Western Union 2014 Annual Report Download - page 109

91 | The Western Union Company – Proxy Statement
Proposal 6 PROXY STATEMENT
NOTICE OF 2015 ANNUAL MEETING OF STOCKHOLDERS AND PROXY STATEMENT
BOARD’S STATEMENT OPPOSING THE PROPOSAL
After careful consideration, and for the following reasons, the Board believes that the proposal is not in the best
interests of the Company or its stockholders, and the Board recommends voting “AGAINST” this proposal.
The Company has historically made an extremely limited number of political contributions. The
Company’s political contributions are not financially material to the company. In 2014, 2013, and 2012, these
contributions totaled approximately $8,500, $11,500 and $13,700 respectively. In 2014, the Company’s total
expenses relating to political contributions were de minimis when compared to the Company’s total operating costs
of approximately $4.5 billion.
The Company is both transparent and accountable regarding its political contributions. On a limited basis
we have pursued and will continue to pursue efforts to help inform public policy decisions that have the potential
to affect our customers, employees, and the communities in which we operate. To the extent this is done through
a small number of corporate political contributions, such contributions are already strictly controlled. Consider our
current standards, policies and practices regarding corporate political contributions:
• The Company maintains a formal policy regarding political activities, political contributions and lobbying
activities, which is contained in the Company’s Code of Conduct and which is publicly available in the
“Corporate Governance” section of our Investor Relations website.
• Our policy contains standards for participating in the political process for both the Company and its
employees.
• With respect to political contributions, the Code of Conduct provides that the permission of the Company’s
General Counsel’s office is needed before any political contributions are made on behalf of the Company.
• The Code of Conduct also provides that a senior executive officer of the Company’s Government Relations
department and the General Counsel’s office be consulted prior to contacting a government official or
retaining a lobbyist.
The Company is also transparent and accountable regarding its membership in trade associations.
Participation as a trade association member comes with the understanding that we may not always agree with all
of the positions of the organizations or other members but that we believe that the associations we belong to take
many positions and address many issues in a meaningful and influential manner and in a way that will be to the
Company’s benefit. We believe the below practices allow the Company to reap these benefits while remaining both
transparent and accountable:
• Although we must pay regular membership fees, we do not normally make additional non-dues
contributions to support a group’s targeted political contributions.
• We closely monitor the appropriateness and effectiveness of the political activities undertaken by the most
significant trade associations of which we are a member.
Significant disclosure regarding the Company’s political activities and related policies is already publicly
available. Consider the following:
• Under federal law, all contributions by the Western Union Political Action Committee, the sole political
action committee affiliated with the Company, are required to be reported, and a list of such contributions
is publicly available at the website of the United States Federal Election Commission.