As an industry leader, American Tower ensures the interests of its stakeholders, including its employees, shareholders, partners and tenants, are appropriately represented through leadership roles in industry groups, thoughtful participation in global organizations and representation before governments who are considering regulation or legislation that may impact its business, the industry, or the investment climate. Across its global footprint, American Tower maintains oversight and training processes to ensure engagement in policy arenas is done in a legal, ethical and transparent manner.
Political Contributions and PACs
As a matter of policy, American Tower does not make political contributions in support of any party or candidate in any election, whether federal, state or local and the company does not have, nor does it plan to have, a Political Action Committee (PAC). Consistent with this policy, American Tower also does not use corporate funds to support “Super PACs” or political organizations operating under 26 U.S. Sec. 527 of the Internal Revenue Code known as “Section 527 organizations”.
Governance Practices and Ethics
American Tower’s guidelines regarding political contributions are found in the company’s Code of Ethics and Business Conduct Policy (“Code of Conduct”). The Code of Conduct prohibits all employees and directors from directing or requiring a fellow employee or director to contribute to any political party, cause, organization or candidate. However, the Code of Conduct does not prevent an employee or director, acting on their own behalf and who is representing themselves, from participating in the political process. See American Tower’s Code of Conduct.
Disclosure and Oversight
American Tower is subject to federal, state and local lobbying registration and public disclosure requirements. The company files quarterly reports with the United States House of Representatives and Senate that lists its lobbying activities and discloses the total amounts expended, and these reports are publicly available at https://lobbyingdisclosure.house.gov/. Any consultants that lobby on American Tower’s behalf also file such quarterly reports. The Senior Vice President of Public Affairs has oversight over political, lobbying and compliance activities and the company has effective internal reporting, accounting and compliance procedures in place to closely monitor its expenditures in relation to such matters.
The company’s Board of Directors regularly receives governmental affairs briefings on the activities of its public affairs group.
Industry Groups and Trade Associations
Memberships in industry groups and certain trade associations enable American Tower to gain insight into core issues faced by the industry as a whole, share expertise and knowledge that contributes to realization of greater efficiency and long-term success, build a consensus among organizations with similar interests and advocate in favor of those interests that support an efficient, healthy and competitive industry and are beneficial to our stakeholders. American Tower monitors the activities of these industry groups and trade associations and the global public affairs committee reviews the costs and benefits of its memberships in such organizations on an annual basis.
Memberships, as of January 1, 2020, include but are not limited to the following:
- Americas Society / Council of the Americas
- Business Council for International Understanding
- CTIA
- National Association of Real Estate Investment Trusts (Nareit)
- U.S.-Africa Business Center
- U.S.-India CEO Forum
- Wireless Infrastructure Association (WIA)
- World Economic Forum
Trade associations operate independently from American Tower and undertake responsibility for their own governance and compliance. American Tower through its membership participation conveys its expectations that trade associations comply with all applicable laws with respect to their political and advocacy activities. Furthermore, as a matter of company policy, American Tower declines paying a trade association for special assessments for political spending.
