Thank you for your willingness to volunteer in support of Williams for Sheriff (the “campaign”). These guidelines discuss some of the laws and regulations that apply to your volunteer activities and lay out ways in which you can volunteer without making “in-kind contributions” that the campaign would have to report to the Federal Election Commission (“FEC”). It is your responsibility to comply with these rules and all other campaign finance and election laws, but if you have questions, please do not hesitate to contact a campaign staffer or seek legal advice.
You may spend as much time volunteering for the campaign as you are able and willing to commit. Federal election law exempts the value of a volunteer’s time from counting as a contribution. To fall within this exception, however, you may not receive compensation from any source for the time you are volunteering. For example, you should not volunteer when you are on the clock at work, and if you have a salaried position, you must generally volunteer only during time off, such as nights, weekends, and vacation time.
The one minor exception to this rule is for “occasional, isolated, or incidental” time you spend on your volunteer efforts while at work, as discussed in more detail in the following section.
Avoiding Corporate Contributions; Company Time, Facilities and Meeting Spaces
It is against the law for a corporation to contribute to the campaign. Accordingly, one of the most important issues to be aware of when you are volunteering is not to make use of corporate or company resources, except in the very limited circumstances described below. This applies to the company where you might work, your own small business, and businesses around town like restaurants and coffee shops, as well as to items like office supplies, equipment, letterhead, office or meeting space, etc.
Individual Volunteer Activities While at Work. Provided that it is consistent with your internal company policy, you may use the office space and resources of the company where you work during and after working hours to conduct individual volunteer activities on behalf of the campaign. That activity must be only “occasional, isolated, or incidental.” The phrase “occasional, isolated, or incidental” means any such individual volunteer political activity that does not exceed one hour per week or four hours per month. Even if your activities exceed this de minimis limit, they may still be considered “occasional, isolated, or incidental,” so long as they do not “prevent the employee from completing the normal amount of work which that employee usually carries out.” Either way, your activities may not increase corporate overhead or expenses.
This means that you may occasionally make a local phone call or send an email from work concerning your volunteer activities if doing so would be permitted under your employer’s policies.
Use of Corporate Meeting or Office Space. You should generally not hold volunteer events, meetings, or rallies in corporate space, like an office conference room, lobby, or a private room at a restaurant. If you do, the value of that space may be considered an illegal corporate contribution to the campaign, unless you pay for the space in advance, in which case you will still have made a reportable contribution.
The only exception to this rule is for space that is customarily made available without charge to any club, civic organization, or other group, regardless of political affiliation.
Special Rules for Events at Your Home: Space, Food and Invitations
You can use your own personal residence for hosting a volunteer event without the use of the space becoming a reportable contribution to the campaign. This same rule applies to the use of a recreation room in your residential complex, or a church or community room, provided that the space is regularly used for non-commercial purposes and is available without regard to political affiliation.
Furthermore, when you host an event in your home, or a community room as discussed above, you may spend money on invitations, food, and beverages, without those costs becoming reportable contributions to the campaign.
You may spend up to $1,000 per election on food, beverages, and invitations while hosting volunteer events on behalf of the campaign in your home or in a community room without making a contribution. Your spouse may also separately spend up to $1,000 per election in connection with your volunteer events without it constituting a contribution. While such expenditures do not count against your contribution limit and are not disclosed to the FEC, you must still keep records of your expenses.
Note: This allowance does not extend to other sorts of expenses, such as decorations or entertainment.
You may also obtain discounts from vendors on foods or beverages (including corporate vendors) beyond those that the vendor might normally give. However, the vendor may not charge below cost and the discount applies only to the sale of food and beverages. Also, vendors may not give discounts to the campaign in excess of $1,000. This means that you may not accept discounts from a vendor worth more than $1,000 in connection with your volunteer efforts for the campaign, and you should also ask your vendors whether they have recently given discounts for other campaign events.
Other Considerations Regarding Location
There are several other issues that you should keep in mind when choosing a location for your volunteer event.
Partisan political activities are prohibited in many federal, state, and local government buildings. It is best to avoid any publicly owned building for your events, but if you are planning on using a space in a public library or town hall, for example, it is your responsibility to ensure that there is no law, rule, or regulation, that would prohibit you from doing so.
If you are holding a large event in a public space, such as the courthouse square, park, or on the sidewalk, you may be subject to local permitting requirements. You should confirm with your local police department.
As long as you follow these guidelines, you may use the Internet to discuss and promote your campaign volunteer activities.
Websites. You may create and operate your own website, or your own personal web page on a website such as Facebook or Twitter, subject to that website’s internal policies. The use of your personal computer is not considered to be a contribution to the campaign.
Email. You may send as many personal emails as you would like, to as many people as you would like. Please be respectful of any request to be taken off of your email list.
Use of the Internet While at Work. As discussed above, you may make occasional, isolated, or incidental use of computers at your workplace for your personal, volunteer Internet activities in connection with the campaign, so long as that use does not violate any of your workplace’s policies. Your Internet activities must not prevent you from completing your normal amount of work or interfere with any of your workplace duties. When sending emails in support of the campaign, you should use your personal email address and not your work email address.
Travel in Connection with Your Volunteer Activities
Transportation Expenses. When traveling on behalf of the campaign, you may spend only up to $1,000 in transportation expenses without making an in-kind contribution.
Food and Lodging. Food and lodging expenses paid for by volunteers for their own use when traveling are not considered contributions to the campaign, no matter the amount. As a result, volunteers may spend as much money as they like on their own hotels and restaurants without incurring in-kind contributions. However, if you pay for the food and lodging expenses of others while they are volunteering on behalf of the campaign, you could be making an in-kind contribution to the campaign.