All political activities of RTX Corporation (“RTX”) are managed from the highest levels of the Company. Under the RTX Corporate Governance Guidelines, the Board of Directors has responsibility for reviewing and monitoring the Company’s conduct of government relations activities, including any political action committees. The Board undertakes this oversight responsibility directly and through its Committee on Governance and Public Policy (“GPP”), a standing committee of the Board comprised solely of independent directors. The Board receives regular briefings by management on U.S. government budget and priorities, proposed legislation, and related RTX government relations initiatives. The GPP is responsible for, among other things, reviewing and overseeing the Company’s positions and responses to significant public policy issues, including but not limited to its policy advocacy and its positions taken in legislative, regulatory and judicial forums, and reviewing and monitoring the Company’s policies and practices with respect to contributions to charitable, educational, and other tax-exempt organizations.
The Senior Vice President for Global Government Relations (“SVP GGR”) leads RTX’s government relations and political activities, is a member of the Company’s senior leadership team, and reports directly to RTX’s Chief Executive Officer. The SVP GGR reports to the GPP Committee at least annually on the Company’s political and lobbying activities, including with respect to the Employees of RTX Corporation Political Action Committee ("RTX PAC"). The SVP GGR also works closely with the Legal, Contracts and Compliance (“LCC”) organization, including the Global Ethics & Compliance organization, to ensure the Company’s political activities comply with all legal requirements, company policies, and highest ethical standards. Together, these organizations ensure that all political activities are conducted in accordance with the standards articulated in the Company’s Code of Conduct and government relations policies relating to lobbying, political activities, and political contributions.
RTX and its employees actively participate in public policy debates at the federal, state, and local levels. The Company’s government relations initiatives are intended to educate and inform officials and the public on a broad range of public policy issues in furtherance of its business objectives. These initiatives are not based on the personal agendas of individual directors, officers, or employees.
Corporate political contributions
RTX does not contribute corporate funds to federal, state, or local candidates, section 527 organizations, Super PACs, independent expenditures, or other communications to the general public related to the support or opposition of candidates, ballot measures, or any other election-related matters.
Employees of RTX Corporation Political Action Committee
RTX allows eligible employees to make voluntary contributions to RTX PAC. RTX PAC is not funded using corporate dollars. The purpose of RTX PAC is to use employee contributions to support candidates for federal office and some state offices, and for operating expenses of certain organizations, such as the Democratic and Republican Governors Associations, which are operated in accordance with Internal Revenue Code (“IRC”) Section 527. RTXPAC is governed by a Steering Committee comprised of RTX’s Corporate leadership team, leaders of the Company’s Global Government Relations organization, as well as representatives from LCC and other functions, operating in accordance with RTX PAC’s bylaws.
In addition to its bylaws, RTX PAC adheres to the following principles:
Participation by eligible employees is always voluntary;
RTX PAC does not seek, request or expect any specific benefit for its contributions to candidates or any official act;
RTX PAC reports contributions to elected officials and candidates as required by law, and to PAC contributors periodically; and
RTX PAC contributions are primarily intended for individuals seeking U.S. federal and state elective office. RTX PAC 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 RTX 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 RTX employees and suppliers maintain constituent relationships;
- The candidate’s support for RTX programs, products and services and the Company’s mission domestically or internationally; and
- The candidate demonstrates a commitment to our core values of trust, respect, accountability, and collaboration.
RTX PAC is registered with the Federal Election Commission (“FEC”) and contributes to some non-federal elections in jurisdictions where federal PACs are legally permitted to participate. All contributions made by RTX PAC 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. You can find a full list of all candidates and committees to which RTX PAC has contributed here.
Since December 31, 2019, neither RTX nor its subsidiaries have sponsored any separate state political action committees.
In the ordinary course of business, RTX participates in, and pays membership dues to, 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; supporting workforce development initiatives; 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. RTX does not make payments to trade associations or other tax-exempt organizations that are designated for election-related purposes.
A listing of any 501(c)(6) associations to which RTX paid dues or made contributions of $25,000 or more and the portion of such payments, if any, not deductible under IRC Section 162(e)(1), are set forth in the Association Payment Listings.
RTX 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. All contacts and communications with elected or appointed officials on behalf of the Company must be pre-approved by the SVP GGR or his designee, as a means of ensuring that such engagements adhere with applicable legal requirements and Company policies and align with RTX shareholder interests and the Company’s values. RTX has in place sound procedures to ensure the accuracy, timeliness and oversight of its federal, state, and local lobbying disclosures.
Federal lobbying activities
RTX’s federal lobbying activities are conducted in full compliance with the Lobbying Disclosure Act, the Byrd Amendment, and all internal lobbying-related Policies. As such, the Company's lobbying activities and expenses, as defined by IRC Section 162(e), are reported to the U.S. Congress on a quarterly basis. In addition, the Company files semi-annual reports detailing certain Federal Election Commission Act 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.
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 can be found at the following linked websites: