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, what 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 and political process through regular and constructive engagement with government officials, policymakers and stakeholder groups. The goal of Edwards Lifesciences’ 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, as well as critical care and surgical monitoring, to improve patient outcomes and enhance lives.

Edwards is committed to transparency in its political activities. The company discloses its political activities to appropriate state and federal government agencies, in accordance with applicable laws and regulations. Beginning in late 2015, the company expanded its disclosure activities through this website, providing customers, patients and shareholders easier access to this information and the policies that drive our activities. The policies outlined on this site became effective on January 1, 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 41.

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 (EWPAC), 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. EWPAC 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 Utah Lieutenant Governor’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 are:

Up for election in current cycle, or
Serving on committee(s) with jurisdiction over innovation and patient-related relevant issues, including Medicare, FDA, and tax and trade issues, or
Historically supportive of medical device industry and efforts to increase patients’ access to medical technologies, or
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 EWPAC contributions to ensure that contributions made during the year are consistent with our corporate policies.

Contribution disclosure

Federal PAC contributions Q1-Q2 2018

State corporate contributions Q1-Q2 2018

Previous contributions

Federal PAC contributions 2017

State corporate contributions 2017

Federal PAC contributions 2016

State corporate contributions 2016

Federal PAC contributions 2015

State corporate contributions 2015

Trade Association and lobbying-related activities

Edwards Lifesciences 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
	2015	2016	2017
Advanced Medical Technology Association (AdvaMed)	$44,433	$49,777	$52,440
Healthcare Leadership Council**	$23,000	NA	NA
California Life Sciences Association (CLSA, formerly CHI)	$28,210	$12,120	$9,090

*Includes trade association memberships with total annual dues greater than $50,000.

**Edwards Lifesciences membership ended in 2015.

Edwards Lifesciences does not have visibility into these organizations’ detailed political expenditures; however, all of these organizations have affirmed that less than 1% of their budgets are devoted to political spending. AdvaMed and CLSA each have separate funds devoted to political activities:

Edwards contributed $5,000 from its corporate treasury in 2017 to the AdvaMed California Political Action Committee, devoted to supporting California State Political Candidates. Candidates supported by the AdvaMed California PAC can be found here.
Edwards contributed $7,300 from its corporate treasury in 2017 to the CLSA Political Action Committee, devoted to supporting California State Political Candidates. Candidates supported by CLSA 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 Lifesciences Government Affairs function has authority over the company’s political activities and spending decisions. The Senior Director of Government Affairs, Leah Kegler, is responsible for reviewing and certifying that Edwards’ activities are in compliance with our political disclosure policy.

The Edwards Lifesciences Global Internal Audit function reviews on a periodic basis compliance of Edwards activities with its policies. Internal Audit provides the Edwards Lifesciences Audit Committee of the Board of Directors with reports when activities fall out of compliance with these policies.

Edwards Lifesciences reviews political activities with the Corporation’s Board of Directors on a periodic basis. Beginning in 2016, the Board’s Compensation and Governance Committee will review 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.
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 Lifesciences 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.