It amazes me how many ways elected officials misuse charitable
organizations to engage in ethical misconduct, especially to get
around gift rules. One would think that charities would be
sufficiently sacrosanct. But instead they are frequently used as an indirect form of pay to play, and they have played a major role in getting around campaign finance limitations.
The form of misuse of charitable organizations that this post will look at
involves a company that wants to get around restrictions on
corporate campaign contributions. It is not enough that the
company's employees are allowed to give to a corporate SSF
(separately segregated fund, essentially a corporate PAC). The
company decided to induce such gifts by double "matching" them with
its own gifts to a charitable organization that does only one
thing: help out its employees when they are in need.
The company is Wal-Mart, the charity is Wal-Mart Associates in
Critical Need Fund, and the matter that has arisen is a
complaint filed with the Federal Election Commission
Public Citizen and Common Cause. The most amazing fact stated in the
complaint is that the FEC has already issued twelve opinions on this
very topic, allowing almost all of the situations on
the grounds that there was not "an exchange of corporate treasury
funds for voluntary contributions and a form of indirect
compensation for the contributor's contribution."