Policy Engagement and Political Participation



JPMorgan Chase believes that responsible corporate citizenship demands a strong commitment to a healthy and informed democracy through civic and community involvement. Our business is subject to extensive laws and regulations at the international, federal, state and local levels, and changes to such laws can significantly affect how we operate, our revenues and the costs we incur. Because of the potential impact public policy can have on our businesses, employees, communities and customers, we engage with policymakers in order to advance and protect the long-term interests of the Firm. Meaningful engagement requires JPMorgan Chase to participate in the legislative process and to support candidates through prudent political contributions.
 

Trade Associations


JPMorgan Chase is regularly involved in legislative initiatives across a broad spectrum of policy areas that could significantly affect our operations and results. We regularly express our views to public officials and provide them with factual briefings to inform their decisions. We monitor legislative activities, analyze trends and advance public policies that will benefit the Firm and our stakeholders.

To help us achieve these objectives, we belong to a number of trade associations representing the interests of both the financial services industry specifically as well as the broader business community. These organizations work to represent the industry and advocate on major public policy issues of importance to the Firm and the communities we serve. The Firm's participation as a member of these associations comes with the understanding that we may not always agree with all the positions of an organization or its other members. A list of the principal organizations we belong to is available here. opens a PDF

When we make payments to these organizations, including membership fees and dues, we restrict these organizations from using our funds for any election-related activity at the federal, state or local level, including contributions and expenditures (including independent expenditures) in support of, or opposition to, any candidate for any office, ballot initiative campaign, political party committee or PAC.

We disclose publicly all U.S. federal lobbying costs – those paid directly as well as through trade associations – and the issues to which our lobbying efforts relate, on a quarterly basis, pursuant to reports required by the Lobbying Disclosure Act. We also disclose state and local lobbying costs where required by applicable law.

 

Political Contributions


The Firm's policies prohibit contributions of corporate funds to candidates, political party committees and political action committees. Contributions by the Firm's PACs – which are supported entirely by voluntary contributions made by employees – support candidates, parties or committees whose views on specific issues are consistent with the Firm's priorities. In deciding whom to support, consideration is given to candidates who represent the communities we serve, those who serve on relevant committees or in leadership, and those who have shown support for policies and initiatives of importance to the Firm. Contributions made by the PACs are, as required by law, reported in filings with the Federal Election Commission and the relevant State or local election commissions and are publicly available. The most recent report is available here. opens a PDF

The Firm may from time to time use corporate funds to support or oppose state or local ballot initiatives that affect our business. The Firm does not use corporate funds to make contributions to broad-based groups organized under Section 527 of the Internal Revenue Code. The Firm's PACs may make contributions to ballot committees and 527 organizations; however, contributions to 527s are primarily membership dues and are not used to support the election of any specific candidate or for the purpose of funding specific expenditures or communications. Even where we are not required to disclose contributions to 527s or ballot initiatives, we voluntarily provide that information on our website. The most recent report is available here. opens a PDF

The Firm may occasionally support groups organized under Section 501(c)4 of the Internal Revenue Code on public policy matters, but not for electoral purposes. When we do support a 501(c)4 on public policy matters, we will seek to disclose that information here. opens a PDF

We do not use corporate funds to make independent political expenditures, including electioneering communications, notwithstanding the Supreme Court's decision in Citizens United that corporations may make such expenditures.
 

Compliance and Oversight


All political activities conducted by or on behalf of the Firm are managed by the Firm's Global Government Relations department, which reports to the Head of Corporate Responsibility. The Head of Corporate Responsibility is responsible for the department's policies, activities and legal compliance, upon advice of the Firm's legal counsel and Compliance Department and subject to oversight by the Public Responsibility Committee of the Board of Directors. Government Relations reports not less than annually to the Public Responsibility Committee on the Firm's significant policies and practices regarding political contributions, major lobbying priorities and principal trade association memberships that relate to the Firm's public policy objectives. This organization and leadership helps us focus the Firm's efforts on those public policy issues most relevant to the long-term interests of the enterprise overall and to our clients and shareholders.

JPMorgan Chase is fully committed to complying with all applicable laws regarding political contributions, including MSRB Rule G-37, SEC Rule 206(4)-5, CFTC Rule 23.451 and applicable state and local restrictions and limits.

The JPMorgan Chase Code of Conduct requires that Government Relations review and approve all requests for Firm support of political events, political candidates and their campaigns, political parties or committees, and all political contributions proposed to be made by or on behalf of the Firm. It also requires Government Relations to review and approve all lobbying activities, including retention of outside lobbyists, except where government procurement requires registration. The Firm's employees have the right to participate in the political process by making personal contributions from personal funds, subject to applicable legal limits. However, as stated in the Firm's Code of Conduct, employees cannot be reimbursed or otherwise compensated by JPMorgan Chase for any such contributions.



March 2014