Our engagement with the U.S. Federal and State governments

AbbVie’s public policy engagement is guided by the following principles:

• AbbVie is committed to transparency and is guided by our Code of Business Conduct in all public policy engagement.
• AbbVie pursues activities that shape policies to benefit patients, with a focus on improving patient access to new medical advances.
• AbbVie federal and state government affairs representatives participate in annual ethics and legal training on political engagement. 

Furthermore, AbbVie does not;

• provide political contributions in anticipation of, in recognition of, or in return for an official act;
• seek or receive direct or indirect reimbursements for personal political contributions or expenses;
• pressure or coerce fellow employees to make personal political contributions; or,
• reward employees or make employment decisions based in whole or in part on that employee’s personal political contributions.

Our Federal Government Affairs office in Washington, D.C. is responsible for advocacy activities with the U.S. Congress and the federal government.  Advocacy at the U.S. state level is managed by our State Government Affairs function.  AbbVie also hires outside firms that can provide expertise on our key policy issues.  AbbVie does not currently make direct expenditures for U.S. federal and state grassroots lobbying communications to the general public.  Additionally, AbbVie does not currently contribute funds intended for use in elections to 501(c)(4) organizations but, should such a contribution be made in the future, it would be listed with AbbVie’s other corporate political contributions.

The AbbVie Board of Directors’ public policy and sustainability committee exercises oversight of AbbVie’s political expenditures and lobbying activities, as specifically enumerated in the committee’s charter, and which are further governed by the Committee’s approved policy on political contributions.  The public policy and sustainability committee and AbbVie’s senior management review these activities and expenditures on a regular basis.  In the United States, in compliance with the Lobbying Disclosure Act, AbbVie will file a quarterly report that includes: (i) total federal lobbying expenditures, (ii) the name of the specific piece of legislation or subject that was the topic of communication, (iii) disclosure of AbbVie individuals who lobbied on behalf of AbbVie, and (iv) identification of the legislative body or executive branch that was contacted.  This report incorporates expenses associated with lobbying the federal government, including our Federal Government Affairs office and the portion of trade association dues associated with federal lobbying.  Our latest federal lobbying disclosure filings can be found on the U.S. Senate Office of Public Records website and the U.S. House of Representatives Office of the Clerk website.  We file similar publicly-available lobbying reports with states, as required by law, available here.

AbbVie advocates on a range of issues in the United States, including:

• Advancing patient access to drug therapy as prescribed by their clinician
• Reducing patient out of pocket costs
• Strong intellectual property protections
• Rewarding innovation

The Vice President, Government Affairs, exercises oversight of all external vendors that lobby on AbbVie’s behalf.  The Vice President, Government Affairs also updates the Public Policy and Sustainability Committee of the AbbVie Board of Directors periodically regarding AbbVie’s lobbying priorities.

Internationally, the AbbVie Government Affairs team supports our regional leaders to contribute to the policy debate. 
 

Our report on political contributions

AbbVie participates in the political process by contributing to U.S. federal, state and local candidates and political organizations.  We support candidates and organizations that understand how government actions can affect patients’ access to medical advances and that will work to promote an environment that fosters continued medical progress.  As discussed in more detail below, this support comes via two mechanisms: (1) corporate political contributions direct from AbbVie and (2) political contributions directed from the AbbVie Political Action Committee.

Contributions to office holders and candidates are bipartisan and based on several criteria: policy positions that reflect AbbVie’s interests related to key advocacy priorities; representation of geographic areas where AbbVie employees and facilities are located; relevant legislative committee assignments; ability to be elected; and need for financial assistance.  The private political preferences of AbbVie’s executives or other employees do not play a role in how corporate political funds are spent.

The Vice Chairman, External Affairs and Chief Legal Officer, and the Vice President, Government Affairs, each review and approve all corporate political contributions at the recommendation of AbbVie’s Government Affairs function to ensure these contributions are consistent with the company’s guidelines and in accordance with applicable laws as required by the Corporate Political Contributions Policy.  The Public Policy and Sustainability Committee of the AbbVie Board of Directors reviews the Corporate Political Contributions Policy every three years or more frequently and is periodically briefed on the corporate contributions made by AbbVie.  

An internal Political Action Committee (PAC) Board of Directors guides the AbbVie PAC.  The PAC Board is chaired by the Vice President, Government Affairs and is comprised of at least twelve senior leaders representing a broad range of functions within AbbVie.  The AbbVie PAC Board members hold a wide range of experiences and perspectives that inform AbbVie PAC activities.  A direct link to AbbVie’s PAC contributions can be viewed on the Federal Election Commission website here.

Both AbbVie’s PAC and direct corporate political contributions support a wide range of candidates and committees representing both major political parties and independent candidates and committees.  For example, AbbVie’s corporate federal political contributions, which includes contributions to re-election committees, leadership political action committees, national political action committees and national political party committees, have historically been evenly split between Democratic and Republican organizations.  Many of the recipients of AbbVie’s political contributions engage on a broad range of issues in the course of their regular work, some of which have a direct impact on AbbVie and the patients AbbVie serves, while others are not directly related to AbbVie or the biopharmaceutical industry.

All AbbVie corporate and AbbVie PAC political contributions are vetted through a rigorous process that includes:

1. AbbVie federal and state Government Affairs representatives vetting candidates and submitting proposals to Government Affairs leadership
2. An internal review to confirm that the contribution meets AbbVie’s giving criteria and is within the approved budget, and to assess the reputational risk of making the contribution
3. An external compliance review to ensure the contribution is permissible in the relevant jurisdiction
4. The Vice President, Government Affairs reviewing and approving each contribution
5. AbbVie Finance confirms financial controls and policies have been complied with for all political contributions

When available, AbbVie will provide links to AbbVie’s corporate contributions to political candidates, political parties, political committees, ballot measure committees, and organizations operating under 26 USC Sec.  527 of the Internal Revenue Code.  AbbVie’s corporate political contribution reports are updated every six months and are archived for reference.

Jan – June 2022 Corporate Political Contributions
Jan – Dec 2021 Corporate Political Contributions
Jan – Dec 2020 Corporate Political Contributions
Jan – Dec 2019 Corporate Political Contributions
Jan – Dec 2018 Corporate Political Contributions
Jan – Dec 2017 Corporate Political Contributions
Jan – Dec 2016 Corporate Political Contributions
Jan – Dec 2015 Corporate Political Contributions
Jan – Dec 2014 Corporate Political Contributions
Jan – Dec 2013 Corporate Political Contributions

Our membership in trade associations

AbbVie belongs to trade associations that represent a broad range of policy issues impacting the company and patients.  AbbVie works with its trade associations to ensure AbbVie’s positions are understood and represented within each trade association.  Given that these trade associations represent numerous and diverse members, AbbVie understands that we may not always agree with every position a trade association takes.  In these circumstances, AbbVie conveys, as appropriate, any concerns through our colleagues who serve on the boards and committees of these associations.  We may recuse ourselves from an activity or initiative when appropriate or when we have a divergent point of view.

The major U.S. trade associations to which AbbVie provides $25,000 or more in annual membership dues, and which lobby in the U.S. at the federal level may be found here.  AbbVie also posts a list of trade associations around the world where an AbbVie employee serves on the organization’s board of directors, which are listed here.  The Public Policy and Sustainability Committee of the AbbVie Board of Directors also reviews these memberships.