Best Buy encourages employees to engage in the political process, both personally and professionally in accordance with the law and this policy. U.S. federal and state laws regulate certain political activities of U.S-domiciled corporations and its employees and certain laws compel disclosure pertaining to engagement with government entities. To that end, the purpose of this policy is to clarify the legal and ethical obligations associated with political activity as it relates to your employment with Best Buy. For purposes of this policy, the term “government official” applies to any individual that is elected, appointed or hired by a governmental or quasi-governmental entity.
This policy applies to all employees and contractors, regardless of whether they are acting alone, in conjunction with their department, or as part of a Best Buy Employee Resource Group (i.e. SAGE, LATIN, etc.). While participation in politics is a personal choice, federal, state and local laws define the parameters of permissible activity. This policy seeks to educate employees on the range of permissible activity as well as conduct that is strictly prohibited or otherwise requires pre-approval. The following topics are addressed in this policy:
Please also refer to these other relevant policies located on ETK:
Lobbying involves making contact with government officials in an attempt to influence legislation or regulatory activity at the federal, state or local level. Federal law requires companies to register and report lobbying activity in certain instances. Best Buy files lobbying reports quarterly, copies of which may be viewed at http://lobbyingdisclosure.house.gov. States and local governments may also have their own lobbying, registration and reporting requirements.
Examples of lobbying activities can include: attempting to influence legislation, formal rulemaking or ratemaking, influencing the decision on the award or terms of a government contract, and grassroots lobbying.
As a Best Buy employee:
Best Buy may engage in “Grassroots” lobbying activity by communicating with employees or a segment of the public for purposes of influencing legislation or a rulemaking. Government Relations is responsible for advocacy efforts concerning industry or public policy issues of interest to Best Buy.
Under the direction of Government Relations, Best Buy or one of its subsidiaries may request that employees contact state or federal legislators regarding an issue of critical importance to the business. Such requests will generally include background information about the issue, its importance to Best Buy and a suggested message for employees to convey to their legislator. If applicable, Government Relations may also share information on relevant state or local lobbying laws as prepared by Best Buy’s legal counsel.
As a Best Buy employee:
When a Best Buy employee participates in a political campaign as a candidate, volunteer, financial sponsor or otherwise- the employee is participating as a private citizen and not as a representative of Best Buy. Employees providing financial support to a political candidate or issue are urged to familiarize themselves with state laws and contribution limitations. In some states, certain employees may be required to disclose their personal contributions. Affected employees may include members of Best Buy’s Board of Directors; Executive Officers; and employees contracting with government officials. Immediate family members of affected employees may also be impacted by these laws.
As a Best Buy employee:
Best Buy promotes the importance of voting through its “Turn up the Vote” initiative and encourages all employees to vote on Election Day. Employees can find information about voting on www.bluegrassrootsnetwork.com or by contacting their local government offices. Each employee should talk with his or her manager about Election Day plans to minimize disruption to schedules at home and at work. Your manager will be able to help you request time off for Election Day in accordance with state laws. Managers can access additional information through Manager Self Service on ETK.
Conducting Business with Government Entities
In an effort to prevent bribery and corruption, both federal and state laws regulate the manner in which companies may conduct business with government entities. Some states have enacted so-called “pay-to-play” laws, which may require Best Buy to disclose certain information, including personal political contributions of employees and their families, or limit the scope of business transactions with governmental entities. To ensure compliance with applicable laws, it is imperative that employees selling directly to government entities or managing government contracts understand the instances where personal contributions may impact their business activities and trigger compliance obligations for Best Buy.
As a Best Buy employee:
In connection with Best Buy’s Code of Business Ethics, its FCPA Policy, and in accordance with applicable state and federal laws, employees are strictly prohibited from giving gifts, gratuities or anything of value to influence a government official or to advance a particular business. This prohibition extends to anything that personally benefits the individual to whom it is given, including meals, entertainment, travel, and any other items of value to the recipient. In no event should any employee provide any such items to a government official without the prior approval of Government Relations and the Legal Department.
Employees must strictly comply with these policies to ensure their conduct complies with legal requirements and avoids the appearance of impropriety. Due to sensitive and complex nature of these prohibitions, employees should consult Government Relations for advice prior to interacting with government officials in order to avoid inadvertent violations of company policy and applicable law.
Best Buy supports transparency and for this reason, discloses political contributions allowed by law made in support of candidates, political organizations, or public policy issue campaigns. These contributions are subject to review by the Best Buy Board of Directors. For a copy of this information along with Best Buy’s contribution criteria, please see Best Buy’s Political Activity & Public Policy Report.
The PAC is Best Buy’s federally-registered non-partisan political action committee governed by the Federal Elections Campaign Act. The PAC allows eligible employees to pool their personal funds on a voluntary basis with other employees to help elect candidates to Congress who appreciate and understand the issues important to Best Buy and the retail industry. The PAC’s activity, including all receipts and disbursements are reported regularly to the Federal Election Commission and available for public viewing by visiting www.fec.gov.
As a Best Buy employee:
Each year, under the direction and approval of the Sr. Vice President, Communications, Public Affairs and Corporate Responsibility, the company develops public policy positions that have a direct impact on our business. The Government Relations team manages these issues throughout the local, state and federal legislative sessions. For additional information, please see www.bluegrassrootsnetwork.com and Best Buy’s Political Activity & Public Policy Report.
For questions about this policy, please contact Government Relations: GovernmentRelations@bestbuy.com
© 2003-2010 Best Buy. All rights reserved. Best Buy, the Best Buy logo, the tag design and BestBuy.com are trademarks of BBY Solutions, Inc. For personal, noncommercial use only.
Accessing this site inside or outside of work is voluntary and is not a condition of your employment, and you will not be paid for your time. This website and all material contained within are solely for use by Best Buy Co. and its employees.