Political disclosure and accountability

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 Lifesciences 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 Lifesciences Political Action Committee (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 Lifesciences, 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 it's political contribution decisions.

Edwards' political donations support candidates or organizations supporting candidates, without respect to either political party affiliation or private political preference of individuals, who enable our company to pursue our strategy of patient-focused innovation consistent with the culture defined by the Edwards Credo and meet the following criteria:

• Historically supportive of medical device industry and efforts to increase patients’ 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 Lifesciences’ corporate political contributions and Edwards PAC contributions to ensure that contributions made during the year are consistent with our corporate policies.