HCA Healthcare participates in the political process to help educate policymakers, shape public policy, and address proposals and legislation that impact the patients and communities we serve. We are subject to extensive regulation at the federal, state, and local levels and are involved in a number of legislative initiatives across a broad spectrum of policy areas that can have a significant efect on the patients and communities we serve, our employees, and our business and operations. We ethically and constructively promote legislative and regulatory actions that further the objectives of HCA Healthcare, such as improving access and quality of care.
Government Relations employs a number of tools to educate policymakers, including direct lobbying and participation in trade associations and coalitions with other healthcare organizations. These advocacy tools are implemented pursuant to our compliance protocols, consistent with our Company's Code of Conduct, and in accordance with applicable federal and state laws.
[Our Company's Code of Conduct and Government Relations policies (GR.001, GR.002) provide guidance to](https://hcahealthcare.com/util/forms/ethics/2020-Code-of-Conduct-a.pdf) help ensure our work is done in an ethical and legal manner. Government Relations assesses HCA Healthcare's compliance needs, updates our policies as appropriate, and invests resources to ensure applicable standards are met. Additional information regarding the applicable provisions of the Company's Code of Conduct; our policies and procedures regarding political giving; and our political action committee (PAC), lobbying, and trade association activities is set forth below.
HCA Healthcare's Senior Vice President (SVP) - Government Relations has final authority over HCA Healthcare's political spending decisions. Our Government Relations team, which reports to our SVP - Government Relations, oversees regulatory matters and government afairs, including our direct and indirect advocacy and political contributions in the United States at the federal, state, and local levels.
Our political activities are also subject to oversight by our Board of Directors. The duties of our Nominating and Corporate Governance Committee (comprised solely of independent directors), pursuant to its written charter, include reviewing and considering the Company's policies and practices regarding political activities, including political contributions and lobbying. The Board reviews periodic reports of the Company's political expenditures prepared by the SVP - Government Relations.
HCA Healthcare publishes and archives on our website semi-annual reports regarding political contributions and related activity.
#### Lobbying activity
Federal, state, and local statutes and regulations (e.g., the Lobbying Disclosure Act and Honest Leadership and Open Government Act) govern our corporate lobbying activities and require the Company and its representatives to disclose relevant advocacy activity to the public and abide by applicable gif and ethics rules governing engagement with public ofcials and employees. Outside legal counsel prepares and files required reports for our in-house federal lobbyists. Lobbying reports for external federal lobbyists are reviewed by HCA Healthcare's SVP [Government Relations. Federal lobbying reports filed by HCA Healthcare are publicly available at lobbyingdisclosure.](https://lobbyingdisclosure.house.gov/)
[house.gov.](https://lobbyingdisclosure.house.gov/)
Lobbying reports for our state lobbyists are reviewed and approved by the state's respective Government Relations Director and filed in the respective state. State lobbying disclosure records are also generally available for public review via state government websites and online filing platforms managed by the state lobbying regulatory authority for each jurisdiction. Links to state lobbying reports filed by HCA Healthcare state lobbyists can be viewed [online at HCAhealthcare.com/LobbyingReports.](https://hcahealthcare.com/government-relations/state-lobbying-reports.dot)
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HCA Healthcare supports trade associations that represent a broad spectrum of views on industry and policy issues.
Lobbying and maintaining memberships in trade associations are important parts of participating effectively in the political process. We believe the associations in which we participate take positions and address policy issues in a collective industry manner and often advance positions consistent with HCA Healthcare's interests. However, participation in the political process and as a member of various trade associations comes with the understanding that we may not always agree with all of the positions of the organizations in which we participate, the other members of those organizations, and the stakeholders and policymakers with whom those organizations communicate.