What is the Vanguard Committee for Responsible Government?

The Vanguard Committee for Responsible Government (VCRG) is Vanguard’s Political Action Committee. It was formed with the intent to solicit donations from eligible Vanguard officers and to utilize those funds to make contributions on a bipartisan basis to support the election of candidates to the United States Congress. It supports the election of candidates who promote policies that align with the interests of Vanguard, its clients, and its crew.

The VCRG solicits eligible officers to make voluntary donations​. We solicit a small group of Vanguard’s eligible class of donors, maintaining a targeted and meaningful approach. Eligibility relates to the FEC defined solicitable class [fec.gov] and federal law prohibits foreign nationals [fec.gov] from contributing to federal, state, or local elections. All contributions to the VCRG are voluntary.

What is a PAC?

A Political Action Committee (PAC) is a registered, transparent, federally monitored means of contributing voluntarily combined funds from its members to candidates’ campaigns. It is a way to express united interest with one powerful voice, representing the many members.

Why does Vanguard have a PAC?

By law, Vanguard cannot contribute directly to political candidates. It can, however, sponsor a PAC which uses voluntary employee contributions to support candidates who best represent the concerns, interests, and values of our company. By sponsoring the PAC, Vanguard has a united voice in the federal political process.

Where will my contributions go?

PAC funds are contributed to political candidates’ campaigns for federal office. All contributions go toward the support of candidates; no contributions are used for administrative costs, which are covered by Vanguard, nor are contributions used to support campaigns unaffiliated with a candidate. All contributions are reported to the Federal Election Commission (FEC) on a regular basis, typically monthly and at least quarterly. The FEC posts all contributions on its website and provides its data to organizations that also make such information available to the public.

What criteria is used to make contributions?

Vanguard has a well-defined set of principles that guides its contribution decision-making process. The VCRG Board consisting of Natalie Lamarque​, Kaitlyn Caughlin, Rick Delfin, John Galloway, and Ryan Swann will oversee a robust framework for candidate giving. Policymakers receiving VCRG donations will be thoughtfully discussed as we consider their relevance, openness to investor concerns, and responsibility.​

If I contribute to the Vanguard PAC, can I contribute to an individual candidate of my choice, too?

Yes, subject to Vanguard’s Political Contribution and Fundraising Activity Policy. This policy requires all crew members to obtain advance approval from the Compliance Department before crew members, or a member of their household, makes any political contribution to any federal, state, or local official or candidate for federal, state, or local office, or to any political party or organization (e.g., a non-Vanguard PAC). In most cases, political contributions will be approved; however, based on applicable law, the dollar amount of political contributions to incumbents or candidates for state or local office will be limited. Additionally, contributions to federal officials or candidates for federal office could be restricted if those officials are running for local or state office, or if a state or local official is running for federal office. A summary of the policy’s highlights is provided below. Please refer to the full Political Contribution and Fundraising Activity Policy on CrewNet.

A. Preclearance of political contributions and fundraising activities

All crew members are required to obtain preclearance from Compliance before a crew member:

• Makes any political contribution to a federal, state, or local official, or a candidate for federal, state, or local office; or
• Participates in any political fundraising activity for any federal, state, or local official or candidate for federal, state, or local office.

To obtain preclearance, complete and submit a Political Contribution Form via MCO. Compliance will review each request to determine whether the contribution or fundraising activity is permitted under applicable law and is consistent with this policy.

B. Contribution Limits

In order to comply with the SEC pay-to-play rule, and other applicable law, Vanguard is limiting the amount of political contributions that can be made by crew members, and in certain circumstances, by members of their household, as follows:

State or local officials

• If a crew member is entitled to vote for the state or local official, or candidate for state or local office, the crew member may contribute up to $250 (in cash or things of value) per election.
• If a crew member is not entitled to vote for the state or local official, or candidate for state or local office, the crew member may contribute up to $150 (in cash or things of value) per election.

These limits also apply to contributions to state or local officials running for federal office or federal officials running for state or local office.

In certain situations, applicable law may impose additional restrictions or outright prohibitions on the contributions that may be made by crew members based on their positions.

Federal officials

Although contributions to incumbents or candidates running for federal office must be precleared under this policy, such contributions are not subject to Vanguard-imposed contribution limits, unless the person running for federal office also happens to be a state or local official at the time of the contribution.

C. Limitations on political fundraising activities

Based on applicable law, crew members in certain positions or departments within Vanguard may be prohibited from participating in political fundraising activity. This prohibition may include PACs controlled by such crew members.

D. Limitations on contributions to political parties and PACs

You, or a member of your household, may contribute to a political party or PAC only if you can confirm that the contribution is not a means to accomplish indirectly that which you are prohibited from doing directly. For example, the contribution to the political party or PAC may not be earmarked for or made for the benefit of a specific state or local official. Anyone seeking to make a contribution to a PAC or political party will be asked by Compliance to certify that the contribution will not result in an indirect violation of this policy. You can satisfy this requirement by demonstrating, for example, that the contribution will be used by the PAC or political party to fund the general activities of the organization, or by demonstrating that the PAC or political party will not funnel a contribution to a state or local official.