Policy and advocacy engagement and political contributions

Policy and advocacy engagement

At Bristol Myers Squibb, our mission is to discover, develop and deliver innovative medicines that help patients prevail over serious diseases. In our effort to pursue our mission, we provide information, analysis and opinion to legislators and government leaders to allow for informed and balanced decision-making in regard to healthcare policy, regulatory policy, corporate tax policy, intellectual property policy, and other policies that may impact our ability to deliver life-extending and life-enhancing medicines to patients.

In the U.S., Bristol Myers Squibb directly lobbies policymakers and works with private firms specializing in government advocacy to enhance our ability to communicate key messages with policymakers. We make every effort to ensure that these firms clearly understand our mission, policy and goals. From time to time, we may inform our U.S. employees about important legislative issues at both the state and federal levels and encourage them to communicate with their elected officials. 

Political contributions

Our company believes that it should be an active, effective, and responsible participant in the political process by contributing prudently to federal, state and local candidates and political organizations when such contributions are permitted by federal, state and local laws. Where permitted by law, BMS PAC makes contributions at the federal and state levels and BMS makes corporate contributions at the state level.  Generally, contributions are made to office holders and candidates on a nonpartisan basis whose views support policies that encourage innovation and enhance our ability to meet the needs of our patients.  Contributions are made without regard for the private political preferences of our executive officers. In many cases, we support candidates and office holders who represent the communities served by our company and its subsidiaries.

BMS uses a set of criteria as the primary guide in determining which candidates will receive BMS Political Action Committee (BMS PAC) and corporate contributions.  The criteria are as follows:

• The candidate’s position on issues critical to our patients, company, and our employees;
• Whether BMS has a constituent relationship with the candidate (whether we have facilities or a concentration of employees in the candidate’s district or state);
• The candidate’s position on key legislative committees that have jurisdiction over legislation important to our interests;
• The candidate’s service or potential to serve in a leadership position; and
• The competitiveness of the candidate’s election and need for financial support.

BMS also considers giving decisions in the context of integrity and our ethical standards, as detailed in our Principles of Integrity.

BMS recognizes a candidate’s views on issues regularly evolve, and as such, BMS regularly evaluates its giving strategy accordingly.

Transparency

From time to time, we also support political parties, committees or ballot measures. Should these contributions take place, contributions will be disclosed here. 

Bristol Myers Squibb does not engage in direct independent expenditures on behalf of candidates running for public office. 

A summary of our corporate policy on political contributions may be found here.

A list of all contributions made during January 1, 2023 through December 31, 2023 by Bristol Myers Squibb to individual state candidates, parties, and other organizations eligible to accept corporate political contributions (such as ballot committees, or 527 organizations) may be found here.

The Company makes no political contributions outside of the U.S.

Our employees can also participate in the Bristol Myers Squibb Company Political Action Committee ("BMS PAC"), which is a non-partisan, multi-candidate federal political action committee. The BMS PAC makes contributions to federal and state candidates, state party committees, national political party committees and other organizations eligible to accept corporate contributions. The BMS PAC is funded by voluntary contributions from eligible employees who are U.S. citizens or green card holders. A list of all contributions made during January 1, 2023 through December 31, 2023 by the BMS PAC to these candidates and organizations may be found here.

Archived reports from previous years on political contributions, BMS PAC contributions and lobbying expenditures by certain trade associations and be found here.

Trade association participation

Bristol Myers Squibb is a member of several trade associations that are engaged in biopharmaceutical and healthcare related issues at both the state and federal levels. We are members of these groups because they develop industry positions on key biopharmaceutical issues and we believe it is essential for Bristol Myers Squibb to be represented in the development of important industry policy positions. We make our best efforts to ensure the organizations we are members of maintain policy positions consistent with our mission and policy priorities. Our trade associations strive to gain industry consensus on critical issues and usually are able to do so. On occasion, our trade associations are not aligned with Bristol Myers Squibb’s policy positions and we have the opportunity to voice our concerns and advocate for our positions directly with policymakers. While these instances are rare, Bristol Myers Squibb always reserves the right to advocate directly with policymakers on issues of importance and is not bound in any way to advocate for positions counter to our mission. A table may be found here that identifies, for each U.S. trade association that received at least $50,000 in dues or other payments from Bristol Myers Squibb during January 1, 2023 through June 30, 2023, the portion of such payments that has been identified by such trade association as being used for non-deductible lobbying expenditure.

Governance and compliance

The Board of Directors of Bristol Myers Squibb has delegated responsibility for oversight of our political activities to our Committee on Directors and Corporate Governance. The Committee semi-annually reviews political contributions made by the company and the BMS PAC, and annually reviews the lobbying expenditures reported by certain U.S. trade associations of which we are members. In addition, we have implemented internal and external controls to promote compliance with our political contributions policy and all applicable lobbying and political contribution laws, rules and regulations, including requiring all Bristol Myers Squibb employees to undergo training on our Principles of Integrity: BMS Standards of Business Conduct and Ethics (PDF), requiring that all federal contributions from corporate funds be approved by our Head of Federal Government Affairs, and all state contributions from corporate funds be approved by our Executive Director, State Government Affairs, and requiring that all payments by the BMS PAC be approved by its Board of Directors comprised of up to fifteen representatives from various organizational units.

Bristol Myers Squibb and its subsidiaries are committed to conducting our lobbying activities in compliance with applicable federal, state and local laws and regulations, and in a manner that is consistent with the Company’s values and ethical standards. Therefore, under the federal Lobbying Disclosure Act (LDA), in-house federal lobbyists acting on behalf of Bristol Myers Squibb are required to register with the Secretary of the Senate and Clerk of the House of Representatives to provide full disclosure and full public knowledge and awareness of any lobbyist activities and gift and travel provisions. Additionally, payments made for any outside lobbying services must be disclosed by the lobbyists we retain. All of these reports are publicly available on the U.S. House of Representatives Office of the Clerk website and on the U.S. Senate Office of Public Records website. A summary of our corporate policy on disclosure of our federal lobbying activities may be found here. We file similar periodic reports with state agencies reflecting state lobbying activities which are also publicly available.

Updated December 2023