Code of Conduct

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Corporate Compliance

Mastercard Ethics Helpline

You may choose to report a violation, or raise a question or concern by contacting the Mastercard Ethics Helpline. The Ethics Helpline is a confidential reporting service provided on behalf of Mastercard by a third-party to enable you to file a report in a confidential and, if you choose, anonymous manner where permitted by law. (Local privacy and data protection laws may restrict or limit the availability of the Ethics Helpline.) You may contact the Ethics Helpline by telephone at (800) 405-9318 (please click here for local dialing instructions) or (2) by filing a web-based report at www.mastercard.ethicspoint.com.

Mastercard prohibits retaliation against any person who, based on a reasonable belief, raises a concern that a violation of the law, the Code of Conduct or one of Mastercard’s other policies has occurred, is occurring, or is likely to occur, or who participates in an investigation relating to such concern.

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Privacy & Data Protection Report Our Data Government Requests for Data Commitment to Privacy & Data Protection

Mastercard believes our customers and cardholders have a right to understand how their personal data is handled, and we consider it our responsibility to provide them with the most current and state of the art privacy and security protections available. Mastercard has prepared the following report to explain our information practices, our commitment to privacy, as well as to increase transparency about our business.

Mastercard is a technology company in the global payments industry that connects consumers, financial institutions, merchants, governments and businesses worldwide. We facilitate the processing of payment transactions, permitting Mastercard cardholders to use their cards and other payment devices at millions of merchants worldwide. Our network provides consumers and businesses with a quick, convenient and secure payment method that is accepted worldwide. Our network also provides merchants with an efficient and secure means of receiving payment. We don’t issue the cards or extend credit. Our data relationship with our cardholders is quite limited. For the majority of our transactions we receive only the card account number with no other personal information, not even the cardholder’s name.

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Mastercard receives most of its data when it processes payment transactions; however, we receive a limited amount of data for processing these transactions. We receive the card account number, the merchant name and location, the date and the total amount of the transaction. Importantly we do not receive the cardholder's name or other contact information. Nor do we receive information about the type of merchandise or service that is purchased. With this limited scope of information, Mastercard does not have the ability to identify a given card account number to a particular individual or to contact cardholders.

In addition to our core payment processing activities, we offer some optional programs. For these programs, cardholders make a conscious choice to opt-in after reviewing a notice. If a cardholder explicitly consents to participate in these programs, we may collect additional personal data, such as the cardholder's name and/or email address. For these opt-in programs, the use of the information provided is limited, and subject to the Company’s privacy by design process, which, as discussed further below, ensures that the Company refrains from the use of sensitive classes of information in a discriminatory manner.

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On occasion, Mastercard receives requests from law enforcement and other governmental agencies to provide data about our cardholders. Mastercard responds to these inquires by educating the inquiring agency about our limited data set; we then refer them to the appropriate financial institution, which has a more comprehensive financial and data relationship with the relevant cardholder. Due to our limited data profile, as explained above, Mastercard receives far fewer requests than other companies of our size and global reach. In those instances where a law enforcement or governmental agency further pursues a request, Mastercard ensures that they follow the required legal process for their country and jurisdiction. If there is a question about the legitimacy or scope of the request, we challenge it. Only when we are satisfied that the legal process is valid and appropriate do we deliver the narrowest possible set of data required to be responsive to the request.

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Mastercard builds privacy and data protection into the fabric of our business and has a longstanding commitment to privacy. The way we handle data is a vital part of our responsibility to our customers, cardholders and employees and is part of how we earn their trust.

  • Culture – We value privacy because of its value to people. Our corporate mission focuses the organization's efforts to make payments safe, simple and smart, and incorporates privacy into our business practices. We ensure privacy and data are protected and we regularly conduct training to assist this understanding.
  • Board/Executive Oversight - Mastercard’s commitment to privacy starts at the highest levels of the organization, with our Board of Directors and Chief Executive Officer. Mastercard has a Chief Information Governance and Privacy Officer and has created a global team of professionals responsible for administering a comprehensive privacy program. On an annual basis, or more frequently if needed, the Privacy Officer provides a comprehensive assessment of the program and the related risks to the Audit Committee of our Board of Directors.
  • Accountability – Mastercard holds itself accountable for how it collects, uses and discloses personal data. Mastercard discloses its privacy and data protection practices in one simple privacy notice for all of our transaction processing activities, including our use of data to fight fraud and identity theft. http://www.Mastercard.us/privacy/. On a bi-annual basis Mastercard's security, privacy and information practices are reviewed by United States financial regulators for compliance with the requirements of U.S. financial privacy laws.
  • Privacy by Design - We design, develop and deliver our products and services with respect for privacy. Our privacy program is dedicated to ensuring legal compliance with applicable laws, setting standards and policies and implementing best practices to ensure privacy is embedded throughout our product life cycle. We are committed to the responsible handling of personal information and we balance our product development activities with a commitment to transparency and non-discrimination.
  • Policy Development – We work with governments, regulators and policy makers to develop meaningful privacy laws and standards and balance the right to privacy against other legal obligations necessary for a free and secure society.

We are committed to engagement and understanding what our stakeholders think of our approach, our reporting on information practices and our commitment to privacy. If you have any questions or comments about this report or our privacy practices, please click here https://www.Mastercard.com/us/personal/en/general/contact-us.html or write to us at:

Chief Privacy Officer
Mastercard Worldwide
2000 Purchase Street
Purchase, NY 10577
USA

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Political Activity and Public Policy Statement Oversight of Political and Public Policy Activity Trade Associations, Super-PACs and Independent Expenditures made by the Company Mastercard PAC State and Local Contributions Archived Political Activity Disclosures

Mastercard is committed to engaging appropriately in the political process and policy arena in a manner that informs and affects the debate concerning issues related to our business, investors and customers including but not limited to payment system innovation, data privacy, the regulation of digital transactions, taxation, and other issues disclosed in the company’s public filings. We strive to engage on these issues in the most responsible and ethical way. Mastercard complies with all applicable laws and regulations in connection with the Company’s political and public policy activities. Any such activities in which Mastercard engages are based solely upon the best interests of the Company and are made without regard to the private political preferences of its officers and/or executives. Mastercard will semi-annually disclose on its website political contributions and independent expenditures, if any. As used in this statement, “political contributions” are Mastercard PAC contributions as well as corporate contributions to campaign committees, party committees and political committees where permitted by state law, and “independent expenditures” are funds used for communications that expressly advocate the election or defeat of a candidate that are not coordinated with any candidate.

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Mastercard’s Government Relations team oversees the Company’s public policy strategy, and political contributions and corporate political expenditures are approved by the Executive Vice President, Public Policy. The Nominating and Corporate Governance Committee of the Board of Directors is responsible for overseeing Mastercard’s public policy activities and at least annually will review political contributions, trade association dues used for political purposes, corporate political expenditures, lobbying efforts and strategies, the Company’s political activity policies, and this Political Activity and Public Policy Statement. Mastercard maintains comprehensive internal compliance procedures to ensure that the company’s political and public policy activities fully comply with all laws, regulations, and company policies. Mastercard’s activities in this area, and this Political Activity Statement are reviewed on an annual basis by outside counsel.

Lobbying Efforts; Federal and State Filings

The payment systems policy landscape is always evolving and Mastercard believes it is in the interest of the Company, stakeholders and customers to actively engage in the discussion with policymakers through lobbying efforts and, where allowed by law and to the extent Mastercard deems appropriate, direct contributions to state candidates and campaigns. Mastercard’s lobbying disclosure reports list all of the issues on which the company engages and provide an overview of the company’s legislative and policy priorities and amounts spent on such efforts at any given point in time. An annual summary of these issues and the amounts reported on the Company’s disclosure reports is available here. Mastercard does not use any corporate resources to mobilize employee grassroots efforts.

Mastercard files all state and federal campaign finance and lobbying disclosure reports in a complete and timely manner in accordance with applicable requirements. Copies of federal lobbyist disclosure reports are available here: www.lobbyingdisclosure.house.gov. Copies of lobbyist disclosure reports and/or compiled data for states in which Mastercard is registered to lobby are available here:

Questions about Mastercard’s political activity statement should be directed to the Corporate Secretary, Mastercard, 2000 Purchase Street, Purchase, New York 10577.

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The U.S. Supreme Court held unconstitutional laws prohibiting corporate contributions for independent expenditures, including contributions to groups known as “Super -PACs”. Super- PACs, which are political committees registered with the Federal Election Commission (FEC) solely for the purpose of funding independent expenditures, are required to be transparent and disclose all contributions and expenditures on regular reports filed with the FEC. To the extent the Company determines to contribute to Super PACs or the Company makes any Independent Expenditures, information regarding such contributions will be made available here.

In connection with its business initiatives, Mastercard joins various trade associations and pays regular dues for such membership in order to communicate with other companies on issues of mutual interest and to be part of an important public education effort regarding our industry’s goals and challenges. Trade associations provide specialized services to their members, including monitoring legislative and regulatory agendas, providing data and analysis, and advancing public policy through a collective voice. Participation in a trade association does not mean that we agree with every position or policy the association takes; however, we actively work within our trade associations to try to shape their policies to align with Mastercard’s objectives. All trade association memberships are reviewed and approved initially and annually thereafter by the Executive Vice President, Public Policy to determine whether membership is warranted based on the Company’s evolving business goals and strategies.

The Company does not normally make additional, non-dues payments to support a trade association’s political contributions or independent expenditures. A list of the U.S.-based trade associations that received $25,000 or more from the Company during the calendar year can be found here. For each of those associations, Mastercard discloses the percentage of the payment that the trade association reported was used for lobbying. Mastercard does not direct how the dues paid to trade associations are spent. However, Mastercard will request from any trade association that receives $25,000 or more from the Company during a calendar year, information regarding that portion of the Company’s dues and any other payments, if any, used for political contributions or independent expenditures. For all payments to 501(c)(4) organizations, Mastercard restricts its funds from being used for election-related activities. Notice of use of payments for the purposes described above from any trade association can be found here.

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Federal law prohibits the use of corporate resources to directly support or oppose candidates or political committees. However, eligible Mastercard employees may participate in the political process by making voluntary contributions to the Mastercard Political Action Committee (the “PAC”). Mastercard will not reimburse any person for making contributions to the PAC or for any other political contribution. The PAC’s decision to engage in the political process through contributions is based in part on the following criteria:

  • support for, or expertise on, issues of importance to Mastercard;
  • seniority on committees with jurisdiction over issues affecting Mastercard;
  • leadership positions within Congress;
  • representation of key states and districts where Mastercard has significant operations and interests;
  • commitment to democracy, constitutional protections and the rule of law; and/or
  • respect and tolerance for a diversity of views, leadership on matters of social impact, adherence to high standards and exemplary ethical character

The Board of Directors of the PAC, comprised of Mastercard employees, provides oversight of the PAC’s activities and participates in decisions regarding PAC contributions. The PAC’s activities are fully transparent and heavily regulated by the FEC. A list of PAC contributions is available here.

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The laws of many U.S. states prohibit the use of corporate resources to directly support or oppose candidates or political committees. In certain states where permitted by law, Mastercard may decide to engage in the political process through political contributions or independent expenditures based in part on the following criteria:

  • support for, or expertise on, issues of importance to Mastercard;
  • seniority on committees with jurisdiction over issues affecting Mastercard;
  • leadership positions within state legislatures; and/or
  • representation of key regions or localities where Mastercard has significant operations and interests.

Where permitted by law, Mastercard may make contributions to support or oppose a state ballot initiative or referendum that could impact the company’s business interests or public policy objectives.

A list of contributions to state candidates, parties, political committees and ballot initiative/referendum is available here.

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Archived Political Activity Disclosures can be accessed here.

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Non-Employee Director Stock Ownership Guidelines

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