From time to time, Staff at the Foundation are asked in their individual capacities to become involved in the political campaigns of various candidates, to sign petitions on behalf of various candidates or causes, or to otherwise support candidates or causes. The purpose of this policy is to provide some guidance regarding the Foundation's view of these types of activities to prevent potential legal liability to the Foundation and embarrassment to you or the Foundation.
As you know, the Foundation is precluded from engaging in lobbying activities with respect to legislation or campaign activities on behalf of a particular participant or candidate. There are very strict requirements and harsh penalties should the Foundation be found to be in violation of these restrictions, and we make every effort to ensure that we do not violate these requirements.
Of course, as a private citizen, you have First Amendment and other constitutional rights that you may choose to exercise, and the Foundation values and encourages civic participation as a part of a healthy democracy. The Foundation has no interest, desire or right to burden or interfere with the exercise of such rights so long as the exercise of such rights does not imperil the Foundation or impinge unfairly on rights of other Foundation staff. It is important, however, that in exercising your constitutional rights, you take care not to have your activities viewed as activities of the Foundation and that you be sensitive to the possibility that your employment by the Foundation may be misused by groups or individuals.
It is the Foundation's policy that your affiliation with the Foundation should not be expressed in your individual political activity (for example, signing statements, petitions, or letters) as that may be misinterpreted, misused or abused by people. Therefore, if you become involved on behalf of a candidate or engage in political activity, such as signing petitions, etc., you should take care to ensure that the Foundation's name is not associated with the activity or statement. In general, you should take reasonable steps to avoid being identified as part of the Foundation in connection with your individual activities.
Compliance will most often require utilization of common sense that, hopefully, will be obvious. You should not use Foundation stationery in writing letters or soliciting contributions for candidates or causes. It may be appropriate, in drafting letters, for you to stress that the views are your individual views and not necessarily the views of the Foundation. Other resources of the Foundation (such as computers, phones, etc.) are intended for business use.
In those instances where there is any question or possible confusion regarding any contemplated activity, do not hesitate to contact the General Counsel for clarification.All Policies