Background – merger of United Technologies Corporation and Raytheon Company
The disclosure in this section relates to the policies and practices of Raytheon Technologies Corporation (“Raytheon Technologies”), except for certain historical information that relates to United Technologies Corporation (“UTC”) and Raytheon Company (“RTN”), as specifically referenced. On April 3, 2020, RTN became a wholly owned subsidiary of UTC, in connection with the merger of the two companies (the “Merger”). Following the Merger, UTC was renamed Raytheon Technologies Corporation.
Raytheon Technologies and its employees have a legitimate interest in participating in public policy debates. The Company’s government relations initiatives are intended to educate and inform officials and the public on a broad range of public policy issues that are important to its businesses. These initiatives are consistent with the interests of Raytheon Technologies’ shareowners, and are not based on the personal agendas of individual directors, officers or employees.
Company employees are encouraged, in their personal capacities, to engage in the political process by contributing financial and other support to candidates and political parties of their choice, participating in local political activities, voting in elections, attending caucuses and conventions, and seeking and holding public office. Company policy requires that employees engaged in these activities do so on their own time and not as representatives of (or otherwise on behalf of) Raytheon Technologies. Employees engaging in political activity in their personal capacity may not use Company resources (e.g., work time, email, administrative staff, etc.) for such activities.
All of Raytheon Technologies’ public activities are conducted in accordance with the standards articulated in the Company’s Code of Conduct. Further, the Company has in place a Government Relations Policy relating to lobbying, political activities and contributions. The policy ensures that any lobbying on behalf of Raytheon Technologies, contributions made with Company funds, if any, and political action committee activities comply with all relevant federal, state and/or local laws, as well as the Company’s governance processes and procedures.
Employees of Raytheon Technologies Corporation Political Action Committee
Following the Merger, the respective employee political action committees of UTC and RTN were merged to form the Employees of Raytheon Technologies Corporation Political Action Committee (“RAYPAC”).
Raytheon Technologies allows eligible employees to make voluntary contributions to RAYPAC. The purpose of RAYPAC is to use these contributions to support candidates for federal office and some state offices, and organizations operated in accordance with Internal Revenue Code (“IRC”) Section 527. RAYPAC is governed by a Steering Committee comprised of senior employees from each Raytheon Technologies business and the Company’s Global Government Relations organization, as well as representatives from the Office of General Counsel and other functions, operating in accordance with the RAYPAC bylaws.
In addition to its bylaws, RAYPAC adheres to the following principles:
- Participation by eligible employees is always voluntary;
- RAYPAC does not seek, request or expect any specific benefit for its contributions to candidates or for any official act;
- RAYPAC reports contributions to elected officials and candidates as required by law, and to PAC contributors periodically; and
- RAYPAC contributions are primarily intended for individuals seeking U.S. federal and state elective office. RAYPAC will only make contributions to leadership PACs, multi-candidate PACs, organizational or association PACs, or ballot measures (local, state or federal) after careful and deliberate consideration by the Steering Committee.
The Steering Committee considers the following factors in deciding the timing and amount of contributions to candidates:
- The candidate’s voting record and views on business issues of importance to Raytheon Technologies and industries critical to the Company’s business;
- The candidate’s support for spending sufficient to maintain a modern and capable civil aviation infrastructure, U.S. military and intelligence community, and a healthy industrial base for both;
- Whether the candidate occupies or seeks a position in Congress that has a geographical or jurisdictional impact on the Company’s interests, or where Raytheon Technologies employees and suppliers maintain constituent relationships; and
- The candidate’s support for Raytheon Technologies programs, products and services and the Company’s mission domestically or internationally.
RAYPAC is registered with the Federal Election Commission (“FEC”) and contributes to some non-federal elections where federal PACs are legally permitted to participate. All contributions made by RAYPAC are reported per the FEC's required filing schedule and as required by state or local law in jurisdictions where non-federal contributions are made. Contribution information for RAYPAC, as well as for the legacy UTC PAC, is available at www.fec.gov. RAYPAC and UTC PAC contributions for 2020 are enumerated in historical summaries below.
Since December 31, 2019, neither RTX nor its subsidiaries have sponsored any separate state political action committees. RTN had sponsored one state political action committee in California that was terminated as of December 31, 2019. UTC did not sponsor any state political action committees in 2019.
Expenditures on public communications in support of political campaigns and ballot measures
Raytheon Technologies does not spend Company funds on communications to the general public in support of political campaigns or ballot initiatives. This was also the case for UTC and RTN. In the event that the Company makes any expenditures from Company funds in support of political campaigns or ballot initiatives in the future, it would disclose such expenditures.
Direct corporate political contributions
Raytheon Technologies does not generally make any contributions from Company funds to any federal, state or local candidate or party committee. This is consistent with the past practices of both UTC and RTN. As a matter of policy, no political contribution from Company funds may be offered or made without the prior approval of the Senior Vice President, Global Government Relations, and the Executive Vice President and General Counsel. The review and approval process is designed to ensure compliance with relevant laws, the Raytheon Technologies Code of Conduct and other Company policies. In the event that the Company chooses to make any direct political contributions from Company funds in the future, it would disclose such contributions.
Section 527 and Section 501(c)(4) activity
Pursuant to policy, the Company is permitted to make administrative expenditures in support of RAYPAC, and to contribute to organizations formed under IRC Sections 527 and 501(c)(4). Consistent with past UTC practice, Raytheon Technologies may make contributions to the Democratic and Republican Governors Associations for membership dues and to federal and state inaugural committees (typically 501(c)(4) organizations to help defray the costs of public events (e.g., inaugural events).
In the ordinary course of business, Raytheon Technologies participates in certain trade associations. Membership in trade associations can provide a number of benefits including: facilitating the Company's ability to stay abreast of technical issues and emerging industry standards; providing educational opportunities for employees; reporting on trends relevant to the Company’s business; and engaging in public advocacy and education on behalf of the membership. Some trade associations utilize a portion of membership dues for non-deductible lobbying regarding issues of common concern to members. Under IRC Section 6033(e)(1), trade associations are required to inform contributors of the portion of annual dues, if any, attributable to lobbying expenses.
UTC, RTN and RTX payments to associations
A listing of any 501(c)(4), (501(c)(6), and Section 527 associations to which UTC or RTN paid dues or made contributions of $10,000 or more in 2019 and any such associations to which UTC, RTN, or RTX paid dues or made contributions of $10,000 or more in 2020, and the portion of such payments, if any, not deductible under IRC Section 162(e)(1), are set forth in the Association Payment Listings.
Raytheon Technologies responsibly and lawfully engages in the legislative process to communicate its views on legislative and regulatory matters affecting the Company's business and its various constituencies.
Raytheon Technologies has in place policies and governance processes related to its lobbying activities (Lobbying-Related Policies) to ensure:
- Compliance with federal laws relating to lobbying, including complete and accurate reporting of lobbying activities under the Lobbying Disclosure Act (LDA);
- Compliance with state and local laws relating to lobbying, including complete and accurate reporting of lobbying activities where required; and
- Approval from the Senior Vice President, Global Government Relations, or his designee, prior to engaging in any contact or communication with elected or appointed officials, or their staff, on behalf of the Company.
Federal lobbying activities
In full compliance with the LDA and the Lobbying-Related Policies, the Company's lobbying activities and expenses, as defined by IRC Section 162(e), are disclosed to the U.S. Congress on a quarterly basis. In addition, the Company files semi-annual reports detailing certain Federal Election Commission Act (FECA) contributions, honorary contributions, presidential library contributions, and payments for event costs. These reports are publicly accessible at the U. S. House of Representatives Office of the Clerk and the U.S Senate Office of Public Records websites. The practices of both UTC and RTN were consistent with the foregoing.
The quarterly federal lobbying reports for each of UTC and RTN for the last 5 years, including 2020, can be found here.
State and local lobbying activities
RTX’s state lobbying activities are subject to regulation and reporting in virtually every jurisdiction in which the company or its affiliates do business. As a general rule, the company's state and local lobbying efforts are restricted to issues involving economic development and various business regulation issues that arise during legislative sessions in key states where the company maintains a substantial business presence. For the jurisdictions that provide online availability, filed reports for each of UTC, RTN and RTX for 2020 and prior years, as applicable, can be found at the following linked websites:
- New York State
- New York City
- North Carolina
- West Virginia
Raytheon Technologies has in place sound procedures to ensure the accuracy, timeliness and oversight of its federal and state filings.
The Raytheon Technologies Corporate Governance Guidelines provide that the Board “shall review and monitor the Company’s conduct of government relations activities, including the activities of any political action committees.” The Board’s Committee on Governance and Public Policy assists the Board in fulfilling this responsibility.