Target’s decision-making body regarding financial support of political activities consists of a subset of the Executive Leadership Team that is responsible for balancing our business interests with other considerations that are important to our team members, guests, shareholders, or other stakeholders. This body reports to the Nominating and Governance Committee of the Board of Directors at least twice per year. Target may provide financial support to political candidates, political parties, or ballot initiatives through two separate channels:
- TargetCitizens PAC, which is funded through the voluntary contributions of our eligible team members, and
- The use of general corporate funds where permitted by law.
Regardless of which channel for political contributions is used, our financial support is provided in a bipartisan manner based strictly on issues that directly impact our business priorities.
TargetCitizens PAC is funded through voluntary contributions by eligible team members and contributes in a bipartisan manner to federal candidates and organizations. Target’s senior leadership approves the factors to be considered when making contribution decisions. TargetCitizens PAC considers the following factors when making contribution decisions:
- General alignment with our business objectives
- Extent of our presence in a candidate’s state or congressional district
- Relevant legislative committee assignments
- Leadership positions
- Political balance
- The interests of our guests, team members, shareholders and other stakeholders
TargetCitizens PAC contributions are based on policy and business priorities. Given the diversity of interests, viewpoints, and the broad membership represented by these candidates and organizations, the positions they take do not always reflect Target’s purpose and beliefs. Information on TargetCitizens PAC contributions can be found on the Federal Election Commission’s website.
The use of general corporate funds for political contributions is permitted if Target determines that it would be an appropriate means of advancing issues that are important to our business. Target leadership reviews and approves any use of general corporate funds for electioneering activities, including any contributions to political candidates, parties, committees or other political organizations, or for or against ballot measures.
In making these decisions, Target: (i) determines whether the contribution supports our business interests; (ii) gives consideration to the interests of our guests, team members, shareholders and other stakeholders; and (iii) determines whether under the circumstances, the contribution is an appropriate means of advancing our public policy position. This approval process applies whether the contribution is made directly to a candidate or party, or indirectly through an organization operating under Section 527 or 501(c)(4) of the U.S. Internal Revenue Code.
One way Target and other retail companies engage at the state level is to support state retail association political action committees (PACs) where allowed by law. By pooling resources with other retailers, we are able to support candidates who understand and support issues important to the retail industry, such as tax and labor policy, environmental and health care issues. Target also is a member of national organizations such as the Democratic and Republican governors associations and state legislative campaign committees, which allows our team members to attend conferences and other events to learn about those elected officials’ policy priorities and initiatives and to share a retail perspective. Target expressly requires that our funds are used only to support educational and association management activities and not for campaign contributions. Because those organizations also engage in political efforts, we disclose our memberships as political contributions.
Target publicly discloses its political contributions using corporate treasury funds, which include contributions to recipients such as political candidates, parties and committees; 527 or 501(c)(4) organizations using the funds for political purposes; super PACs; governors associations; and independent political expenditures supporting or opposing campaigns or ballot measures. A list of such individual contributions of $5,000 or more, including recipient name and amount, is updated twice per year and available below.
All Target team members are required to comply with the foregoing corporate policies on public policy engagement and political contributions. Legal counsel reviews and approves all TargetCitizens PAC reports and materials.
Government Affairs staff and key internal business partners complete annual training and certify compliance with corporate policies on public policy engagement and political contributions. Target corporate political contributions and lobbying practices are subject to periodic internal audit.