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This policy sets forth basic principles concerning political contributions and activities. It is our policy to conduct business ethically and in compliance with all applicable laws, and in a manner that is consistent with the values espoused in our Business Ethics and Conduct Policy.
APPLICABILITY
This Political Contributions Policy applies to all employees of Lyondell Chemical Company and its consolidated subsidiaries.
POLITICAL CONTRIBUTIONS
While we encourage our employees to be involved in local political processes as individuals, in most cases the law prohibits corporations, including corporations that are partners in a business, from contributing to political candidates. If a contribution is illegal, it cannot be made, either as a direct donation of corporate funds or as an "in-kind" gift of corporate goods or services. Because of the complexity of the laws in this area, only Lyondell’s Government Affairs Department may make political contributions on behalf of the company.
We are subject to legislation and regulations that significantly impact our business operations. Our Government Affairs Department staff lobbies on issues that impact the company and our ability to do business. Political contributions, where permitted, are an important part of the political process, and are made in accordance with this policy as permitted under federal, state and local laws.
We maintain a political action committee (Lyondell PAC) program to allow our employees to be engaged in the political and legislative processes. The Lyondell PAC is supported by voluntary contributions from qualified employees. These contributions are reported to relevant federal, state and local campaign finance agencies as required by law. Moreover, the Lyondell PAC publicly discloses its contributions to the Federal Election Commission.
Contributions are made to candidates based on factors which include:
Whether they understand and support our businesses;
Whether they represent a district or state where we have operations and employees or where significant business interests could be affected;
Their elected leadership position; and
Whether they are an effective advocate for our businesses.
Lyondell PAC’s Board of Directors, comprised of Lyondell executive officers and senior management employees, is responsible for the oversight, accountability and administration of the political contributions process. This Board reviews PAC contributions to ensure they represent the interests of the company and its stockholders, and are in compliance with all applicable laws. Additionally, internal controls exist to ensure company compliance with federally mandated contribution limits.
EMPLOYEE POLITICAL ACTIVITIES
Employees are free to participate in personal political activities on their own time in any manner consistent with federal, state, and local laws. When engaging in personal political activities, we expect employees to make it clear that they are not acting as a representative of Lyondell. Employees must not perform personal political activities on company time or use company resources. Lyondell will not reimburse or otherwise compensate an employee for political contributions.