Corporate Governance of Political Expenditures: 2011 Benchmark Report on S&P 500 Companies, By Heidi Welsh and Robin Young, November 2011 “This study takes a close look at the nature and extent of the voluntary governance reforms companies have made, using a broad definition of “political spending,” to see how these practices affect key disclosure and accountability concerns raised by critics. We examined:

• Direct contributions to state-level candidates, party committees and ballot initiative committees;
• Direct contributions to political committees registered with the Federal Election Commission
  (FEC), known as “527 committees” for their tax code designation;

• Direct federal lobbying expenditures; and
• Available information on indirect contributions made through trade associations and other nonprofit groups.”