Political Engagement Report

In this Report, we provide important information on how we participate in the political process.

Download July - December 2023 Report

Overview

AT&T is a proud member of the communities where we live and work. We strive to bring our customers the innovation they demand, provide shareholders value on their investment and be a responsible corporate citizen. A critical component of these efforts is actively participating in the political process. We do this through corporate political contributions, memberships in trade associations, contributions to other tax-exempt organizations, Employee Political Action Committee (PAC) contributions and lobbying expenditures.

In this Report, we provide important information on how we participate in the political process. Every action we take is in strict compliance with local, state and federal law, but that is only the beginning. Our decisions are grounded in AT&T’s public policy positions and the best interests of our business and our employees, without regard to political party affiliation and always mindful of our Company Purpose, our Code of Business Conduct, and our Political Engagement Policy. In addition, the Governance and Policy Committee (GPC) of the Board of Directors provides strong oversight and we have a robust internal authorization process for all these activities. Together, these processes and protections are directed to one objective: to ensure we have an effective, responsible voice in policy discussions that impact our business, our employees, and our customers.

Twice yearly, in accordance with applicable law, campaign finance and disclosure rules, and our own internal policies, we publicly disclose U.S. political contributions via this Report. We also identify organizations that report using some or all our contributions for lobbying activities.

This Report provides retrospective information for the applicable period. Past support of a candidate or an organization cannot be assumed to mean that the Company and/or its Employee PACs are providing similar support today. The Company and its Employee PACs reserve the right to discontinue support of any recipient and may have discontinued giving to some recipients listed in this Report.

Public Policy Positions

Public policy creates the “rules of the road” for companies like AT&T, and now, more than ever, we need these rules to keep pace with the relentless innovation and limitless possibilities that drive America’s future.

At AT&T, we are cognizant of the important role corporations play in the health of our society. Our purpose is to connect people to greater possibility, and we do that in many ways.

Our local programs lift up underserved neighborhoods and disadvantaged communities. Our employees volunteer millions of hours of service each year to make communities stronger. Our employee and retiree benefits, supporting more than 900,000 people, are among the best in the nation. Our culture fosters inclusion to provide a workplace where all employees can be their best. Our technology and our leadership are tackling climate change by reducing emissions for our company and for our customers. Our millions of dollars of philanthropy each year and our partnership programs support non-profits that fill critical care gaps for those in need.

These actions and commitments are designed to improve the social fabric of our society and make possible a better future for people in the communities in which we live and work.

Delivering on our purpose also requires us to engage in the political process. Public policies set by federal and state legislators elected by the nation’s voters heavily affect AT&T, as we are more regulated than most companies. We actively participate in public policy debates to educate lawmakers about the impact of various policies on our business, and in the political process to support candidates in accordance with our business objectives.

Political Engagement Priorities

U.S. Economic Stability and Growth

• AT&T provides essential communications services that power commerce and connections around the world. We support policies that enable us to hire workers, innovate for customers and deliver sustainable long-term shareholder value to millions of Americans with shares held in our company individually or in managed funds. Policies that support and encourage economic stability promote AT&T’s ability to expand into new business opportunities and, in turn, further invest in communities around the country.

Resilient Infrastructure, Technological Progress and Technology Access

• Through a mix of private investment and partnerships with communities, governments, non-governmental organizations, and other businesses, AT&T seeks to bring high-speed internet connectivity to businesses and households, including those who cannot afford it or currently do not have access to it. We support policies that help foster connectivity and help support our ability to deploy advanced networks. Such advanced technological capabilities strengthen AT&T’s competitive position in the marketplace and provide national economic security benefits for the country and its residents.

Employee Opportunity

• AT&T is proud to provide economic opportunity and upward mobility to our employees through good-paying jobs; a safe and inclusive workplace; and robust healthcare and retirement benefits. We support policies that make it easier to hire and retain a skilled workforce with good pay and benefits. Our workforce reflects the world we live in, our millions of customers and the diverse communities we serve. Policies that enable AT&T to attract and hire top talent, including union-represented employees, enable us to provide family-sustaining wages with strong benefits. Our employees help their friends, families, local businesses, and schools connect to greater possibilities.

These Political Engagement Priorities are identified by the company’s Senior Executive Vice President of External and Legislative Affairs through a process that includes:

• Conferring with business co-workers about the risks and opportunities facing the business operations and its workforce.
• Assessing the competitive climate and the rules and regulations required for a level playing field for fair competition.
• Analyzing the political environment to understand emerging policies and their impact on our ability to serve our customers.

Thereafter, the priorities are discussed and approved by AT&T’s CEO, and the Governance and Policy Committee of the Board of Directors.

Finally, we prepare and publish our Political Congruency Report, which assesses the congruency of votes made by recipients of political contributions from AT&T and from AT&T’s Employee PACs with our Political and Corporate Sustainability Priorities.

As AT&T assesses public policies that impact business objectives, we also are mindful of complex societal issues that can affect us. These issues are most immediately addressed through the company’s social programs, philanthropy, benefits, and community involvement. Although no single social issue or criterion determines our engagement, AT&T and Employee PAC Disbursal Committee members do consider the impact of such issues on the Company, its shareholders and its employees.

Single issue advocacy groups and non-governmental organizations often urge AT&T to weigh in on controversial, hotly debated issues. We are thoughtful in our response to such requests. If an issue has an impact on our business interests, or direct bearing on our workforce, and/or we have subject matter expertise, we may opt to engage publicly. Given the size of our employee population, AT&T workers are not monolithic in their opinions and their views on societal issues tend to reflect the diverse views of the broader U.S. population.

An area of deep knowledge and expertise for our company is how to best eliminate the digital divide, which is one of the highest priorities of the federal and state governments. We have worked hard to inform policymakers in their efforts to enable low-income households to afford access to the internet, and to spur investments in networks in rural, unserved areas. These policy efforts are bolstered by a deep commitment to philanthropy, volunteerism, and community programs. Eliminating the digital divide for those for whom no network is available or for those who cannot afford connectivity will have a significant impact on our economy and our society. Connecting the unconnected confers vastly greater opportunities in employment, education, healthcare and wellbeing, and our employees are extremely proud of the role we play in expanding those opportunities.

Additional information about AT&T’s positions on a variety of public issues can be found in the issue briefs located on the Company’s Public Policy main page and our Corporate Responsibility website.

Political Contributions

Political contributions, where permitted, are an important part of the political process. To encourage public policies that help us be the best connectivity provider in America, AT&T contributes prudently to state and local candidates and political organizations, as permitted by law, when such contributions advance AT&T’s business objectives and the interest of our shareholders.

Our company and others are sometimes targeted by ideological organizations exerting pressure on us to contribute in alignment with their political goals, or to cease participation in the political process altogether. They often use selective data to criticize our political engagement, and conflate contributions to individual candidates with support of a policy opposed by their organization, even though that policy position had nothing to do with AT&T’s Corporate Political Contribution and our Employee PAC contribution decisions. Often AT&T and our Employee PAC have contributed significantly to individual candidates who support their organization’s preferred policy, but they ignore those contributions in releasing data.

We believe prudent policies result when lawmakers on both sides of the aisle work together toward innovative solutions. AT&T and our Employee PACs contribute to both Democrats and Republicans, which helps foster a healthy dialogue and exchange of ideas to address pressing challenges. Companies like ours that support bipartisan engagement can help temper today’s often divisive political discourse and mitigate polarization.

As our officers, executives and committee members make contribution decisions, they are mindful of our Code of Business Conduct, our Political Engagement Policy and our Company Purpose, and make recommendations and decisions without regard for personal political preferences.

AT&T personnel consult with the AT&T Legal Department to ensure that contributions are lawful and consistent with applicable statutes, regulations, limits and guidelines. Further, no contributions are made in anticipation of, in recognition of, or in return for any official act or favor.

Elected officials hold varied and diverse views on a wide range of issues, reflecting those of our broader society and the voters who elect our nation’s political leaders. Contributions made by the Company or its Employee PACs to an individual or political organization do not mean the Company or its Employee PACs support or agree with every position taken by contribution recipients on every issue.

Policy issues can touch upon sensitive topics, such as race, sex, sexual identity, or social justice. If an elected official or candidate makes a controversial statement on any such issue, we consider the impact, nature and context of the statement, which helps inform future contribution decisions. Depending on the severity of the controversy, AT&T’s response will be escalated for review through various levels of senior leadership, which could include informing the General Counsel, CEO, and the AT&T Board of Directors' Governance and Policy Committee (GPC).

Our Political Engagement Policy is publicly available, and it details how we make the decision to contribute, the process by which we use to make the contributions, and which corporate leaders approve these expenditures.

Political Contributions Disclosures

This Report is intended to provide transparency regarding our corporate contributions, as well as contributions made by our Employee PACs. To summarize:

• Our employees can participate in the political process through Employee PACs. PAC disbursements support federal, state or local candidates and are disclosed in this Report.
• Where lawful, we make corporate political contributions to state and local candidates, political parties, PACs and ballot measure committees. Those contributions are disclosed in this Report.
• We do not make corporate political contributions to federal political parties or candidates for federal office.
• As a general practice, we do not make independent political expenditures or corporate political contributions to independent expenditure committees or to any non-candidate or non-political-party political committee organized under Section 527 of the Internal Revenue Code (e.g., Super PACs); however, if we do, we disclose them in this Report.
• Among other factors, contributions are generally made to candidates who support a strong private sector and show a free-enterprise philosophy, and all contributions are in accordance with our publicly stated political engagement priorities.

In addition, our disclosures extend beyond political contributions. When a trade association or other tax-exempt organization uses our contribution(s) for lobbying activities, we disclose them as described below.

Our latest contributions and disclosures can be accessed through the links found in the remainder of this Report.

Corporate Political Contributions

Trade Association and Other Tax-Exempt Organization Contributions

AT&T supports organizations that have significant public policy positions that impact our industry. We review differing policy issues, and those are taken into consideration when determining contributions or annual membership. Our participation in these various industry, trade and advocacy groups comes with the understanding that we might not always agree with all positions held by the organization and/or other members, and that we are committed to voicing our concerns as appropriate through the AT&T leaders who interact with these organizations.

AT&T contributes to trade associations and other tax-exempt organizations, including those organized under Internal Revenue Code Section 501(c)(6), that promote matters of importance to the industry on behalf of their members. The criteria for contributions to these organizations is found in our Political Engagement Policy, and includes restricting these organizations from using our contributions or payments for electioneering expenses.

We disclose organizations to which we contribute $50,000 or more where a portion of those contributions has been identified as used for lobbying. We make a reasonable effort to obtain from these organizations, or through other means, the portion of the Company’s payments that the organization allocates to lobbying expenditures, and we disclose those amounts.

We also contribute to tax-exempt advocacy organizations that engage in political activities, such as those organized under Internal Revenue Code Section 501(c)(4), where those organizations’ missions align with our policy interests. If a portion of our contribution has been identified as used for lobbying, we identify that organization in our disclosures. We make a reasonable effort to obtain from these organizations, or through other means, the portion of the Company’s payments the organization allocates to lobbying expenditures and we disclose those amounts. The criteria for contributions to these organizations is found in our Political Engagement Policy, and includes restricting these organizations from using our contributions or payments for electioneering expenses.

Employee PAC Contributions

AT&T Employee PACs are voluntary, non-partisan and provide eligible AT&T management employees an opportunity to collectively support public policy positions that are important to AT&T. In all, there are 30 separate state Employee PACs and a federal Employee PAC. Each AT&T Employee PAC has a chair, officers, a committee of employees who are engaged in PAC operations, and Articles of Operation outlining its operating procedures.

Our Employee Political Action Committee disbursal committee is comprised of geographically diverse employees from various parts of the company and who reflect the broader employee population. The employee PAC committees’ decisions are based on AT&T’s public policy positions and the best interests of the business and our employees. At the same time, our committees and those who make recommendations to our committees are mindful of our Company Purpose, our Code of Business Conduct, and our  Political Engagement Policy. All recommendations and decisions are made without regard to political party affiliation.

The criteria for PAC contributions and the disbursement guidelines and procedures are found in our Political Engagement Policy.

Lobbying

AT&T is committed to adhering to the highest ethical standards when engaging in all political activities. As such, AT&T complies with all federal and state laws and regulations for lobbying registrations and reporting. AT&T companies, employees and external lobbyists and firms must register as lobbyists as required by applicable law to represent the Company’s interests.

All lobbying registrations and expenditures reporting are done in strict compliance with these laws.

AT&T files federal lobbying reports quarterly with the Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate, pursuant to the federal Lobby Disclosure Act. To review the quarterly federal filings, visit the links above and select “AT&T” in the name search field.

AT&T files state lobbying reports with the appropriate state governing agencies in compliance with the requirements in respective states. These reports are publicly available in the respective jurisdictions and disclose the required lobbying information.

Governance

Board of Directors Oversight

The AT&T Inc. Board of Directors’ Governance and Policy Committee (GPC), comprised entirely of outside directors, is responsible for oversight of AT&T’s public policy priorities, activities and corporate political disbursements. As part of the GPC’s oversight of AT&T’s public policy activities, the GPC annually reviews the Company’s priorities, policies, practices and expenditures related to political contributions, as well as contributions to trade associations and other tax-exempt and similar organizations that may engage in public policy initiatives.

Corporate Political Contributions

Each year, the GPC recommends, and the AT&T Inc. Board of Directors authorizes, a maximum aggregate limit for contributions that can be made by AT&T for the purpose of supporting or opposing any party, candidate, political committee, ballot measure, or any political purpose connected to the same. Contributions must be permitted by, and in strict compliance with, applicable law. For 2023, this authorized amount was $6.0 million. The GPC receives annual reports about all political contributions made by the Company, offers guidance and provides a full report of these activities to the Board.

Trade Associations and Other Tax- Exempt Organizations

A full list of these contributions is shared with the GPC of the Board and the full Board on an annual basis for their review and guidance.

Executive Leadership Approval

AT&T’s Senior Executive Vice President External & Legislative Affairs, who reports directly to AT&T Inc.’s Chief Executive Officer, is responsible for overall management of and participation in the political process.

Corporate Political Contributions

Contributions to candidates and organizations is done with the intent to further our Political Engagement Priorities, disclosed earlier in this document. AT&T personnel consult with the AT&T Legal Department to ensure that proposed contributions are lawful and consistent with applicable statutes, regulations, limits and guidelines. Political contributions are reviewed and approved as to lawfulness by the AT&T Legal organization prior to being authorized.

All corporate political contributions must be approved by the Company’s Senior Executive Vice President – External and Legislative Affairs, or by a delegate if the amount is $2,500 or less. A report of all political contributions, regardless of amount, is reviewed annually by AT&T Inc.’s Chief Executive Officer and by the board.

Trade Associations and Other Tax-Exempt Organizations

AT&T has a rigorous approval process for contributions to trade associations and other tax-exempt advocacy organizations. Each proposed contribution must be in the best interests of the Company and our shareholders and intended as support for the AT&T’s Political Engagement Priorities.

These contributions must be approved by the Senior Executive Vice President External & Legislative Affairs or other senior leaders. A full list of these contributions is shared with the GPC of the Board and the full Board on an annual basis for their review and guidance.

Compliance

AT&T has established strict internal policies, processes, and compliance measures to ensure adherence to legal and regulatory requirements.

We employ a rigorous system for requesting, evaluating, processing, and authorizing all contributions. This mechanized system, which requires individual attention to each separate contribution request, manages contribution budgets and tracks spending limits and aggregation to ensure compliance.

Every political contribution request is legally reviewed, and all contributions are approved by management in strict compliance with our policy and procedures for contributions.

AT&T facilitates compliance with our policies and procedures regarding political activities, contributions and lobbying through regular training and reminders, periodic internal audits, and employee acknowledgments regarding compliance with AT&T’s policies governing political activities.

Specifically, the Code of Business Conduct includes provisions regarding political activity and contributions that provide guiding principles and practical application for employees. The Code of Business Conduct is reviewed annually by employees.

AT&T encourages our employees’ voluntary, personal participation in the political process, whether by voting, volunteering time, holding public office or contributing money to the candidates of their choice.

However, there are strict laws that apply to corporate involvement in the political process, and it is important that employees’ personal political activities are separate from their responsibilities to the Company. AT&T has a policy that instructs employees to maintain separation between their personal political activities and their activities on behalf of AT&T. Employees are advised that personal political activities must never occur on Company time, and no Company resources can be used.

It is the unequivocal policy of AT&T that no employee will be subject to any form of pressure, coercion or intimidation related to participation in political activities, nor shall any employee receive compensation or benefits for participating in personal political activities.