The company participates in trade associations for a variety of reasons, including networking, building industry skills, civic participation and monitoring of industry policies and trends. Company participation in trade associations, including membership on a trade association board, does not mean that the company agrees with every position a trade association takes on an issue. In fact, from time to time our corporate positions may differ from those of the trade association of which we are members.
The company makes payments to these associations, including membership fees and dues.
Each year, we make a list available of the U.S. trade associations organized under Section 501(c)(6) of the Internal Revenue Code to which the company paid annual dues of $25,000 or more. The company asks these trade associations what portion of the company’s payments were used for non-deductible lobbying expenditures under Section 162(e) of the Internal Revenue Code. The percentage of dues for lobbying are disclosed when provided by the trade association.
The company’s policy is to instruct U.S. trade associations not to use company funds for independent campaign expenditures or contributions to any federal, state or local candidate, ballot measure, party committee, non-candidate organization (such as political convention host committees) or organizations organized under Section 527 of the Internal Revenue Code.