Letter from the General Counsel
Aflac is firmly committed to good governance and corporate citizenship. Part of this commitment involves being fully participatory in the democratic process. Aflac, as stewards of the trust that our policyholders, employees, agents, shareholders and communities place in us, understands the importance of all of our constituencies having a voice to ensure their rights and values are protected. By engaging in the legislative process, we become that voice for them.
One important way in which this is done is through the Aflac Political Action Committee (Aflac PAC) and Aflac’s corporate political contributions. By making political contributions to candidates in accordance with all applicable rules outlined in the Aflac Incorporated Code of Business Conduct and Ethics, which includes board oversight, the Company fully engages in the political process.
Aflac PAC and Aflac corporate contributions are bipartisan, and all activities are transparent, subject to board oversight, and of the highest ethical standards as outlined by all governing laws. Further rules of conduct regarding Aflac PAC and corporate political contributions are outlined in Aflac’s Political Participation Program.
Thank you for your interest in Aflac and its engagement in the democratic process.
Audrey Boone Tillman, Executive Vice President
General Counsel
Aflac's Political Participation Program
Aflac's political participation program supports candidates for federal and state offices.
Management and Oversight
The operational management of Aflac's bipartisan political action committee, Aflac Political Action Committee (Aflac PAC), is performed by its Treasurer and Secretary. These officers are responsible for the solicitation of contributions to and the disbursement of funds from Aflac PAC consistent with applicable law, the Aflac PAC By-Laws, and Aflac's contribution policy and criteria. In addition, Aflac PAC is subject to periodic internal audits, as well as external reviews by outside legal counsel.
Corporate contributions made by Aflac are reviewed by outside legal counsel for compliance with applicable campaign finance and related laws, and reviewed and approved by an Aflac Senior Vice President reporting directly to Aflac's General Counsel for consistency with Aflac's contribution policy and criteria.
The Corporate Governance Committee of the Board of Directors, which is composed of independent directors, reviews the policies, processes and contribution criteria outlined in Aflac's Political Participation Program and monitors compliance. In addition, the Corporate Governance Committee reviews Aflac's Political Activity Report prior to its publication on Aflac's website.
Contribution Policy and Criteria
Consistent with our commitment to being a good corporate citizen and to operating our business in accordance with the Aflac Way, it is the policy of Aflac and the Aflac PAC to maintain an active role in the public policy arena and to support legislators and other lawmakers who have a strong interest in issues of significance to the Company without regard for the private political preferences of executives. Before making any political contribution from the Aflac PAC or Aflac corporate funds, a number of criteria are considered including:
- the candidate's understanding of and support for the free enterprise system
- the candidate's demonstrated leadership or potential for leadership, as well as candidate's committee assignments and seniority within Congress or state government
- the candidate's involvement with and position on issues important to Aflac and/or the insurance industry
- the likelihood of the candidate's election success
While not exhaustive, the following list represents the type of questions considered before making any political contribution from the Aflac PAC or Aflac corporate funds:
- What is the candidate's record on public policy matters and issues of importance to Aflac's business objectives?
- Is the request for the contribution in writing and does it identify the purpose, including the name of the candidate or issue involved?
- Who has solicited or encouraged the contribution?
- What is the amount of the proposed contribution?
- Are any concerns raised by the timing of the contribution request in light of other internal and external activities?
Independent Expenditures
Neither the Aflac PAC nor Aflac, as part of its corporate political contributions program, make contributions to independent expenditure-only committees (i.e., super PACs). Any change to this policy would require a waiver from Aflac’s General Counsel and would be disclosed on Aflac’s Political Activity Report.
Disclosure
Contributions are publicly disclosed as required by applicable federal and state laws. Federal and state laws require candidate campaign committees, political committees and ballot committees to report the contributions they receive. Aflac PAC is required to publicly disclose receipts and contributions to the Federal Election Commission, which may be found at www.fec.gov.
In order to promote transparency and accountability regarding Aflac's engagement in political activities, Aflac will generate a Political Activity Report, which will disclose:
- any contributions made from corporate funds to:
- political candidates or their committees
- political parties or their committees
- ballot measure committees
- 527 organizations, 501(c)(4) organizations, and other similar organizations that make expenditures for political activities
- the non-deductible portion of annual payments (including dues and special payments) made by Aflac to trade associations (when the total annual payments exceed $50,000 and to the extent such non-deductible portion is known by Aflac and provided by the trade association)
- direct independent expenditures
After being reviewed by the Corporate Governance Committee, Aflac will publish its Political Activity Report on Aflac's website at least annually.