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Morgan Stanley
Corporate Political Contributions Policy Statement
This Policy sets forth basic principles concerning Morgan Stanley’s
political contributions.
As a global financial institution, Morgan Stanley is committed to being
a responsible corporate citizen and an effective participant in the legislative
and regulatory process. Morgan Stanley participates in the public policy
arena on a wide range of issues that are important to Morgan Stanley shareholders,
clients and employees, including issues relating to the financial regulatory
environment worldwide, the growth and stability of the global economy and
healthy capital markets. This participation includes dialogue with government
officials in the many jurisdictions in which it operates, including U.S.
federal and state governments across the U.S.
COMPLIANCE AND OVERSIGHT
Morgan Stanley is committed to complying with all applicable laws relating
to political contributions. The activities described in this Policy are
conducted in a transparent manner and consistent with legal and regulatory
requirements. The Morgan Stanley Code of Conduct and Global Policy on U.S.
Political Contributions and Activities govern the political activities
of the Firm, our employees and the Morgan Stanley Political Action Committee
("MSPAC"). These Policies are designed to help Morgan Stanley
and our employees act in compliance with applicable laws and regulatory
requirements as well as this Policy. The Nominating and Governance Committee
of the Morgan Stanley Board of Directors oversees Morgan Stanley’s
corporate political contributions, if any, and policies relating to corporate
political contributions.
CORPORATE POLITICAL CONTRIBUTIONS
Morgan Stanley does not make corporate contributions in the U.S. at the
federal, state or local level to candidates, political party committees,
ballot committees or political action committees even when permitted to
do so by applicable law. Further, Morgan Stanley does not use corporate
resources for independent expenditures or electioneering communications,
as defined by U.S. federal election law, and does not make contributions
to “Super PACs” that accept corporate contributions to make
independent expenditures in connection with U.S. elections.
MORGAN STANLEY POLITICAL ACTION COMMITTEE
Federal election law allows corporations to establish political
action committees, which may make contributions to federal candidates,
state candidates (as permitted by law) and other committees. In the U.S.,
Morgan Stanley sponsors MSPAC, a federal political action committee registered
with the Federal Election Commission. Morgan Stanley does not sponsor any
state or local political action committees. MSPAC is funded solely through
voluntary employee contributions. As legally permitted, Morgan Stanley
supports the modest cost of administering the MSPAC; however, corporate
funds are never contributed to MSPAC.
MSPAC contributes on a bi-partisan basis to U.S. federal candidates and
political committees and does not make contributions in connection with
U.S. presidential elections or U.S. state or local elections. Decisions
regarding MSPAC’s contributions are made by Government Relations,
under the oversight of the MSPAC’s board. The MSPAC’s board
of directors has broad representation from employees. Contribution decisions
are not made to reflect the personal political views or interests of senior
management. Contribution criteria considered when the MSPAC makes contribution
decisions include:
- the candidates’ views on issues relevant to Morgan Stanley,
its shareholders, clients and employees;
- the candidate’s
leadership positions;
- the jurisdiction of the Congressional committees
on which the candidate serves; and
- the candidate’s representation
of a jurisdiction where Morgan Stanley has a significant employee presence.
PUBLIC REPORTING AND DISCLOSURE
Morgan Stanley and MSPAC comply with all legally required disclosure
requirements, including the Federal Election Campaign Act, Municipal Securities
Rulemaking Board Rule G-37, Investment Advisers Act Rule 206(4)-5 and Commodity
Futures Trading Commission Rule 23.451. MSPAC’s political contributions
are reported to the Federal Election Commission and are publicly available
at www.fec.gov and all contributions required to be disclosed by the Honest
Leadership and Open Government Act of 2007 are reported to the U.S. Congress.
Morgan Stanley prohibits corporate political contributions under this Policy,
and will post to its public website records of prior year’s contributions
demonstrating compliance with that policy.
Initially Adopted December 2004
Amended and Restated as of August 2013
Click here for the Morgan Stanley Political Contributions Disclosure Statement.
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