At Adobe, good business begins with a commitment to the highest ethical standards and adherence to the guiding principles of integrity, respect, honesty, quality, responsibility, and fairness. These guiding principles are the foundation of our culture. By operating with integrity and transparency, we build and deepen credibility and trust with our employees, customers, vendors, partners, stockholders, and the community.
We believe public policy engagement is an important and appropriate role for companies when conducted in a legal and transparent manner. Adobe is committed to participating in the political process in compliance with applicable federal, state, and local laws and reporting requirements. Our policies and procedures for political contributions made with corporate funds are set forth in the Adobe Public Policy and Government Relations Policy .
Under U.S. law, corporations are not allowed to support candidates for federal office. Many U.S. states allow corporate donations to state and local candidates or ballot issue campaigns. On a limited basis, Adobe may make corporate political contributions to support candidates and ballot measures that align with our public policy agenda and business interests, and are in compliance with the Adobe Public Policy and Government Relations Policy . As part of our policy, we prohibit "soft money" contributions to any groups organized under section 527 of the Internal Revenue Code. In 2012 Adobe did not make any corporate political contributions to state or local candidates or to ballot issue campaigns.
Adobe has not established a federal or state Political Action Committee (PAC).
Adobe belongs to several trade associations that require the payment of regular dues. Adobe does not make additional contributions to these organizations. In 2012 no trade associations to which Adobe paid dues in an amount greater than $50,000 (USD) annually used any portion of such dues for political expenditures as defined by 162(e)(1)(B) of the Internal Revenue Code.
Board Oversight Management will report annually to our Board of Directors, or appropriate committee thereof, regarding political contributions made by Adobe. Our Board of Directors, or appropriate committee thereof, will periodically review and assess the appropriateness of the Adobe Public Policy and Government Relations Policy .