Advocacy

We have a Government and Regulatory Affairs organization to enable Pitney Bowes to navigate the ever more complex government and regulatory environments in which we operate. Pitney Bowes engages in public policy and political processes in a variety of ways.

Where public policies impact our business and our clients, we aim to lend an informed and constructive voice. We naturally focus our efforts in areas and geographies most relevant to our business, including policies related to the postal industry, trade and privacy.

We maintain a robust compliance program to ensure that our advocacy work complies with all applicable laws. We also hold ourselves to the highest ethical standards in this work. We voluntarily report our adherence to these principles for corporate political spending on an annual basis.

Questions regarding these principles should be addressed to Pitney Bowes Global Government and Regulatory Affairs, 3001 Summer St., Stamford, CT 06926 or to govtaffairs@pb.com.

U.S. Corporate Political Spending Governance

The Governance Committee of the Pitney Bowes Board of Directors oversees the company’s political activities, including our policy on political expenditures. The Committee, comprised entirely of independent directors, reviews regular reports regarding the company’s contributions to political candidates, committees and political parties, as well as our expenditures to trade associations and other tax-exempt organizations that could be used for political purposes. The Committee receives periodic briefings concerning the company’s political activities and spending. Our entire Board of Directors is also briefed on these activities.

In addition to Board oversight, we periodically seek review of our political contribution policies and compliance by independent experts.

The team leaders of Global Government and Regulatory Affairs, who are senior managers of the company, are responsible for day-to-day decision making on political activities. They oversee the company’s participation in the political process and have final authority on contributions to political candidates, committees and political parties, as well as our expenditures to trade associations to support the company’s objectives. The leaders report directly to a member of the Pitney Bowes senior management team, who in turn reports directly to the CEO.

The Pitney Bowes Corporate Contributions Committee is composed of Pitney Bowes senior level managers. This committee oversees decision making related to corporate contributions to candidates, committees and political parties. The criteria we use to determine what candidates and candidate committees to support are detailed under Political Spending.

Political Spending in the United States

In the U.S., we do not contribute corporate funds or make in-kind contributions to candidates for federal office or to national party committees. Our policy on expenditures with corporate funds is reflected in the company’s Code of Conduct, known as our Business Practices Guidelines.

Independent Expenditures: We do not use corporate funds to make any direct independent expenditures or fund electioneering communications on behalf of candidates running for public office.

Ballot Measures: We generally do not use corporate funds to support or oppose ballot measures. If a matter with significant impact to our business were on the ballot, any contribution to a campaign for or against the measure would require the approval of the Pitney Bowes Corporate Contributions Committee.

Corporate Political Contributions:  We utilize corporate funds to contribute to U.S. state-level candidates, committees and political parties, in large part because a number of states do not allow the use of a Federal PAC, which has historically been our most common channel for political giving. Our corporate contribution decisions are based on a variety of factors, including the candidate’s or committee’s:  views on public policy issues that are important to Pitney Bowes; demonstrated leadership or potential for leadership within their party; representation of districts or states where Pitney Bowes has a business presence; service on committees whose actions could affect our business; and likelihood of election success.

In the U.S., we also use corporate funds to support a small number of organizations of statewide elected and appointed officials and political party convention committees, some of which are known as 527 organizations. Historically, we balance our contributions between the two major political parties, although the amounts may vary from year to year. We do not consult with any of the groups regarding the disbursement of their funds. On our website, twice each year we disclose the aggregate contributions made from corporate funds for such organizations.

We make contributions to support the interests of Pitney Bowes, without regard to the private political interests of company executives, officers or board members. We do not make campaign contributions in anticipation of, in recognition of, or in return for an official act.

Trade Associations and Other Organization Memberships and Partnerships:  Pitney Bowes is a member or partner of several industry, trade and other groups that represent the mailing, technology and global ecommerce industries, as well as groups representing the general business community. We invest in these partnerships in an effort to bring about consensus on policy issues that can impact our business and our clients. Our participation in these groups comes with the understanding that while we may have some shared policy interests, we may not always agree with the positions of the larger organization and/or other members.

Each year, we make reasonable efforts to obtain from member associations the portion of the company’s dues or payments totaling $25,000 or more that were used for non-deductible lobbying and political expenditures under Internal Revenue Code section 162(e). This information is publicly disclosed as required by law as part of a report to the U.S. House of Representatives, which can be found at http://clerk.house.gov/public_disc and the U.S. Senate, which can be found at http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm.

We do not plan to request information concerning the contributions made by these groups to others, nor do we plan to condition our membership or sponsorships of organizations on any specific criteria except those which may help to advance our business objectives.

Employee Involvement

We value the right of our employees to participate in the political process in a variety of ways. This participation is a matter of personal choice. We require that our employees’ personal political activities not suggest an endorsement by Pitney Bowes, not be conducted during an employee’s scheduled working time nor involve the use of any company resources. In addition, we do not reimburse employees, directly or indirectly, for political donations or expenses. These principles are reflected in the company’s Business Practices Guidelines, which is our Code of Conduct.

In the U.S., we provide an opportunity for employees to voluntarily participate in the political process by joining the company’s non-partisan political action committees, the Pitney Bowes PACs. The PACs allow our employees to pool their financial resources to support political candidates, parties and committees to help further the interests of the company.

Pitney Bowes PAC contributions are funded exclusively through voluntary contributions from eligible employees who are U.S. citizens or permanent legal residents. Personal contributions to the Pitney Bowes PACs have no bearing upon an employee’s standing with the company, nor will we take any retaliatory action against an employee who chooses not to contribute.

Senior managers serve on the Political Action Committee, which oversees PAC contributions to candidates, committees and political parties. Recipients of PAC contributions are determined by considering the candidate's or committee's:  views on public policy issues that are important to Pitney Bowes; demonstrated leadership or potential for leadership within their party; representation of districts or states where Pitney Bowes has a business presence; service on committees whose actions could affect our business; and, likelihood of election success.

Our PACs make contributions to support the interests of Pitney Bowes without regard to the private political interests of company executives, officers or board members. The PACs do not make contributions in anticipation of, in recognition of, or in return for an official act.

The Pitney Bowes Federal PAC reports its contributions to the Federal Election Commission, which can be found at http://www.fec.gov/, and the New York State PAC reports its contributions to the New York State Elections Commission. The Commission’s website is http://www.elections.ny.gov/INDEX.html. The Pitney Bowes PACs disclose their contributions on the Pitney Bowes website twice a year.

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