying. It also reviews and considers the company’s policies and practices regarding other significant public policy issues, which the Board may determine from time to time.
Lobbying is highly regulated in the United States, and we comply with applicable U.S. federal and state laws, including the Lobbying Disclosure Act and Honest Leadership and Open Government Act that require reporting on lobbying activities and certification of compliance with Congressional gift rules. Our company’s federal lobbying reports can be found on the Lobbying Disclosures website. You can directly access our consolidated lobbying reports.
Our Government Affairs team represents the company’s point of view in Washington, D.C., and in state capitals around the country. We focus on legislative and public policy issues that impact the company’s delivery of pharmacy care and long-term business interests, and communicate with policymakers and stakeholders on issues that impact our business.
As a public corporation, CVS Health is prohibited by federal law from making contributions to candidates or political parties in federal elections. We make contributions at the state level, as allowed by state laws. All of the company’s contributions promote the interests of the company and are made without regard for the private political preferences of company officers and executives. A listing of our political donations at the state and local level, including candidates, political parties and ballot initiatives, is available in the Political Activities and Contributions report.
Colleague Political Action
As with many corporations, CVS Health offers certain eligible colleagues an opportunity to participate in the political process by voluntarily contributing to the CVS Health Political Action Committee (PAC), our company’s federal PAC. Political contributions to federal, state, and local candidates, political party committees, and political action committees are made by our PAC in accordance with applicable law. Consistent with federal law, CVS Health pays the administrative, solicitation and compliance costs of the Committee.
The CVS Health PAC is subject to comprehensive regulation by the federal government, including detailed disclosure requirements.
Under the Lobbying Disclosure Act of 1995, CVS Health submits to Congress semi-annual reports, which also include a listing of EPAC’s contributions to federal candidates. In a move toward greater transparency and per shareholder requests, we report these contributions in the Political Activities and Contributions report on our website. Included on our website are disclosures of the contributions the PAC makes at the state level in accordance with individual state laws. Additionally, we operate employee-funded state Political Action Committees in Rhode Island and Massachusetts.
CVS Health has a policy governing political contributions made from corporate and PAC funds to ensure that all potential political contributions made by or on behalf of CVS Health or an PAC are reviewed and approved internally for compliance with all federal, state, and local laws, and that all of the company’s political activities are conducted in accordance with high ethical standards. This policy applies to all employees of CVS Health, and each of its subsidiaries and affiliates. CVS Health does not make any independent expenditures in federal, state or local elections.
CVS Health participates in various federal and state trade associations or organizations that operate in support of specific industries. Trade associations participate in activities such as education, advertising and lobbying to influence public policy. Many associations offer other services, such as producing conferences, networking or charitable events or offering classes or educational materials. Some associations also make political contributions or operate a PAC.
From January 2017 – March 2018, CVS Health paid approximately $7.5 million in dues to trade and industry associations. (This amount includes payments to governors associations and certain non-profit civic organizations.) Details regarding CVS Health’s trade and industry association membership dues can be found in our annual Trade Association Dues Report, along with our past reports. These reports include the amount paid for advocacy and/or political purposes for any trade or industry association with annual total dues of $25,000 or more, as well as payments in excess of $25,000 to such associations and governmental organizations.