Investors

FICO’s Government Relations team is responsible for development and execution of our political and public policy engagement activities, in consultation with and at the direction of members of the executive team and senior management who are accountable to the FICO Board of Directors. The head of FICO Government Relations reports directly to the Executive Vice President of Software, who in turn reports directly to our Chief Executive Officer and member of the Board. Political and public policy decisions are made without regard to the private personal political preferences of our executive team or any other senior leaders.   

FICO is committed to complying with all applicable federal, state, and local laws and regulations in connection with our political and public policy engagement activities. Accordingly, FICO maintains internal policies and procedures that are designed to ensure compliance with applicable laws and adherence to our commitment to ethical conduct, accountability, and transparency. This includes FICO’s Code of Business Conduct and Ethics, which is reviewed annually by the Audit Committee to the Board of Directors, as well as FICO’s Policy on Interactions with Government Officials.

Federal law prohibits FICO from making direct political contributions to candidates running for federal office or national political committees.

FICO policy prohibits the use of corporate funds by any employee for political contributions, even where permissible, without the express consent and consultation of FICO Government Relations, in accordance with the FICO Policy on Interactions with Government Officials.   

FICO does not direct corporate funds to independent political expenditure committees or to electioneering communications in support or opposition of a clearly identified federal candidate.

FICO does not make corporate political contributions to any state candidates or state political committees, even when permitted by state law.

FICO does not contribute corporate funds for the purpose of supporting or opposing state or local ballot measures and initiatives.

FICO does not use corporate funds to support Super PACs or political committees organized under section 527 of the Internal Revenue Code.

Future use of corporate funds by FICO for any of the above categories of expenditure will be disclosed as required by law and detailed on FICO’s website.

FICO values the right and responsibility of our employees to participate in our democratic process. We recognize that such participation is a matter of personal choice. FICO provides eligible employees with the opportunity to voluntarily participate in the political process by joining the Fair Isaac Corporation Political Action Committee (“FICO PAC”). FICO PAC is a non-partisan political action committee with the goal of elevating our level of engagement in Washington by directly supporting candidates who are active and aligned on policy issues of importance to us and the industries in which we and our customers operate.

FICO PAC contributions to candidates are made in accordance with the FICO PAC Governing Principles and with the approval of the FICO PAC Advisory Board (“Advisory Board”) which oversees the FICO PAC. The Advisory Board meets several times a year to set FICO PAC policy and approve PAC budgets and disbursements. The Advisory Board is composed of representatives from several of our business units and includes members of our executive team and senior management.

FICO PAC contributions to federal candidates are determined by the Advisory Board based on the FICO PAC disbursement policy. To be considered for a contribution from the FICO PAC, a candidate must be focused on issues important to FICO and/or the industries in which we participate, and exhibit behavior that does not conflict with FICO’s standards for ethics and integrity in operating its business. In addition, a candidate must satisfy at least one of the following criteria: hold a position of leadership; serve on a committee(s) with jurisdiction over policy issues of importance to FICO; represent a state or district that has a significant presence of FICO employees and/or facilities; or align with views and actions taken on public policy issues of importance to FICO. FICO PAC is a non-partisan PAC and may support candidates of any political affiliation.

FICO PAC complies with all applicable federal, state, and local campaign finance laws. On non-election years the PAC reports to the FEC on a quarterly basis, switching to monthly reporting on election years. A full list of FICO PAC’s disbursements in 2023 can be found here:

Fair Isaac Corporation (FICO) PAC 2023 Disbursements

FICO Government Relations, in conjunction with FICO management, engages in lobbying on public policy issues of importance to us. This includes communicating with officials, regulators, and other policymakers, to convey our position and provide information for the purposes of helping to inform the policymaking process. FICO Government Relations is committed to strong ethical conduct, accountability, and transparency in connection with all lobbying activities.

Federal lobbying activities are regulated by the Lobbying Disclosure Act (“LDA”). In accordance with the LDA, FICO files quarterly disclosure reports with the Clerk of the House and Secretary of the Senate regarding expenditures for federal lobbying activities. These reports disclose all direct and indirect expenses related to lobbying, including the portion of membership payments to industry trade associations and other tax-exempt advocacy organizations that are allocated to lobbying activities. These federal lobbying reports can be found here:

Fair Isaac Corporation Federal Lobbying Reports (LD-2)

FICO is a participant – through full or associate membership – in various industry trade associations that advocate on major public policy issues of importance to our business operations, our customers, and other industries relevant to us. Our participation in these various industry trade associations comes with the understanding that we might not always agree with all positions taken by the associations and/or their other members, and that we are committed to voicing our concerns as appropriate. Participation in these associations is primarily led by FICO Government Relations.

FICO pays regular membership dues to various industry trade associations. Some of these associations utilize a portion of membership dues for non-deductible lobbying expenditures. In accordance with the requirements of Section 162(e)(1) of the Internal Revenue Code, the industry trade associations to which we contribute must provide us with the percentage of our annual dues that are attributable to lobbying expenses. A listing of the industry trade associations of which we are members and pay dues of greater than $2,000, along with the portion of the membership dues attributable to lobbying in 2023, can be found below: