Political disclosure and accountability
Edwards Lifesciences corporate political disclosure and accountability
At Edwards Lifesciences, we conduct our business with honesty and openness, and in accordance with laws around the world. Edwards’ global business practice standards, which we call the Titanium Book, is a practical guide to help our employees in a dynamic, growing company understand business practices and make the right decisions.
Public policy is no exception. Public policy impacts our ability to help patients, and we are active in the policy making process through regular and constructive engagement with government officials, policymakers and stakeholder groups. The goal of Edwards’ policy and political process engagement is to advance sound public policy on areas related to the company’s focus on patient-focused medical innovations for structural heart disease to improve patient outcomes and enhance lives.
The Edwards Lifesciences Political Action Committee (Edwards PAC) operates in alignment with the values expressed in Edwards Lifesciences' Credo and strives to act as a trusted partner in creating a community unified to help patients in need.
Edwards PAC is a separate legal entity from the company; it is sponsored by Edwards and funded through employee contributions. Contributions to Edwards PAC are strictly voluntary.
Edwards is committed to transparency and discloses its political activities to appropriate state and federal government agencies, in accordance with applicable laws and regulations. In late 2015, the company expanded its disclosure activities through this website, to provide customers, patients, shareholders, and the general public easier access to this information. The policies outlined on this site drive our activities and became effective at the beginning of 2014.
Edwards’ policy on political activities
“We conduct political activity responsibly. It is in Edwards’ best interest to maintain good relationships with public officials. Every country has different laws about how we may engage in the political process. Whenever we advocate Edwards’ position to government authorities or offer support for any political purpose, we must obey the law. Specific individuals within Edwards’ Government Affairs organization have the responsibility for government relations activities on the Company’s behalf. Consult with them before contacting elected or appointed officials on a matter related to Edwards’ business.” Edwards’ Titanium Book, page 45.
All Edwards employees must provide a signature at the time of employment agreeing to uphold all of the company’s global business practice standards, including our policy on political activities. Non-hourly employees recertify that commitment annually.
Political disclosure and related policies
U.S. federal and state laws exist that prohibit and/or restrict the use of corporate treasury funds for political purposes. Corporate treasury funds may not be used to contribute to candidates for federal office. The Edwards PAC, made up of employee volunteers, makes contributions to candidates for federal office, and fully discloses its contributions on a regular basis to the Federal Election Commission. Edwards PAC contributions can be found here.
Corporate treasury funds may be used, where legally permissible, to contribute to candidates for state and local office. All contributions made by Edwards to state political candidates and parties are disclosed on a regular basis to the appropriate state oversight authorities, including the California Secretary of State. Edwards’ contributions to California state elected officials and parties can be found here. Edwards also follows the state of Utah's reporting guidelines for corporations and Edwards’ contributions to Utah state elected officials and parties can be found here.
Contribution/spending criteria
Edwards engages political organizations or entities, including:
- Individual candidates for local, state or federal office
- Political action committees, including “Leadership PACs”
- Political parties and their respective political action committees
At Edwards , corporate treasury funds may not be used to make payments to 527 groups, such as governors associations and "super PACs." Corporate funds may not be used for "independent expenditures" in connection with federal and state elections. In addition, corporate treasury funds may not be used for 501(c)(4) organizations. Edwards prohibits the use of corporate funds to influence ballot measures.
Edwards uses objective criteria to guide its political contribution decisions.
The criteria ensures that Edwards’ political donations support candidates or organizations supporting candidates, without respect to political party affiliation nor private political preference of individuals. The Edwards PAC supports those individuals/organizations who are:
- Historically supportive of medical device industry and efforts to increase patient access to medical technologies;
- Up for election in current cycle;
- Serving on committee(s) with jurisdiction over innovation and patient-related relevant issues, including Medicare, FDA, and tax and trade issues;
- Running for office in a district in or around which Edwards facilities or employees are located; or
- In a leadership role.
The Edwards’ Government Affairs team prepares an annual analysis of Edwards’ corporate political contributions and Edwards PAC contributions to ensure that contributions made during the year are consistent with our corporate policies.
Contribution disclosure
Twice a year, Edwards updates this website; the previous year's contributions are posted in February and a mid-year update is posted in August.
Previous contribution
Trade Association and lobbying-related activities
Edwards is a member of several industry and trade groups, including organizations that engage in lobbying activities.
Edwards believes that membership in these organizations is consistent with the interests of patients, employees, the company and shareholders. The following table lists the amount of Edwards dues spent on federal-related lobbying activities.
Federal-related Lobbying Expenditures by Certain U.S.-Based Trade Associations*
| Payee | Portion of dues Spent on federal lobbying |
| 2021 2022 2023 | |
| Advanced Medical Technology Association (AdvaMed) | $30,284 $13,122 $92,920 |
| Medical Device Manufacturers Association (MDMA) | $19,500 |
| California Life Sciences (CLS) | $14,490 $18,375 $21,000 |
*Includes trade association memberships with total annual dues greater than $50,000.
Edwards Lifesciences does not have visibility into these organizations detailed political expenditures; however, they have all affirmed that less than 1% of the organizations' budgets are devoted to political spending. AdvaMed and CLS each have separate funds devoted to political activities:
- Edwards contributed $5,000 from its corporate treasury in 2023 to the AdvaMed California PAC, devoted to supporting California State Political Candidates. Candidates supported by the AdvaMed California PAC can be found here.
- Edwards contributed $8,100 from its corporate treasury in 2023 to the CLS PAC, devoted to supporting California State Political Candidates. Candidates supported by CLS PAC can be found here.
In accordance with the law, Edwards Lifesciences files quarterly reports regarding our federal lobbying activities with the Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate. These reports are available by searching for "Edwards Lifesciences" as a "Registrant" on the U.S. Senate's website.
Oversight
The Edwards Government Affairs function has authority over the company’s political activities and spending decisions. The Head of Global Government Affairs, Dirksen Lehman, is responsible for reviewing and certifying that Edwards’ activities are compliant with our political disclosure policy.
The Edwards Global Internal Audit function reviews on a periodic basis compliance of Edwards activities with its policies. Internal Audit provides the Edwards Audit Committee of the Board of Directors with reports when activities fall out of compliance with these policies.
Edwards reviews political activities with the Corporation’s Board of Directors on a periodic basis. Since 2016, the Board’s Compensation and Governance Committee has reviewed Edwards' political activities to ensure compliance with its policies for political transparency. This includes review and approval of:
- The company’s policy on political expenditures;
- Political expenditures made with corporate funds; and
- Payments to trade associations and other tax-exempt organizations that may be used for political purposes.
Compliance
To meet our commitment to high ethical practices, Edwards has a compliance program designed to detect and prevent behaviors that could harm our company and the people we serve. Edwards employees are responsible for reporting wrongdoing, should any occur within the company. If an employee believes a law has been broken or that the Edwards Global Business Practice Standards have been violated, it must be reported.
No one will be punished for asking about possible breaches of law, regulation or Edwards policy. We absolutely prohibit retaliation against anyone who raises or helps address a compliance matter in good faith.
The Edwards Integrity Helpline is an external reporting service operated by an independent company, staffed by non-Edwards employees. Translators are available for non-English speakers. The Helpline can be contacted either by telephone or via the internet. To contact the Edwards Integrity Helpline, call 877.219.3178. Reports to the Helpline may be made via the internet: Inside the U.S.: reportlineweb.com/edwards or Outside the U.S.: iwf.tnwgrc.com/edwards.
More information on the corporate responsibility program at Edwards including details on our compliance program can be found at corporate responsibility program page.