EAO 503

The single fact that a corporation shares a vendor with a candidate would not constitute a campaign contribution by the corporation to the candidate. If a corporation uses its general treasury funds to make a campaign expenditure to a vendor for services to benefit a candidate, and if the vendor is concurrently providing campaign services to both the corporation and the candidate or if the vendor has previously provided campaign services to the candidate, the expenditure may constitute a prohibited contribution to the candidate. Whether the expenditure constitutes a prohibited contribution depends on whether the expenditure is made with the prior consent or approval of the candidate. An expenditure that is not made with the prior consent and approval of the candidate is not a campaign contribution to the candidate.