Integrity Standard - Political Activity and Community Involvement

Policy:
Federal laws restrict the use of corporate funds in connection with federal elections, and there are similar laws in many states. It therefore is the policy of the Company that neither Company name, the Company funds, nor Company facilities shall be used directly or indirectly for political purposes on behalf of candidates for political office, political parties or elected incumbent office holders at any level, federal, state or local, except as permitted by law and the Company’s Political Activity Policy. The Company will not reimburse employees for contributions to political candidates or causes.

The Company is committed to playing a leadership role in fulfilling our social responsibility. Our efforts to meet our obligations will vary from location to location. The Company’s local presence and commitment will be coordinated at the corporate level and shaped by local needs and opportunities. Employees are encouraged to participate in community programs.

Employees are encouraged to vote and participate fully in the political process. However, except as permitted by Company policy, we cannot use Company resources to vote and be active in political activities. Employee participation in non-corporate political activity is strongly encouraged, but must be done on our own time and at our own expense. The Company complies with the requirements of all applicable laws entitling employees to excused “time off” for voting.

Nothing in this Standard prohibits eligible salaried employees from voluntarily participating in the Company’s Political Action Committee (PAC) activities nor does it prohibit the Company from bearing the administrative expense of establishing and operating federal or state Political Action Committees (PACs) in conformance with Company policy and with applicable federal and/or state legal requirements.

The Company's management may, from time to time, distribute memos or sponsor activities to bring political and public policy issues to the attention of employees. These activities may include participation by public officials or candidates for public office. Any such activities by the Company shall be for the purpose of encouraging employee participation in the public policy dialogue and shall not constitute endorsement of any particular candidate, officeholder or political party. Equal opportunity will be afforded all rival candidates and political parties.

Question & Answers

Q: Can I, on occasion, do some personal volunteer work monitoring election practices during various municipal, state, and federal elections?
A: You may use PTO days to work as a volunteer in the election-related activities mentioned. However, no reimbursement will be made by the Company for any expenses which you incur.

Q: Can I speak at a local club meeting on the issue of health care reform?
A: Yes, as long as you make it clear that you are speaking for yourself and not as an official spokesperson for our Company. If you are asked to represent our Company in a formal capacity, you should obtain approval from your EVP/SVP who will advise you whether you need to discuss the matter and review your proposed presentation with our Public Affairs Department.

Q: Can our Company pay for the administrative expenses necessary to establish and operate either a federal Political Action Committee (PAC) or a state Political Action Committee (PAC)? May I voluntarily participate in the Company’s PAC program?
A: Under federal and state laws, the Company is permitted to pay the costs necessary to establish and operate federal and state PACs. It is also legally permissible for Company employees both to voluntarily contribute to a federal or state PAC and to perform the administrative tasks necessary to establish and operate a federal or state PAC.

Q: I just received an e-mail announcing that a candidate for office will be speaking in our building to employees. Doesn't that violate our Code by using the building for political purposes?
A: Provided all rival candidates or political parties are offered equal access, this does not constitute endorsement of a particular candidacy and is not a violation of our Code.

Q: Our Public Affairs Department has sent out an e-mail urging employees to contact members of the Legislature in opposition to a specific piece of legislation. They say the bill would hurt our company. Isn't that a violation of the Code?
A: No. Public policy issues differ from political endorsements. The Company's ability to operate effectively depends upon fair and equitable legislation and regulation at both the state and federal levels. It is important that the company and its employees be heard on these issues. However, while the Company is entitled under the Code to encourage such employee participation; it is always voluntary on the part of the employee.

Remember, if you do not understand, or if you have any questions concerning, this Integrity Standard or any other part of the Code, contact your Supervisor, a higher level Supervisor, any of the Corporate Resources or call the Corporate Integrity HOTLINE
(1 800 838-2552).