/corporate-governance/saic-political-activities

SAIC Political Activities

Overview

As a premier Fortune 500® technology integrator and trusted partner of the U.S. government, SAIC’s purpose is to advance the power of technology and innovation to serve and protect our world. We integrate emerging technology, rapidly and securely, into mission-critical operations that modernize and enable critical national imperatives.

Political engagement is an important part of our business strategy. Consistent with our core values, we advocate for policies that support innovation, defense readiness, and the safety of our nation, and we do so in a manner that is honest, transparent, and in the best interests of our stakeholders. We actively monitor and contribute to public policy discussions that affect national security, the technology and defense industries, and the well-being of our employees and communities.

Our dedication to integrity and accountability is the bedrock of our political activity. We are committed to contributing positively to the broader policy conversation while remaining compliant with all applicable laws and regulations.

Board Oversight and Governance

SAIC’s Senior Vice President, Government Affairs (“SVP, GA”) leads our government relations and political activities. As a member of the Company’s senior leadership team, the SVP, GA reports at least annually to the Nominating & Corporate Governance Committee (“Nom Gov”) of the Board of Directors on the Company’s political and lobbying activities, including those of SAIC’s Voluntary Political Action Committee. The Nom Gov reviews our political engagement efforts, including contributions and trade association spend, to ensure alignment with our business strategy and corporate values. The SVP, GA also works closely with the Legal and Ethics organizations to ensure that our political activities comply with all legal requirements, Company policies, and the highest ethical standards.

Corporate Political Expenditures
  • Federal Contributions

Consistent with U.S. federal law, SAIC does not use corporate funds to contribute to federal candidates, political parties, or political committees. 

  • State and Local Contributions

SAIC makes limited political contributions with corporate dollars at the state and local level in conjunction with our community engagement agenda. We use three main criteria when considering state and local contributions:

  • Does the potential recipient uphold pro-business policies aligned with SAIC’s policy and business objectives?
  • Does the contribution align with SAIC’s corporate citizenship strategy as a technology/business leader?
  • Does the potential recipient maintain a reputation of integrity and demonstrate potential for long-term leadership in their jurisdiction and/or the nation as a whole?

SAIC’s state and local contributions are carefully vetted by our Government Affairs Office and legal counsel, and the Board of Directors reviews them annually. We fully disclose all contributions to the appropriate jurisdictions as required by applicable law. Our 2024 state and local contributions are available here.

  • Section 527 Organizations

SAIC makes limited contributions to select Section 527 organizations. We evaluate these contributions on a case-by-case basis, ensuring they align with the Company’s values and interests while adhering to applicable legal and ethical standards. Our 2024 contributions to Section 527 organizations are available here.

  • Trade Associations

SAIC contributes to public policy debates by participating in trade and industry associations and by engaging directly in advocacy and grassroots communications. We join trade associations that represent a broad spectrum of views on industry and policy issues important to our business interests. 

Our participation in trade associations is subject to management oversight by the Company’s Government Affairs function. Government Affairs serves as SAIC’s principal representative in trade and industry associations.

SAIC pays regular dues to several trade associations. Some trade associations utilize a portion of membership dues for non-deductible state and federal lobbying and political expenditures. Per the requirements of Section 162(e)(1) of the Internal Revenue Code, the trade associations to which we contribute must provide us with the percentage of our annual dues attributable to lobbying expenses. A list of the national-level trade associations to which SAIC paid dues of $25,000 or more in a single year, along with the non-deductible portions of those dues, is available here.

  • Lobbying

SAIC participates in industry associations and interacts directly with various stakeholders in an effort to educate, inform, and advocate on behalf of the Company, our employees, and our shareholders. These communications are often regulated by federal, state, and local laws, under which we report our lobbying activity and associated expenses on a regular basis. In accordance with the Lobbying Disclosure Act (“LDA”), we disclose our lobbying activities and expenses, as defined by Section 162(e) of the Internal Revenue Code, to the U.S. Congress on a quarterly basis. SAIC’s lobbying activities and expenses are available here. Federal reports disclosing lobbying activity and expenses, including state-level and grassroots activity, are available to the public via the Office of the Clerk of the U.S. House of Representatives at the following website: http://lobbyingdisclosure.house.gov/.

SAIC Voluntary Political Action Committee (“VPAC”)

SAIC’s VPAC is a nonpartisan, segregated fund we established in accordance with federal law in 1994. The VPAC is funded exclusively through voluntary contributions from eligible employees, shareholders, and directors; those participating in the VPAC are not reimbursed, directly or indirectly, for political contributions or expenses. The Board’s ROC reviews the VPAC’s governance and compliance at least annually.

The VPAC donates to federal congressional candidates who support SAIC’s business interests, including technology, engineering, and national security. The VPAC makes these donations without regard to party affiliation, based solely on the best interests of the Company and its stockholders, and not on the personal agendas of SAIC’s directors, officers, or employees. The VPAC strengthens its contributors’ political voice by combining their individual contributions into larger donations to congressional candidates who support SAIC’s interests. The VPAC does not contribute to presidential candidates or to politicians at the state or local levels.

The VPAC is managed by the VPAC Committee, which consists of representatives from SAIC’s Business Groups. The SVP, GA chairs the VPAC Committee and supervises all VPAC contributions. In accordance with the VPAC bylaws and federal law, we report all VPAC contributions to the Federal Election Committee fec.gov website.