Mastercard’s Government Relations team oversees the Company’s public policy strategy, and political contributions and corporate political expenditures are approved by the Group Head of Global 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, and corporate political expenditures, if any, the Company’s political activity policies, and this Political Activity Statement. Mastercard maintains comprehensive internal compliance procedures to ensure that the company’s political activities fully comply with all laws, regulations, and company policies. Mastercard’s political activities, 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 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.ethics.gov. Copies of lobbyist disclosure reports and/or compiled data for states in which Mastercard is registered to lobby are available here:

• California - (http://cal-access.sos.ca.gov/Lobbying/Employers/)
• Florida - (http://www.leg.state.fl.us/lobbyist/index.cfm)
• Illinois - (http://www.cyberdriveillinois.com/departments/index/lobbyist/)
• Kentucky - (http://apps.klec.ky.gov/searchregister.asp)
• Louisiana - (http://ethics.la.gov/LobbyistData/SearchByCompRep.aspx)
• Massachusetts - (http://www.sec.state.ma.us/LobbyistPublicSearch/Default.aspx)
• Michigan - (http://miboecfr.nicusa.com/cgi-bin/cfr/lobby_srch.cgi)
• Missouri - (http://www.moethics.mo.gov/EthicsWeb/Lobbying/Lobbying.aspx)
• Nebraska - (http://www.nadc.nebraska.gov/l/)
• Nevada - (http://www.leg.state.nv.us/AppCF/lobbyist/)
• New Jersey - (https://wwwnet1.state.nj.us/lpd/elec/AGAA/lobby_reports.aspx)
• New York - (https://apps.jcope.ny.gov/lrr/Menu_reports_public.aspx)
• Ohio - (http://www2.jlec-olig.state.oh.us/olac/Reports/ReportsHome2.aspx)
• Pennsylvania - (https://www.palobbyingservices.state.pa.us/ACT134/Public/EnhancedSearch.aspx)
• Texas - (http://www.ethics.state.tx.us/dfs/search_LOBBY.html)
• Vermont - (http://vermont-elections.org/elections1/lobby_employers_seek.html)
• Washington State - (http://www.pdc.wa.gov/public/lobbyist/informationaboutlobbyist.aspx)

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

The U.S. Supreme Court recently 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 is a member of various trade associations and pays regular dues for such membership. The Company does not normally make additional, non-dues payments to support such group’s political contributions or independent expenditures. Examples of trade associations in which Mastercard is a member include: Financial Services Roundtable, Consumer Bankers Association, American Bankers Association, American Financial Services Association, Electronic Funds Transfer Association and Electronic Transactions Association. Mastercard does not direct how the dues paid to trade associations are spent. However, Mastercard will request from any trade association that receives $50,000 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. Notice of use of payments for the purposes described above from any trade association can be found here.

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; and/or
• representation of key states and districts where Mastercard has significant operations and interests.

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.

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 made during the first half of 2018 is available here. 

Archived Political Activity Disclosures can be accessed here.