The Times’ methodology

Over the last six months, The Times sent the na­tion’s 75 largest pub­licly traded en­ergy, health­care and fin­an­cial ser­vices com­pan­ies sur­veys ask­ing a series of ques­tions about their prac­tices for re­port­ing polit­ic­al spend­ing on their cor­por­ate web­sites.

Com­pan­ies were asked about three kinds of polit­ic­al spend­ing — stand­ard polit­ic­al giv­ing to can­did­ates and cam­paigns, giv­ing to trade as­so­ci­ations and giv­ing to oth­er tax-ex­empt is­sue ad­vocacy groups or­gan­ized un­der Sec­tion 501(c)4 of the tax code.

All in­form­a­tion provided by com­pan­ies was checked against cor­por­ate web­sites, fin­an­cial fil­ings and state and fed­er­al cam­paign fin­ance re­ports. You can re­view the res­ults here.

Standard political giving

Fed­er­al and state elec­tion laws re­quire com­pan­ies to pub­licly dis­close this giv­ing to gov­ern­ment agen­cies. But if the in­form­a­tion is not pos­ted on a com­pany’s web­site (which is not re­quired by law), re­view­ing dona­tions can re­quire lengthy and cum­ber­some searches of mul­tiple state and fed­er­al web­sites.

The most trans­par­ent com­pan­ies re­port dir­ect giv­ing and giv­ing by its polit­ic­al ac­tion com­mit­tee on their web­sites, al­low­ing easy pub­lic re­view. Com­pan­ies that post only a por­tion of their cor­por­ate giv­ing are con­sidered to have only par­tially re­por­ted.

Questions:

• Does the company report giving by its Political Action Committee?
• Does the company report giving involving corporate funds?

Trade association giving

Com­pan­ies are not re­quired by law to re­port the dues they pay to trade as­so­ci­ations, even those that are used by as­so­ci­ations for polit­ic­al pur­poses such as lob­by­ing or cam­paign-re­lated ad­vert­ising. But trade as­so­ci­ations have played a grow­ing role in state and na­tion­al polit­ic­al cam­paigns, spend­ing tens of mil­lions of dol­lars on ad­vert­ising, of­ten tar­get­ing can­did­ates they op­pose.

The most trans­par­ent com­pan­ies re­port mem­ber­ships to groups in which they pay dues above a spe­cified threshold — the threshold can vary from $25,000 to $100,000. They also re­port the por­tion of dues that those trade as­so­ci­ations used for lob­by­ing and oth­er polit­ic­al activ­ity. Trade as­so­ci­ations make that cal­cu­la­tion for tax pur­poses be­cause com­pan­ies are not al­lowed to de­duct polit­ic­al con­tri­bu­tions.

Com­pan­ies that post only a sampling of their mem­ber­ships — without a threshold — are con­sidered to have pos­ted a par­tial list.

Questions:

• Does the company report membership in trade associations, such as the U.S. Chamber of Commerce?
• Does the company report the dues it pays to trade associations?
• Does the company report the portion of its dues used for political purposes?

Giving to tax-exempt issue advocacy groups

Com­pan­ies are not re­quired by law to re­port con­tri­bu­tions to groups or­gan­ized un­der Sec­tion 501(c)4 of the tax code. These is­sue ad­vocacy groups also are not re­quired to re­port their donors. But in re­cent elec­tions some groups have spent mil­lions of dol­lars on cam­paign-re­lated ad­vert­ising and played de­cis­ive roles in polit­ic­al races.

The most trans­par­ent com­pan­ies either re­port all of their giv­ing or have writ­ten policies on their web­sites pro­hib­it­ing dona­tions to 501(c)4 groups.

If a com­pany has a writ­ten policy pro­hib­it­ing dona­tions, it is con­sidered to have fully dis­closed its giv­ing. Com­pan­ies that do not post writ­ten policies, but say that they did not make any con­tri­bu­tions to 501(c )4 groups, are not con­sidered to have dis­closed be­cause they would be un­der no ob­lig­a­tion to re­port fu­ture dona­tions.

Com­pan­ies that have no writ­ten policy on giv­ing to 501(c)4 groups, but have dis­closed con­tri­bu­tions to at least one group are con­sidered to have pos­ted a par­tial list.

Question:

• Does company report payments to tax-exempt issue advocacy groups?