Conducting Business with Governments - CA Technologies
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Conducting Business with Governments

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Government business

The laws and regulations governing contracting with government agencies impose requirements and create risks not traditionally associated with commercial business transactions. Violations of the laws and regulations can subject CA Technologies to damaging litigation, reduction of negotiated contract prices, payment of fines, suspension of our eligibility to receive government contracts and debarment from doing business with the government. Violations may also subject CA Technologies and the individual employees involved to civil lawsuits or criminal prosecution, with possible resultant fines, debarment or suspension and prison sentences.

If your job includes doing business with the government, you must be aware of the many rules and regulations that could apply. A few examples include rules that may restrict employees from making contributions to political campaigns, contacting government employees during restricted periods, influencing legislative or executive action, or giving anything of value, or offering employment to government personnel. There are also requirements to report all lobbying activity, which can be defined very broadly. You should work with the U.S. Public Sector Legal Group if you have any questions regarding compliance in this area.

For non-U.S. government business, you should work with your local Worldwide Law Department Area Counsel.

What would you do?

You are going to a meeting with an IT procurement employee at your state government customer, and you'd like to give her a CA Technologies coffee mug. You don’t have a current deal on the table with this customer, and you know she'd appreciate the mug which really doesn’t have much value at all anyway.

Is this okay?

Not necessarily.

In the U.S. you must obtain pre-approval from the U.S. Public Sector Legal Group. Depending on what state or municipality you are working with, giving a gift of any value to government personnel with any influence over the award of a contract can be deemed to be a violation of the pay-to-play and gift laws. In the U.S. you should always check with the U.S. Public Sector Legal Group or the Regulatory Law Group within the Worldwide Law Department before offering or giving any gift to a government employee.


It is CA Technologies policy to adhere strictly to lobbying laws and regulations wherever it does business. The definitions of lobbying vary widely and may be quite broad. Generally, any contacts with government personnel for the purpose of influencing legislation, regulations or decision-making may constitute lobbying. However, this may also include activities that you would not ordinarily think of as lobbying such as providing and servicing software solutions to state agencies or even purchasing a cup of coffee for a government employee. Lobbying laws almost always require registration and/or disclosures. If your work for CA Technologies might include lobbying or working with government agencies or personnel in the public sector, you are responsible for understanding these laws and CA Technologies policies, and for U.S. issues you should work with the U.S. Public Sector Legal Group and the Regulatory Law Group within the Worldwide Law Department to ensure compliance in this area. For non-U.S. government business, you should work with your local Worldwide Law Department Area Counsel.

Political contributions

CA Technologies encourages employees to be involved in civic affairs and the political process. As CA Technologies continues to execute against our strategic goals we need to have a strong voice and effective advocacy in Washington, D.C. on issues that are critical to the success of our business. Federal law prohibits companies from contributing directly to federal campaigns with corporate dollars.

You should be aware that employees may not contribute CA Technologies funds, property or services to any Federal political party, committee or candidate for any governmental office. Prohibitions include but are not limited to):

  • Using Company email or mailing lists or other resources to promote a candidate
  • Using Company time to perform volunteer work for political candidates
  • Pressuring any colleague, vendor, customer or partner to make political contributions or support any political party or candidate, even implicitly (for example, you cannot ask your subordinates to purchase tickets to a political fundraiser)
  • Reimbursing any individual for making a political contribution

Due to so-called "pay-to-play" laws, certain Company executives and those working with public sector customers may be restricted from making personal political contributions, or may have to disclose those contributions, due to CA Technologies role as a governmental contractor. If you have any questions, you should work with the U.S. Public Sector Legal Group and the Regulatory Law Group within the Worldwide Law Department to ensure compliance in this area. For non-U.S. government issues, you should work with your local Worldwide Law Department Area Counsel.


In the U.S., there are Federal, State and local laws and regulations that prohibit government officials from accepting gifts, and CA Technologies and its employees are required to abide by those laws and regulations as well. These laws vary from jurisdiction to jurisdiction, and you should never offer or provide a gift of any value to anyone in the U.S. public sector without first obtaining written approval from the U.S. Public Sector Legal Group. (Remember that a "gift" can be anything that has value.)

If you are unsure about whether you may make a political contribution or if you want to provide a gift to an individual without violating our rules, please contact a member of the U.S. Public Sector Legal Group and the Regulatory Law Group within the Worldwide Law Department. For political contributions or gifts to non-U.S. government officials, you must consult your local Worldwide Law Department Area Counsel and/or the Business Practices and Compliance Team.

Legal proceedings and audits

It is CA Technologies policy to cooperate with government inquiries and to respond appropriately to legal proceedings of all kinds. To meet these obligations, the Worldwide Law Department must be notified immediately of any lawsuit, investigation, inquiry, subpoena or legal proceedings in which the Company is or might be involved, including any situations where an employee is involved as a third-party (for example, as a witness) if the matter concerns the employee’s job or job duties. Information, whether oral or written, or records or files of any nature, must not be furnished to any outside party in connection with a legal proceeding without the prior written approval of the Worldwide Law Department.

In addition, employees must never, under any circumstances:

  • Lie or make misleading statements in connection with any government or other investigation or legal proceeding, or cause another employee to do so
  • Destroy, alter or conceal any documents (or other materials) in anticipation of or following a request for those documents in connection with any investigation or legal proceeding

Similarly, you must not, directly or indirectly, mislead or otherwise impair the work of the Company's internal auditors, internal investigators or external public accountants or legal counsel.

What would you do?

A manager asks you to contribute to a political candidate, and indicates that the Company will "make it up to you".

Is that okay?


This would be against CA Technologies policy and likely a violation of the law. You should decline the request and report the matter using the procedures described in this Code.

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