Intuitive Surgical, Inc. (“Intuitive” or “the Company”) and its subsidiaries support the development of effective public policy through direct advocacy, participation in industry associations, and sponsorship of the Intuitive Surgical, Inc. Political Action Committee (“Intuitive-PAC”). Decisions on lobbying and political spending are made with the objective of promoting the interests of the Company and are made without regard for the private political preferences of Intuitive executives.
Intuitive engages in lobbying to advocate on public policy issues. Intuitive submits regular reports disclosing its federal lobbying activities, and reports of any state or local lobbying activities in which it may engage when required. The federal reports are available at http://disclosures.house.gov
Intuitive may contribute to nonprofit organizations or belong to industry or trade associations and similar organizations (e.g., AdvaMed and the Medical Device Manufacturers’ Association, etc.) that are engaged in or may engage in lobbying or political activity. The portions of the Company’s membership dues that trade associations or similar groups allocate to lobbying are included in the total amount of lobbying expenses the Company discloses. In the interest of transparency, the company discloses the names of all trade associations receiving dues and other payments in excess of $25,000 and the portion of such payments that are non-deductible under Section 162(e) of the U.S. Internal Revenue Code. View our disclosure here.
From time to time, Intuitive may participate in the political process by contributing to U.S. state or local candidates, political parties, political committees, ballot committees, political organizations, and tax-exempt organizations, where such contributions are permitted by applicable law. Contributions are based on several criteria, including policy positions that reflect the interests of Intuitive including on issues related to public health and innovation; representation of geographic areas where Intuitive employees and facilities are located; ability to be elected; and the need for financial assistance.
In the interest of transparency, the company posts semi-annually a report that discloses the company’s contributions to political candidates, parties, and committees, political organizations operating under Section 527 of the U.S. Internal Revenue Code, and ballot measure committees. View our disclosure here.
Intuitive has not made and does not plan to make any independent expenditures in connection with federal, state, or local elections. If the company’s position on making independent expenditures changes, those expenditures (including recipient names and amounts given) would be disclosed.
Intuitive-PAC was established to encourage the advancement of sound public policy that supports our mission. Participation is voluntary, and activities are non-partisan and in compliance with applicable law. Federal law prohibits corporations from making political contributions to federal candidates or party committees, but corporations may establish political action committees funded solely through voluntary employee contributions.
Intuitive-PAC, governed by a PAC Committee comprised of employees and executives of Intuitive has adopted by-laws and operational guidelines that include criteria for disbursements by the Intuitive-PAC to federal candidates.
To determine if a federal candidate is eligible for Intuitive-PAC contributions, the candidate is evaluated against criteria such as key committee assignments, leadership, history of support for the medical device industry and industry-related issues, and constituent representation.
Intuitive-PAC complies with all applicable laws concerning political contributions, including laws requiring public disclosure of such contributions. The PAC reports all financial activity as required by law to the Federal Election Commission.
Intuitive pays the PAC’s administrative costs as allowed by law. All Intuitive-PAC contributions are funded through the voluntary support of eligible Intuitive employees and its Board of Directors. Intuitive prohibits contributions to the Intuitive-PAC from corporate funds. In addition, no contribution or expenditure will be given or made in anticipation of, in recognition of, or in return for an official act. Under no circumstances will an employee be reimbursed directly or through compensation increases for personal political contributions or expenses.
The Political Spending Committee (“the Committee”) has oversight over any political spending, policy-focused activities, lobbying, and compliance activities. All corporate political expenditures must be approved by the Political Spending Committee. The Political Spending Committee is comprised of Intuitive’s General Counsel & Chief Compliance Officer, Vice President of Global Public Affairs, and Chief Financial Officer.
The Committee reviews annually, or as needed, all corporate political activity to make sure all actions are in alignment with Intuitive corporate policy and the Company’s mission. The Committee will also review the Company’s Lobbying and Political Spending policy annually to ensure continued compliance with federal regulations and alignment with corporate values.