Public Policy

Dell and its employees are active and engaged in their communities. Whether it's charitable activities or political engagements, Dell employees are informed and involved in the decisions that affect their company. Dell believes that supporting candidates who understand the company's legislative initiatives and policies is appropriate and in the best interest of its customers, employees and stockholders.

In connection with this activity, Dell has embraced a strong policy of strict adherence to federal and state campaign finance laws and regulations governing political contributions and the disclosure of those contributions. Pursuant to federal law, employees have established a separate, segregated fund or Political Action Committee (PAC), which is supported solely by voluntary contributions from eligible employees, spouses of eligible employees and shareholders who collectively choose to allocate those contributions to federal and state candidates and committees.

Dell and Dell™ PAC's political spending reflects company, employee and shareholder interests and not those of individual officers or directors. Dell has a strong policy regarding gifts to United States Congressional officials. The company policy on political disclosure and accountability is outlined as follows.

Personal Employee Political Activities

Employees are free to volunteer in political activities and contribute personal resources to candidates and parties in any manner consistent with applicable federal, state and local laws. Employees may not use Dell resources or coercive solicitations to further their own personal political activities.

Consistent with federal law, Dell does not contribute corporate funds to federal candidates, national political party committees or other federal political committees. Contributions may only be made by the Dell Employee PAC (Dell PAC). Dell also does not contribute corporate funds to state or local candidates, even where permissible by state and local laws. Contributions to state candidates may only be made through the Dell PAC.

Dell sponsors a federal PAC, which allows employees to voluntarily pool their resources to support candidates for public office. Dell PAC fully discloses all contributions made and received on reports filed with the Federal Election Commission and the various state ethics commissions, as required by law.

In compliance with applicable laws, the Dell PAC contributes money to candidates for federal and state office, political parties and committees. From time to time, the Dell PAC solicits support from employees but coercive solicitations are strictly prohibited. A PAC Executive Committee governs and oversees all PAC activities. Outside ethics counsel reviews and approves all PAC materials and activities.

For more information, please contact PAC@Dell.com

The Executive Committee has the following functions:

• Establishes policy
• Delegates authority
• Names the treasurer and assistant treasurer (on recommendation of the chair)
• Performs the functions of a corporate board of directors

The Executive Committee is composed of 10 voting members. All members of the Executive Committee must be employees or former employees and current shareholders of Dell. The Executive Committee meets quarterly to review, revise and approve PAC activities. The current chair of the Executive Committee is the Dell senior vice president and general counsel.

PAC Audit

An audit of the PAC is performed at least once every two-year federal election cycle to ensure compliance with federal election laws, equivalent state and local laws, and all other applicable laws. The audit results and corrective plan, if any, are sent to the PAC Executive Committee and to the office of the CEO.

Dell does not contribute corporate funds or PAC funds to state or local ballot initiatives or to support or oppose state or local referenda.

Dell will make no corporate contributions to any noncandidate or nonparty affiliated political committees organized under section 527 of the Internal Revenue Code. Dell may make contributions to certain established and nationally recognized organizations that are organized under Section 527 of the federal tax code, such as the Republican and Democratic Governors Associations. In cases when Dell makes these payments, they are reviewed and approved by the PAC Executive Committee, as well as the Dell senior vice president and general counsel.

In addition, the Dell Board of Directors will be informed once a year on membership and dues to all 527 groups. Dell will disclose all such contributions to 527 organizations on its website under major U.S. trade associations and organizations to which Dell belongs.

Dell belongs to several trade associations and pays regular dues to these groups. Dell does not normally make additional, nondues contributions to these organizations to support the groups' political activities. In the event that Dell does make payments to trade associations that are designated for political purposes and are beyond the required annual dues, Dell will disclose such contributions on its website.

Dell will inquire and make a reasonable effort to obtain from the trade associations listed what portion of the company's dues or payments were used for lobbying expenditures or political contributions that, if made directly by Dell, would not be deductible under Section 162(e)(1) of the Internal Revenue Code.

To enable interested parties to review Dell PAC contributions, Dell posts on its company website links to specific databases compiled by the Federal Election Commission (FEC), The Center for Responsive Politics and The Center for Public Integrity.

Major US Trade Associations and Organizations to Which Dell Belongs

Dell is a member of several diverse organizations. In some instances, the official policy position of Dell may differ with that of the supported organization. Dell is a member of the organization because of the total value the organization brings to Dell, Dell employees and Dell shareholders.

Dell constantly reevaluates membership with all the organizations to which it belongs and adds and drops membership on an ongoing basis.

To align with the criteria of the Center for Public Accountability, Dell is disclosing its trade associations, how much it pays them and how much of what it pays is used for lobbying. The information below reflects the Dell state and local associations and federal associations.

State and Local Associations