Individual Political Engagement Policy
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.
Political Contributions
Political contributions are integral to shaping public policies that affect our business and stakeholders. Eastman supports state and local candidates whose platforms align with the company’s strategic objectives and shareholder interest, always ensuring strict compliance with the following established political spending guidelines and all applicable laws. Personal political preferences of Eastman executives, directors, and employees play no part whatsoever in decisions involving political contributions.
Corporate Contributions
Members of the EastmanPAC Executive Board approves political expenditures for all corporate contributions. Approvals made by these members are as follows:
- Corporate political contributions under $5,000 made by Eastman or on its behalf in the United States, as set forth by the Government Affairs organization, must require the express authorization of the Vice President of Corporate Affairs.
- Contributions of $5,000 or more must be authorized by the Vice President of Corporate Affairs and the Officers of the EastmanPAC Executive Board.
As a matter of policy, Eastman rarely makes direct corporate political contributions to political party committees, ballot committees, or political action committees, even when permitted to do so by applicable law. Pursuant to state law, however, Eastman makes corporate political contributions to state candidates. Eastman also operates, 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.
State Contributions
Eastman makes corporate political contributions to state candidates where permitted under state law. 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. Funding of the Eastman State of Tennessee PAC is approved by the EastmanPAC Executive Board Officers. Individual contributions from the Eastman State of Tennessee PAC are approved by the EastmanPAC Treasurer and Assistant Treasurer, and contributions are publicly disclosed in the Political Contributions Report and to the Tennessee Ethics Commission in compliance with state law.
Corporate political contributions less than $5,000 to a state candidate outside of Tennessee, if permitted by law, is set forth by Eastman’s Government Affairs organization and approved by the Vice President of Corporate Affairs. Contributions of $5,000 or more is set forth by Eastman’s Government Affairs organization and approved by the Vice President of Corporate Affairs and the Officers of the EastmanPAC Executive Board.
Federal Contributions
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 and the 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.
Governance
Eastman’s Government Affairs organization routinely reviews the Company’s corporate and EastmanPAC political contributions to ensure they align with these guidelines throughout the year.
In addition to the regular management by Eastman's Government Affairs 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, government policy, political contributions policies, and expenditures on a semi-annual basis. Such review and oversight allow 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.
The EastmanPAC Executive Board, comprised of a diverse group of Eastman employees, including members of the Company's Executive Team and at least one employee from Eastman’s Law department, is responsible for approving political expenditures of all corporate contributions including the funding of the Eastman State of Tennessee PAC.