Compliance Risk Management
Risk Assessment, Monitoring, Auditing and Improvement
Comcast continuously assesses and monitors areas of compliance risk across the company and looks for ways to improve the Compliance Program. The Compliance Committee, which is a key component of the program, conducts periodic risk assessments to help identify risks and periodically reports on them to our Board of Directors or appropriate committee(s) of our Board. The Compliance Committee conducts monitoring and auditing to detect non-compliance with standards, procedures and laws; has systems in place to permit employee feedback; reviews industry standards; and periodically evaluates the effectiveness of the Compliance Program.
Compliance Areas of Particular Relevance
While Comcast is committed to following all applicable laws everywhere we do business, there are a few areas of corporate compliance that are particularly relevant to our business operations that we highlight below: Privacy, Anti-Corruption, and Political and Trade Association Activity.
From a privacy perspective, Comcast continuously reviews the policies and procedures it has in place to ensure that confidential customer personal identifiable information and customer proprietary network information are appropriately maintained. In addition to ensuring compliance with applicable laws, regulations and policies, Comcast understands that privacy is a key component of the Comcast-customer relationship and the trust that customers have in Comcast. Our Chief Privacy Officer coordinates overall Comcast privacy compliance and administration in conjunction with several internal working groups and committees that include legal, policy, regulatory, legislative and business members.
Comcast is opposed to corruption in all forms and conducts due diligence on the business relationships it enters into to ensure compliance with all applicable anti-corruption laws. Comcast’s Code of Conduct includes several policies directly addressing international compliance, including anti-corruption laws, money laundering prevention and international trade controls. Training related to anti-corruption laws and regulations is embedded into training programs completed by all employees and targeted training is provided to appropriate personnel. Comcast monitors company activities to ensure it is operating in accordance with all laws and regulations, including the Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act, regarding business payments to government officials in the United States and abroad.
Political and Trade Association Activity
Participation in political activities, whether done directly or through our involvement with trade associations or other organizations, is important to achieving our business objectives. It is critical that all of our activities in this area rigorously comply with applicable laws, regulations and our own standards of integrity. For this reason, our policy regarding political activities is set forth in our Code of Conduct.
Comcast Corporation Statement on Political and Trade Association Activity
Participation in political activities, whether done directly or through involvement with a trade association or other organization, is important to achieving the business objectives of Comcast. It is also critical that all of our activities in this area display rigorous compliance with applicable laws, regulations, and our own code of ethics. For this reason, Comcast's essential policy with respect to political activities is set forth in the Company's Code of Conduct. This statement provides additional amplification on the Company's implementation and compliance activities in connection with that basic policy.
Key Implementation Statements
- The primary responsibility for implementation of Comcast's political and trade association activities rests with the Company's Government Affairs ("GA") organization, which ultimately reports to the Company's Executive Vice President (a direct report to our Chairman and CEO). The GA organization operates throughout the business footprint of Comcast and in Washington, D.C. The political activities engaged in by the GA organization include development and advocacy of public policy, lobbying, political contributions, activity in a variety of trade associations, participation in a number of intergovernmental associations, and partnerships with other companies in the cable industry and third party organizations on public policy issues of concern to the Company. The work of the GA team is regularly reported to senior management of the Company and to the board of directors.
- The political activities of the Company undertaken directly and through participation in a trade association are directed to influencing the wide variety of public policy issues that impact the Company's business. These activities include making contributions to candidates who support issues of concern to the Company as well as issue and legislative advocacy. The issues include legislation and regulation relating to the distribution of video content over our cable plant, local and state cable franchising laws and regulations, regulation of the Internet and high speed data services, regulation of the telephone industry, and a variety of general legislative and regulatory initiatives that affect Comcast as a business, including tax, labor, and workplace safety issues.
- Requests for corporate and political action committee ("PAC") political contributions are made by members of the GA organization, or by business leaders of the Company, through a member of the GA organization. All such requests are reviewed pursuant to a rigorous process and all contributions are ultimately approved by the Vice President of Administration and the Executive Vice President and reviewed by inside and/or outside legal counsel, as appropriate. No contribution will be given in anticipation of, in recognition of, or in return for an official act. Management makes an annual report to the board of directors on the Company's political activities, including all political contributions. The Governance and Directors Nominating Committee of the board, composed entirely of outside directors, is responsible for overseeing the company's political activity and receives the annual report and periodically reviews this statement. As outlined in the Comcast Code of Conduct, employees are also prohibited from causing such corporate or PAC contributions without going through this vetting process. Employees are required to have gifts to, and entertainment of, government officials vetted in the same manner. Employees will not be reimbursed directly or through compensation increases for personal political contributions or expenses.
- Comcast also participates in the activities of various trade organizations and chambers of commerce. The trade organizations are principally composed of cable industry associations and are operated for the purpose of advancing the common goals and interests of the member companies and their customers. Participation in all trade associations is subject to approval by the Executive Vice President.
- Political contributions are normally made from employee-funded PACs that are sponsored by Comcast. When permitted by law, political contributions are occasionally made out of corporate funds. Comcast does not make independent expenditures, contribute to federal, state or local political committees that only make independent expenditures (so-called "SuperPACs"), nor contribute to any organization for the purpose of funding independent expenditures.
- The Comcast PACs are operated by a board of directors, chaired by the Executive Vice President. The board of the PACs has adopted a set of criteria that guide all Company political contributions, including contributions from the PACs and legally permissible corporate contributions. These principles include:
- a general principle of supporting candidates whose views and positions promote the interests of or are otherwise good for Comcast, the cable industry, and a free-market, deregulated economy in general and to candidates who demonstrate a high level of personal ethics and integrity;
- an attempt to achieve bipartisan balance in our political contributions, without regard for the private political preferences of Comcast's officers and directors;
- an emphasis on candidates who are or will be members of committees with subject matter jurisdiction over public policy issues of concern to the Company and the cable industry;
- support for candidates whose voting record evidences support for the Company's business objectives; and
- support for legislative and committee leadership.
Comcast will not pressure or coerce employees to make personal political expenditures or take any retaliatory action against employees who do not. These principles were completely adhered to in 2010, 2011, 2012 and 2013 to date.
- From a compliance perspective, first and foremost, the Company complies with all applicable laws and regulations concerning political contributions. We regularly consult inside and outside counsel to design and monitor our political activity compliance program. All contributions are publicly disclosed as required by law, including disclosures required by federal law to the Federal Election Commission and comparable disclosure requirements in many states and localities.