Political Activities

The Universal Health Services, Inc. (UHS) Political and Advocacy Activity Policy, as well as the day-to-day management of political and advocacy activities, are overseen by the UHS General Counsel or his or her designee.   The UHS General Counsel will make reports to the Audit Committee of the UHS Board of Directors regarding UHS political and advocacy activities as necessary and the Audit Committee will review UHS political and advocacy policies.

Except for the limited circumstances discussed below, all UHS political contributions and expenditures are made through a Separate Segregated Fund (SSF) registered with the Federal Election Commission (FEC) and funded by voluntary contributions from eligible employees.  The SSF uses these funds to support candidates for elected office at the federal, state, and local levels in the U.S., as allowed by law, in furtherance of UHS’s interests and without regard for the private political preferences of UHS or subsidiary/affiliate executives. UHS does not contribute corporate funds to the SSF, but does provide administrative support as allowed by federal law. Eligible employees who are U.S. citizens or lawfully admitted for permanent residence in the U.S. may support the activities of the SSF through voluntary contributions made in accordance with applicable laws. The UHS General Counsel’s office reviews and approves contributions made by the SSF.

UHS has adopted a political activity policy that provides that UHS and its subsidiaries/affiliates, with limited exceptions, does not use corporate funds to make political contributions or pay for independent expenditures. Specifically, no corporate funds or UHS or its subsidiaries/affiliates may be used to contribute to any candidate, campaign committee, political party, 527 organization, Super PAC, independent expenditure committee, or ballot question committee, or to pay for any independent expenditure made in direct support of or opposition to a campaign, unless it has been approved, in advance, by the UHS General Counsel’s office.  Any proposed corporate contributions or expenditures are considered on a case-by-case basis, must be determined to be in the interest of UHS and/or its subsidiaries/affiliates, and must be without regard for the private political preferences of UHS or subsidiary/affiliate executives. All corporate contributions and expenditures must be properly disclosed as required by relevant law.

Prior to joining or contributing to a third-party advocacy group on behalf of UHS or its subsidiaries/affiliates, such as a 501(c)(4) social welfare organization or a 501(c)(6) trade association, employees must consult with and obtain the approval of the UHS General Counsel’s office.  UHS is currently a member of several associations, including:

• Federation of American Hospitals
• National Association for Behavioral Healthcare

In addition, certain UHS subsidiaries/affiliates may be members of their respective state hospital associations.

UHS and subsidiary/affiliate corporate contributions to ballot question committees will be considered on a case-by-case basis, must be in the interest of UHS and its subsidiaries/affiliates, and must be approved by the UHS General Counsel’s Office. This restriction applies to ballot questions, initiatives, measures, referenda, propositions, proposed statutes, constitutional amendments, and the committees and other efforts to support or oppose them. All ballot question committee contributions must be properly disclosed as required by relevant law.

The UHS Board of Directors will review UHS’s Political and Advocacy Activity Policy as appropriate.  Training or information regarding UHS’s policy will be provided to key officers and employees by the UHS General Counsel’s office as needed.