Political and Lobbying Activities
Background and guidelines
91³Ô¹ÏÍø¹ÙÍø engages in U.S. political and lobbying activities in ethical and responsible ways to advocate for the company’s business interests. The personal preferences of individual employees or directors have no bearing on the company’s political and lobbying activities and payments.
Government Relations manages the company’s political and lobbying activities. 91³Ô¹ÏÍø¹ÙÍø maintains a robust compliance program with internal controls to ensure political and lobbying activities are conducted and disclosed in compliance with applicable laws and company policies.
91³Ô¹ÏÍø¹ÙÍø’s Board of Directors has oversight of the company’s political and lobbying activities and meets at least annually with the Head of Government Relations. The Nominating and Corporate Governance Committee of the Board of Directors approves the company’s reports on political spending and trade association memberships. The executive-level Enterprise Responsibility & Sustainability Committee, with authorities delegated by the Nominating and Corporate Governance Committee, manages these annual reports and monitors related company policies, practices, and systems.Â
Company Political Contributions and Expenditures
91³Ô¹ÏÍø¹ÙÍø does not contribute company funds to any political party, committee, or candidate for federal office. 91³Ô¹ÏÍø¹ÙÍø does not make independent political expenditures in direct support of, or in opposition to, campaigns, and the company does not make payments to influence the outcome of ballot measures. 91³Ô¹ÏÍø¹ÙÍø’s annual political spend report provides a summary of political contributions and expenditures.Â
91³Ô¹ÏÍø¹ÙÍø Political Action Committee
The 91³Ô¹ÏÍø¹ÙÍø. Political Action Committee (91³Ô¹ÏÍø¹ÙÍø PAC) is a voluntary, nonpartisan organization that operates in accordance with U.S. campaign finance laws as well as its own bylaws and policies. The 91³Ô¹ÏÍø¹ÙÍø PAC is organized to support candidates running for federal office who are aligned with the company’s positions on key issues directly related to our business and industry. The 91³Ô¹ÏÍø¹ÙÍø PAC maintains a bipartisan distribution strategy and does not contribute to presidential candidates or to candidates at the state and local levels.
91³Ô¹ÏÍø¹ÙÍø PAC disbursements are funded entirely by voluntary personal contributions from eligible 91³Ô¹ÏÍø¹ÙÍø employees and family members, members of the company’s Board of Directors, and company stockholders. 91³Ô¹ÏÍø¹ÙÍø uses its general treasury funds to pay the establishment, administration, and fundraising costs of the 91³Ô¹ÏÍø¹ÙÍø PAC, as permitted by law, but 91³Ô¹ÏÍø¹ÙÍø cannot and does not contribute company funds to the 91³Ô¹ÏÍø¹ÙÍø PAC’s disbursement account.
The 91³Ô¹ÏÍø¹ÙÍø PAC is managed and governed by its own board of directors, which is chaired by the Head of Government Relations and composed of leaders from across the company. 91³Ô¹ÏÍø¹ÙÍø PAC activities are not influenced by direction from company leadership. The 91³Ô¹ÏÍø¹ÙÍø PAC’s board of directors meets quarterly and is responsible for ensuring that disbursement recipients meet the 91³Ô¹ÏÍø¹ÙÍø PAC’s established support criteria. The Head of Government Relations briefs the company’s Board of Directors annually on 91³Ô¹ÏÍø¹ÙÍø PAC activities. 91³Ô¹ÏÍø¹ÙÍø PAC disbursements are reported to the Federal Election Commission. These reports are available to the public at
Company Lobbying Activities
91³Ô¹ÏÍø¹ÙÍø’s Government Relations team represents 91³Ô¹ÏÍø¹ÙÍø in direct engagements with members of Congress, Executive Branch officials, and select trade associations to provide meaningful input on policy, regulatory, and legislative issues that affect the company. Â
In compliance with the federal Lobbying Disclosure Act, 91³Ô¹ÏÍø¹ÙÍø reports all lobbying activities and expenses to Congress quarterly. These reports include full lists of federal lobbyists and the issues on which they lobby. They are available to the public via the .
Trade Associations
91³Ô¹ÏÍø¹ÙÍø joins a select number of trade associations in support of our strategic business objectives. 91³Ô¹ÏÍø¹ÙÍø employees can maintain individual trade association memberships so long as the association and employee activities comply with company policies.
Company payments to trade associations are typically associated with membership fees or dues, event and program sponsorships, and individual employee memberships and professional development. A trade association payment does not mean 91³Ô¹ÏÍø¹ÙÍø agrees with the trade association’s lobbying activities.
91³Ô¹ÏÍø¹ÙÍø publishes annually on our website a report on trade associations for which the company’s annual membership dues totaled $50,000 or more. A trade association may choose to allocate a non-deductible percentage of its membership dues to lobbying activities. 91³Ô¹ÏÍø¹ÙÍø discloses this percentage in the report. In accordance with federal law, the company accounts for the non-deductible percentage in quarterly reports to Congress on lobbying expenditures. These are available to the public via the .
Employee Activities
91³Ô¹ÏÍø¹ÙÍø encourages employees to be informed about public policy issues and respects their right to participate in the political process on a personal basis in accordance with all applicable laws and company policies, including the Code of Business Ethics & Conduct and the Political Activities & Lobbying policy. Individual employees may make contributions to candidates, parties, or other political organizations pursuant to applicable federal, state, and local laws or otherwise engage in political activities, but those contributions and activities are private in nature and do not necessarily reflect the perspective of 91³Ô¹ÏÍø¹ÙÍø. The company will not take any adverse employment action against an employee based on their personal political affiliation or lawful political activity.
