Eastman encourages personal participation in the political process, consistent with applicable laws and Company policy. Eastman employees must follow the laws governing participation in political affairs, including political contributions, lobbying, and gift giving. Employees are free to give a personal contribution to a party, committee, or candidate on their own behalf, but are prohibited from making any contribution of Company funds, or from seeking reimbursement of contributions, including petty cash, property, or services to any political party or committee, or to any candidate or holder of any office of any government without specific, prior approval from Eastman's Government Affairs Department and the Law Department.
Any employee who is considering seeking public office should be aware of applicable Company personnel policies and should discuss the matter with Eastman's Government Affairs organization, as well as their management and Human Resources representative. To prevent a conflict of interest and assure compliance with applicable law, at no time should Eastman's name, information, property (including personnel, office space, computers, email accounts, telephones, copiers, etc.), time, or other resources be used for political activities not specifically sponsored by the Company or approved by Eastman's Government Affairs Department.
Any contribution by the Company to a political party or candidate must be done in accordance with all applicable laws. To ensure compliance with contribution laws, no political contribution of any kind, either direct or indirect, shall be made by the Company or on its behalf without the express authorization from the Company's Vice President, Corporate Affairs, Eastman's Government Affairs Department, and the Law Department.
As a matter of policy, Eastman rarely makes direct corporate political contributions to political candidates, political party committees, ballot committees, or political action committees, even when permitted to do so by applicable law. Pursuant to state law, however, Eastman does operate, through a separate legal entity, the Eastman State of Tennessee PAC, which is funded by corporate funds and only supports Tennessee state candidates. Eastman State of Tennessee PAC contributions are publicly disclosed on the Political Contributions Report and TN.gov.
Further, it is Eastman's general policy not to directly support or oppose ballot initiatives or to make direct independent expenditures that advocate the election or defeat of federal, state, or local candidates, despite the law permitting corporations to make such expenditures. Eastman, however, could support or oppose ballot initiatives in the future if the initiative would materially and directly impact the interests of the Company and our stockholders and employees. When such contributions are made, they are publicly disclosed on the Political Contributions Report.
Federal law prohibits corporate political contributions to candidates in connection with federal elections. Such contributions include any direct or indirect payment, distribution, subscription, loan, advance, deposit, or gift of money, services or anything of value to any candidate, campaign committee, political committee, or political party in connection with any federal election. However, the Supreme Court's decision in Citizens United permits a corporation to make independent expenditures on behalf of candidates.
It is Eastman's general policy not to make direct independent expenditures that advocate the election or defeat of federal, state, or local candidates. In the event, however, that funding an independent expenditure through a Section 527 or Section 501(c)(4) organization ("indirect independent expenditure") will advance the Company's position on issues that are of critical importance to it, the Company will disclose the amount and recipient of such payment on the Political Contributions Report as required by federal and state law. Prior approval for the expenditure must be obtained from Eastman's Chief Executive Officer, Chief Legal Officer, and Vice President of Corporate Affairs. Requests for such expenditures will be considered on a case-by-case basis and will include the review of whether the contribution would be an appropriate means of advancing issues that are important to Eastman's business, stockholders, and other stakeholders and whether it is an appropriate means of advancing Eastman's public policy position. Policies and initiatives of importance to the Company fall in the following areas:
- Circular economy
- Chemical management
- Energy and environment
- Tax
- Trade
Further, all Eastman federal contributions and other political spending are reported to the Board of Directors and the Board's Environmental, Safety and Sustainability Committee semi-annually and are disclosed publicly as required by federal and state law and on the Political Contributions Report.
Eastman rarely makes corporate political contributions to state candidates, even where permitted under state law, with one exception. Eastman has established the Eastman State of Tennessee PAC which, pursuant to state law, may use Eastman funds not to exceed $25,000 per year or $50,000 in the aggregate over a two-year election cycle to make contributions solely to Tennessee state candidates. Contributions from the Eastman State of Tennessee PAC are approved by the EastmanPAC Treasurer, Assistant Treasurer and Chair and are publicly disclosed to the Tennessee Ethics Commission in compliance with state law. A monthly report of contributions made by the Eastman State of Tennessee PAC is provided to officers of the EastmanPAC Advisory Council.
Any Eastman corporate contributions to a state candidate outside of Tennessee, if permitted by law, are approved by EastmanPAC' s Treasurer and Assistant Treasurer. and Chair. A monthly report of corporate contributions made to candidates in states other than Tennessee is provided to officers of the EastmanPAC Advisory Council. Further, all Eastman state contributions and other political spending are reported to the Board of Directors and the Board's Environmental, Safety and Sustainability Committee semi-annually and are disclosed publicly as required by federal and state law and on the Company website.
In addition to the regular management by Eastman's Government Affairs Department, Law Department, Eastman's Board of Directors and the Board's Environmental, Safety and Sustainability Committee (the members of which Committee are all of the Board's independent non-employee directors) review and oversee the Company's involvement in political activities and government policy and political contributions policies and spending semi-annually. Such review and oversight allows continued application of Eastman's high ethical standards, transparency in the Company's political involvement, and ensures that the Company's political involvement is in the best interests of stockholders and the Company and are made without regard for the private political preferences of executives.