Political Engagement

Equifax believes that transparency and accountability with respect to political expenditures are important.

Political Engagement Policy

This policy addresses political engagement by Equifax Inc. and its subsidiaries (the “Company”). 

  1. Background & Philosophy

The Company believes it is in the best interests of the Company and its shareholders to engage constructively and responsibly in the public policy and political process when necessary to advance and protect the long-term interests of the Company.  Therefore, we participate in the development of public policy that addresses issues affecting our industry, business, products, customers, employees and communities.  We do so in various ways, including educational outreach to elected officials on key public policy issues related to the Company’s business, voluntary political giving by eligible employees through the Equifax Inc. Political Action Committee (“Equifax PAC”), and membership in trade associations that help to advance our business objectives.

Therefore, the Board of Directors has adopted this policy to help ensure that any political engagement, including contributions and expenditures, is done in a manner consistent with the Company’s commitment to the highest standards of ethics and business integrity and to protect and enhance shareholder value. 

  1. Political Activities of Employees

While the Company values the rights and responsibilities of its employees to participate as individual citizens in the political process, decisions to do so are entirely personal and voluntary.  Employees engaging in political campaign activities are expected to do so solely as private citizens, and must at all times make clear that their views and actions are their own, and not those of the Company.  Employees may not use their position with the Company to coerce or pressure other employees to make political contributions or expenditures to, or support or oppose, any political candidates, elections or ballot initiatives.  Employees engaging in political activities must adhere to this policy, the applicable provisions of the Company’s Code of Ethics and Business Conduct and the Equifax Inc. Political Activity Guidelines.  

The Company provides an opportunity for certain eligible employees to voluntarily participate in the political process by joining the Company’s political action committee, the Equifax PAC.  The Equifax PAC allows eligible employees to pool their financial resources to support political candidates, campaigns and committees in furtherance of the best interests of the Company and its shareholders and employees.  The Equifax PAC is a separate legal entity, with its own oversight body, which is funded solely from voluntary contributions made by eligible employees (no corporate funds are used).  All Equifax PAC contributions are made in a legal, ethical and transparent manner in accordance with federal laws and regulations governing political action committees.  The Senior Vice President of External Affairs manages all Equifax PAC contributions in accordance with Equifax PAC governing documents.  All Equifax PAC contributions are fully and publicly disclosed in reports filed with the Federal Election Commission and can be viewed on the website of the Federal Election Commission at www.fec.gov.

  1. Political Contributions

Generally, it is the Company’s policy that it does not make contributions to political parties, candidates for public office or political organizations.  No company resources, including the use of company premises, use of company equipment or property, or monetary payments, may be contributed to any political candidate, political committee (other than for the administrative or solicitation expenses of Equifax PAC, as permitted by law), political party, ballot measure committee or to any other organization for the purpose of attempting to influence elections or ballot measures unless permitted under applicable law and approved in advance by the Company’s Senior Vice President of External Affairs, in consultation with members of the Company’s senior management, as appropriate.  In determining whether or not to approve any political contribution or expenditure, the Company’s Senior Vice President of External Affairs shall determine that the contribution appropriately advances the Company’s policy interests and business goals by examining relevant factors, including, but not limited to, the merits of the candidate, election or ballot initiative, the value of the contribution to the election or ballot initiative, the quality and effectiveness of the organization to which the contribution will be made and the appropriateness of the Company’s level of involvement in the election or ballot initiative.  

The Company is committed to complying with all federal, state and local laws and related regulations regarding the use of corporate resources in connection with federal, state and local election for political office or ballot initiative.  To that end, all political contributions and expenditures made by the Company must comply with the Foreign Corrupt Practices Act, and all other applicable laws and regulations in the jurisdictions in which the contributions are made, and adhere to this policy, the applicable provisions of the Company’s Code of Ethics and Business Conduct and the Equifax Inc. Political Activity Guidelines.  The Senior Vice President of External Affairs shall consult with legal counsel as appropriate to ensure compliance with applicable law.

  1. Lobbying

The Company engages in direct and indirect lobbying, or advocacy, in the United States at both the federal and state levels to advocate our positions on issues that affect the Company, our industry, business, products, customers, employees and communities. We have a responsibility to our customers, employees, communities and shareholders to represent their interests in public policy discussions that impact our business.

The Government Relations department, led by the Senior Vice President of External Affairs, is primarily responsible for implementing the Company’s political activities. The Government Relations department’s activities include development and advocacy of public policy, lobbying, membership in trade associations and outreach to other third party organizations on public policy issues of concern to the Company. 

The Company’s Government Relations department coordinates with relevant business units and functional departments, such as the legal department, to identify and prioritize public policy issues that are important to the Company. Key issues are reviewed by senior management and the Board of Directors, as appropriate. The Company advances these issues through direct and indirect advocacy.

  • Direct Advocacy - The Company’s Government Relations department engages with government officials and policy makers at the federal, state and local levels on legislation, regulations and policies that affect the Company. In addition to advocacy by Company employees, the Company retains outside consultants to support our political engagement.
  • Indirect Advocacy - The Company may be a member of various trade associations representing the interests of both our industry specifically as well as the broader business community that further the Company’s business, economic and community interests.  These associations keep the Company informed on developments and trends in its industry, and help the Company focus its advocacy in the most effective way.  The Company may communicate and advocate its positions through its memberships in concert with its industry and customer partners.  Some of the support provided to these organizations may be used by the firms for lobbying.  The Company’s participation as a member of these associations comes with the understanding that the Company may not always agree with all the positions of an organization or its other members.  Dues paid to these trade associations may be made with corporate funds if approved in advance by the Company’s Senior Vice President of External Affairs, in consultation with members of the Company’s senior management, as appropriate.

From time to time, the Company may also engage in indirect advocacy through its membership in other tax-exempt organizations that engage in lobbying or political activities.  Any membership in these organizations will be approved and managed by the Government Relations department.  

  1. Reporting and Compliance

The Company is committed to complying with all federal, state and local laws and related regulations regarding the reporting requirements for political contributions and expenditures.  Failure to comply with any applicable laws and regulations governing political activities subjects the individual and the Company to potential civil and criminal penalties.  Failure to comply with this policy subjects an employee to disciplinary action, up to and including termination of employment.

The Company will annually disclose, on its public website, information related to aggregate expenditures during the most recently completed fiscal year, if any, made at the direction of the Company’s officers with corporate funds specifically for the purpose of influencing the election or defeat of any candidate for federal, state or local political office or ballot initiative, with such content and in such a format as the Company’s officers reasonably deem to be appropriate.

The Company will also annually disclose, on its public website: (1) the names of any U.S.-based (A) trade associations, (B) tax-exempt organizations that write and endorse model legislation, and (C) 501(c)(4) social welfare organizations, in each case, that are engaged in U.S. lobbying activity, managed by the Company’s Government Relations department and receive annual payments from the Company of at least $50,000; and (2) the aggregate annual dollar amount paid by the Company to all such organizations, regardless of the $50,000 annual threshold.

  1. Review and Amendments

The Governance Committee of the Board of Directors annually reviews (1) Equifax PAC spending and corporate expenditures to influence public policy, including elections and dues to trade associations and (2) Equifax lobbying priorities and activities. In addition, this policy is reviewed periodically by the Governance Committee, and any amendments hereto must be approved by such Committee. 

Adopted February 16, 2017; Revised March 14, 2019

Corporate Political Contributions

Equifax makes a limited number of corporate political contributions at the state or local level where permitted by law. This includes corporate contributions to state candidates and political action committees in areas where the company has a significant presence.

Year

Aggregate Corporate Political Contributions

2018

$0

2017

$6,712

2016

$1,500

2015

$2,000

2014

$10,250