DXC GOVERNMENT AFFAIRS

DXC Technology’s (DXC) Government Affairs function, resident in the company’s Ethics and Compliance Office, engages worldwide in public policy activities aligned with its business objectives.  The function plays a strategic support role in the development and growth of DXC’s public sector and other businesses, in efforts to influence legislation and regulation, in the management of regional and local risks and opportunities, and in efforts to preserve DXC’s reputation as a reliable partner and accountable employer.

In keeping with DXC’s CLEAR Values and Code of Business Conduct, DXC pursues its public policy agenda in strict accordance with the law and its global Government Affairs policy which, among other things, establishes clear governance for Lobbying, Political Contributions, and Contact with Government Officials.

LOBBYING—DXC’s Government Affairs policy establishes the following requirements:

• All DXC lobbyists shall be approved by the VP, Ethics, Compliance, and Government Affairs.
• All DXC lobbyists shall be subject in advance to an integrity review and screened in for conflicts of interest.
• All DXC lobbyists shall maintain appropriate business records of their lobbying activities and report them to DXC.
• DXC shall comply with all regulatory and statutory lobbying disclosure obligations.

POLITICAL CONTRIBUTIONS—DXC’s Government Affairs policy establishes the following requirements:

• DXC, its board members, and employees shall comply with all U.S. federal and state and local government laws that restrict or seek to create transparency around political contributions by corporations and their personnel.  As such, in the U.S. and around the world, DXC funds and other assets shall be offered as political contributions only as allowed by law.
• DXC’s political contributions shall be authorized and made in keeping with the strategies articulated by the corporate contributions plan.
• DXC shall establish and maintain a duly registered Political Action Committee (PAC) to provide lawful financial contributions on behalf of DXC to select candidates in U.S. federal and state campaigns (as allowable).
• Individual PAC contributions from eligible DXC employees shall be made voluntarily; PAC contributions shall not be mandatory.
• As allowable by law, DXC or its PAC may make contributions to state candidates and to state and local government ballot measures, PACs, and political party committees.  All such contributions shall comply with DXC’s pre-authorization and reporting requirements.
• As required by law, the DXC PAC shall report receipts and disbursements periodically with the U.S. Federal Election Commission.

CONTACT WITH GOVERNMENT OFFICIALS—DXC’s Government Affairs policy makes clear with the following statements DXC’s zero tolerance stance on corruption:

• DXC does not make or take kickbacks or bribes to or from anyone to obtain, retain, or direct business, or to secure any other business advantage—nor does DXC permit any other person or entity to do so on its behalf—at any time or in any circumstance.
• No one shall ever use un-reimbursed personal funds to circumvent these prohibitions.