El Toro works with a significant number of political candidates, independent expenditure organizations political action committees, and campaign committees. As such, we have a legal and ethical responsibility to ensure that each digital advertising campaign is delivered in compliance with all federal and state regulations regarding campaign finance and coordination of expenditures. In simple terms, as an employee or contractor you are prohibited from working on behalf of multiple parties who are legally prohibited from coordinating or communicating with one another. An example of this prohibited behavior can include working on behalf of a campaign and an independent expenditure committee for the same candidate.
Below are the basic tenants of our policy:
- This policy applies to employees and consultants engaged in advertising work or interacting directly with a candidate, authorized committee or political party committee. From a practical standpoint this is typically the sales and account management teams at El Toro.
- Employees and consultants working on behalf of a candidate, authorized committee, or political party committee are prohibited from communicating with another employee about their work if that employee has direct contact with another candidate, authorized committee, or political party committee in the same race.
- This firewall policy also prohibits employees and consultants who have direct contact with candidates or committees from discussing and conveying material information to those employees and consultants who do not have direct contact with the candidates or committees who are engaged in non-coordinated advertising efforts.
- If approached by a potential client that may represent any conflict with the policy outlined above, please notify your supervisor immediately.
Collectively by following these steps we can ensure that El Toro is able to deliver high quality digital advertising targeting services to our political clients.
Note – While this is an internal policy that is largely applicable to employees and contractors, we also expect clients and potential clients to notify us of any possible conflicts prior to campaign submission. Additionally, since many large political purchasers require a copy of this policy we have conveniently posted it on our website. Please contact us if you have any questions about political firewalling.