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 that 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 .

Corporate political contributions

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 are consistent with our public policy agenda and business interests, and in compliance with the Adobe Public Policy and Government Relations Policy. It is also Adobe's policy not to make "soft money" contributions to any groups organized under section 527 of the Internal Revenue Code.

In 2011, Adobe did not make any corporate political contributions to state or local candidates or to ballot issue campaigns.

No Political Action Committee

Adobe has not established a federal or state Political Action Committee (PAC).

Trade associations

Adobe belongs to several trade associations and pays regular dues to these groups. Adobe does not make additional, non-dues contributions to these organizations to fund the groups' political expenditures. In 2011, no trade associations to which Adobe pays dues in an amount greater than US$50,000 annually used any portion of such dues for political expenditures as defined by 162(e)(1)(B) of the Internal Revenue Code.

Board oversight

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.