Political Activity — Policies, Oversight, and Disclosure
Political Activity — Policies, Oversight, and Disclosure
Marriott International Inc. (Marriott), believes that political participation at all levels of government is important to our business and to our country. Public policy decisions often have a significant impact on Marriott, and we believe that being involved in the political process is essential to Marriott’s success. Marriott is committed to participating in the political process to promote its interests and business objectives, without regard to political preferences of its executives. We therefore support candidates seeking elected office at the federal, state and local level who support issues important to Marriott’s business.
COMPANY POLITICAL ACTIVITIES
Independent Expenditures: While companies are permitted by law to engage in independent expenditures or electioneering communications to advocate for the election or defeat of federal candidates, Marriott International has chosen not to engage directly in such activity at this time.
501(c)(4) Organizations: To the extent that Marriott makes any contributions to 501(c)(4) organizations, it will disclose semiannually on its website all such contributions. All such Marriott contributions must be approved in advance by Marriott International’s Government Affairs Office.
State & Local Contributions: Where permitted by law, Marriott or Marriott’s Political Action Committee may contribute directly to state and local candidates, state party committees, and other state and local political entities. All such Marriott contributions must be approved in advance by Marriott International’s Government Affairs Office. Marriott International will semiannually disclose on its website all Company state and local-level political contributions and expenditures.
527 Committees: When permitted by law, Marriott may contribute to 527 political committees. Such contributions must be approved in advance by Marriott International’s Government Affairs Office. Marriott International will semiannually disclose on its website all Company political contributions and expenditures.
Ballot Measures: Marriott and affiliated hotels are permitted to make contributions to ballot measure committees where permitted by law and which are approved in advance by Marriott International’s Government Affairs office. These contributions are disclosed under applicable laws that require recipients of political contributions to disclose the source, date and amount of all contributions received. Marriott International will also semiannually disclose on its website all ballot measure contributions.
POLITICAL ACTION COMMITTEE
Federal law does not permit corporations to contribute their own funds to federal candidates, political parties, or most other political committees. U.S. law does permit companies to establish a political action committee to collect employee donations to contribute to federal candidates and other committees regulated by the Federal Election Commission (FEC). Federal PACs may also contribute to state and local candidates or committees regulated by state election agencies.
The Company has created the Marriott International Political Action Committee (MARPAC) for this purpose. Contributions to federal candidates and committees are made only through MARPAC, in accordance with FEC regulations. MARPAC also contributes to state and local candidates in states where that is permissible. To provide funding for MARPAC, the Company periodically solicits voluntary contributions from eligible employees. The Company fully discloses all MARPAC activity on reports filed with the Federal Election Commission (FEC), which are publicly available on the FEC website or relevant state agency for contributions made to state candidates.
DISCLOSURE OF POLITICAL EXPENDITURES BY NON-PROFIT ORGANIZATIONS
For any trade association of which Marriott is a member or otherwise contributes, Marriott will disclose the portion of Marriott International’s payments that are used for federal lobbying and political expenditures as defined by 26 U.S.C. Section 162(e) as provided by a trade association partner. Marriott International will semiannually disclose this information on its website. Payment to a trade association does not imply agreement with or endorsement of an association’s activities, positions or their expenditures.
PERSONAL EMPLOYEE POLITICAL ACTIVITIES
Marriott’s culture encourages individual participation by employees in the political and governmental process. This includes service on governmental bodies, work with advocacy organizations, and participation in partisan political activities. However, pursuant to Marriott’s policies, such activities are considered personal, they must be undertaken on an Associate’s own time, and may not involve the use of Company resources or coercive solicitations.
OVERSIGHT AND GOVERNANCE
Marriott has internal policies governing political contributions, lobbying, and personal political activities, and enforces compliance through its internal legal and government affairs departments. The Nominating and Corporate Governance Committee of the Board of Directors reviews these policies and practices annually and reviews political contributions and expenditures by the Company and its PAC semiannually. The Company’s Executive Vice President and Chief Global Communications & Public Affairs Officer, who reports directly to the Company’s President and CEO, is responsible for the overall management of the Company’s participation in the political process, and all corporate political contributions must be approved by the Executive Vice President and Chief Global Communications & Public Affairs Officer or the Senior Vice President, Global Corporate Communications & Public Policy.