EMC is committed to responsible and transparent participation in the political process. We engage in this process to help shape public policy that impacts the company and our industry. Our involvement aims to ensure that the interests of customers, shareholders, employees and other stakeholders are fairly represented at all levels of government.
The Corporate Governance and Nominating Committee regularly reviews our corporate political activity and the activity of the EMC Political Action Committee (the “EMC PAC”), including review of our semi-annual disclosure statements, key public policy priorities, and the appropriateness of EMC’s Political Contributions Policy.
Since 2007, we have had a publicly available Political Contributions Policy, which outlines procedures for contributions made with corporate funds. The Political Contributions Policy also describes oversight of the EMC PAC, a nonpartisan committee registered with the Federal Election Commission.
Any proposed corporate political contribution by EMC, whether monetary or “in-kind,” must be submitted in advance to EMC’s Office of Corporate Government Affairs and the Chief Compliance Officer for pre-approval.
Any contribution by the EMC PAC must be reviewed and approved by the EMC PAC Board. Our due diligence process includes, among other things, consideration of whether the proposed recipient of a contribution represents a state or district where a major EMC facility is located, supports employee interests in his or her district, serves on a Congressional committee with jurisdiction over issues of importance to EMC’s business, or has been supportive of the IT industry on key issues. Contributions may be made to members of all political parties and are made without regard to the political preferences of EMC executives.
Public Policy Priorities
Our desire to assist in the development of sound public policy guides how we prioritize our government affairs activities. Our priorities align with our business interests and are reviewed with our Board of Directors. The following are examples of our public policy priorities and the rationale behind our support.
- Informing Federal Cloud Computing Policies – Cloud computing and data center consolidation are critical elements of federal IT policy. Federal stakeholders are pushing agencies to adopt these policies to increase productivity, reduce environmental impacts, and achieve cost savings. We work with trade associations and industry partners to educate policy makers on these topics, including enhancing their understanding of cloud computing deployment, service models, and information security and privacy issues. EMC is a founder and board member of the Cloud Computing Caucus Advisory Group, a coalition of technology companies and industry groups focused on educating lawmakers and the public about cloud computing. EMC also continues to participate in various events to discuss the company’s own journey to the cloud, and expertise and knowledge of industry best practices regarding data center consolidation. In 2015, a delegation of Congressional staff toured EMC’s Franklin manufacturing facility to learn more about EMC’s cloud computing and data storage capabilities as well as the Federation’s technology policy priorities.
- Leveraging Big Data to Advance Key Public Sector Missions – The era of Big Data has spurred organizations to find new ways to scale and manage their storage environments and to develop and leverage advanced data analytics capabilities. We support policies that harness Big Data to enhance intelligence and defense programs and advance health and environmental sciences by meeting massive storage requirements through cost-effective and scalable solutions. In 2015, the FBI Chief Financial Officer visited Pivotal Labs in New York, one of the companies that make up the EMC federation, to learn more about agile software and the company’s Big Data solutions. To learn more about Big Data, visit IT & Society.
- Patent Litigation Reform – EMC supports legislation that eliminates abusive and frivolous patent litigation. EMC has testified twice before the House Judiciary Committee and once before the Senate Judiciary Committee about patent litigation abuse and the importance of enacting legislation to improve and rebuild our patent system. EMC has also repeatedly met with Members of Congress and their staffs and worked with trade associations and industry stakeholders to promote patent litigation reform. In 2015, EMC also participated in a meeting on patent reform with White House officials and other industry leaders and stakeholders.
- Comprehensive Immigration Reform – Through our activity with trade associations and industry partners, such as Business Round Table, the Technology CEO Council, and the Information Technology Industry Association, EMC supports bipartisan comprehensive immigration reform that includes critical high-skills provisions.
- Prompting Effective Sustainability/Energy Efficiency Approaches – Through Congressional testimony and outreach, we communicate frequently with federal stakeholders about our sustainability strategy and environmentally sound IT policies in the public sector. EMC supports the introduction of legislation that would save the federal government energy and money, and reduce greenhouse gas emissions, by requiring the use of energy-efficient and energy-reduction technologies, particularly in federal data centers. In 2015, EMC testified before the House Energy and Commerce Committee on the importance of energy-efficient technology solutions and policies. To learn more about EMC’s efficiency approach, visit Energy Use & Climate Change.
- Promoting Policies to Address Advanced Cyber Threats – Organizations face cyber threats every day – including increased attempts to steal sensitive data such as intellectual property – and cyber security has become a major national and economic security priority. EMC, along with our Security Division, RSA, worked with the Administration and Congress to advocate for policy recommendations that will address the security and privacy concerns of our customers. Following years of engagement by EMC/RSA, Congress recently passed critical legislation that expands a cyber threat information sharing framework between public and private sectors. This framework aims to protect privacy while enhancing our ability to protect networks from an increasingly advanced global threat in cyberspace.
- Securing the Information Technology Supply Chain – Ensuring that the public sector supply chain remains secure and free from malicious attempts to modify products and services remains a top priority for EMC and the technology sector. We continue to work with Congress and the Administration on creating effective policies that keep our federal supply chains strong and free of counterfeit parts and other malicious attempts to weaken the security of information technology systems.
- Harnessing the Influence of the Global Technology Industry – Many countries have turned to strengthening regulatory initiatives to improve their nation’s cybersecurity and enhance the privacy and civil liberties of their citizens. Some of these regulatory efforts can have the consequence of stifling innovation and restricting market access to foreign IT vendors by forcing data localization and requiring indigenous technologies. EMC is focused on maintaining access to foreign markets and globalized supply chains as a major source of growth and new investment. Specifically, EMC is focused on “Secure and Controllable” initiatives in China, forced localization requirements in Russia, and Safe Harbor negotiations with our European partners. We must harness a consistent, international standards-based approach to enhancing the security and protecting privacy of consumers as the most effective approach to solving these complex challenges.
- Corporate Tax Policy – EMC supports comprehensive tax reform aimed at improving U.S. corporate competitiveness. EMC is a member of the Alliance for Competitive Taxation (ACT), a coalition of 42 Fortune 500 companies that support comprehensive tax reform that lowers the corporate rate to 25 percent, establishes a modern globally competitive tax system, and is fully paid for by ending tax breaks and preferences. In 2015,Congress passed a tax package that provides a permanent extension of the research and development tax credit and other tax policies of importance to EMC.
- Advancing Effective Education Policy and STEM Education – As a technology company, our primary interest and expertise lies in advancing Science, Technology, Engineering and Math (STEM) education to build a highly diverse, trained, and innovative workforce for the future. We also work to improve education systems around the world.
- EMC is a signatory to The Climate Declaration, a project of Ceres that brings together companies and individuals to demonstrate support for national action on climate change.
- In 2014, EMC signed the Corporate Renewable Energy Buyers’ Principles.
- EMC’s Policy Position on Climate Change
EMC is committed to responsible participation in the political process in compliance with applicable federal, state, and local laws and reporting requirements.
In the interest of transparency for our shareholders and other stakeholders, we provide information about our corporate and EMC PAC contributions, lobbying expenditures, and major trade association memberships on our website.
The amount of our contributions is relatively small, but nonetheless we believe it is in the best interests of EMC and our shareholders to keep lines of communication open with our elected officials and help shape public policy consistent with our business priorities. Political contributions represent just a fraction of EMC’s involvement in our communities and our activities as a responsible corporate citizen. To learn more, visit Community Involvement.
We make information about our corporate political contributions publicly available on a semi-annual basis. A listing of our 2015 corporate political contributions is available in the reports listed below.
The purpose of the EMC PAC is to promote good citizenship and further business interests that are of concern to shareholders and employees of EMC. The EMC PAC provides eligible employees with an opportunity to participate in the elective process at the federal level of government and to support the election of qualified, informed, and constructive candidates for office. The EMC PAC is funded entirely by voluntary employee contributions; no corporate funds are used to fund the EMC PAC.
While we do not expect recipients of contributions to agree at all times with our positions on all issues, we seek to support individuals who will promote the interests of EMC.
A list of the EMC PAC’s contributions is available here.
We work closely with many different stakeholders in an effort to promote well-considered public policy for the benefit of our customers, employees, shareholders, and company. This pragmatic approach to the development of sound policy is effectuated through engagement with policymakers at all levels.
A list of EMC’s federal lobbying expenditures and disclosures is available here, and information on state-level lobbying activities in Massachusetts, where our headquarters is located, is available here.
Trade Association Memberships
EMC participates in various trade associations and organizations that engage in activities such as education, lobbying, advertising, and knowledge sharing. We take a collaborative approach in working with the trade associations to advance the best interests of EMC and our stakeholders. Among other things, we consider whether the trade association has been effective in advancing EMC’s priorities when considering whether to join an organization or renew our membership.
We publicly disclose our major U.S. trade associations, the amount of our annual membership dues, and information we received from these organizations regarding lobbying expenses and political expenditures using membership dues. Details regarding our trade association memberships and dues paid are updated annually and available in the reports listed below.
EMC’s testimonies before the House Judiciary Committee
October 29, 2013 House Testimony: House Judiciary Testimony
February 12, 2015 House Testimony: House Judiciary Committee
March 18, 2015 Senate Testimony: Senate Judiciary Committee
April 30, 2015 House Testimony: Energy and Commerce Committee