DXC Technology’s Government Affairs function, resident in the company’s Ethics and Compliance Office, engages in public policy activities aligned with its business objectives. The function plays a strategic support role in the development and growth of DXC’s 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.

DXC Government Affairs Policy

In keeping with DXC’s Code of 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 Ethics and Compliance Office.
• All DXC lobbyists shall be subject in advance to an integrity review and screened 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 allowable by law, DXC or its executives may make contributions to state candidates and to state and local government ballot measures, Political Action Committees (PACs) and political party committees. All such contributions shall comply with DXC’s pre-authorization and reporting requirements through the Ethics and Compliance Office. No corporate funds or assets may be used by DXC for contributions to candidates for U.S. federal political office, or for federal office in any country.  
• Our Policy defines Political Contributions as anything of value — typically in money, goods, services, or in kind — given to a candidate for office, candidate’s committee, or political party or party committee.
  

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. 

Disclosures

Lobbying

• The company discloses its international, U.S. federal, state and local lobbying activity and expenditures as required by law.
• All United States federal lobbying costs, and the issues to which they relate, are disclosed in the United States under the Lobbying Disclosure Act, which requires the filing of quarterly reports with the United States Congress. These reports are publicly available here.
• DXC’s only US lobbying expenditures relate to fees paid to Monumental Advocacy. Monumental Advocacy does not engage on advocacy work on behalf of DXC, but instead has been retained to keep DXC apprised of legislative changes which may impact DXC, its people or customers and to ensure compliance with law. Below are the periodic reports filed by Monumental Advocacy with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives in 2022 and Q1 and Q2 2023 for these services. 

• DXC does not currently make direct expenditures towards U.S. federal or state grassroots lobbying communications to the general public.

Corporate Political Contributions

• DXC’s Government Affairs policy does not allow DXC to use corporate funds or assets for contributions to candidates for U.S. federal political office.
• DXC did not make political contributions in 2022 to U.S. state candidates and to state and local government ballot measures, PACs and political party committees. 

Trade associations

• DXC did not make any trade association payments used for political contributions in 2022.