**Political Engagement and Contributions Policy**
As part of Annaly's long-standing commitment to corporate responsibility, we believe that
responsible corporate citizenship demands active engagement on public policy. We utilize our
market expertise, strong reputation, and the relationships that we have developed with
policymakers over time to share our insights on areas that we believe lead to more stable housing
and financial markets and that may impact our company. Annaly has adopted this policy to ensure
that our political engagement and contributions comply with all applicable laws, are consistent
with our core values, and protect and enhance shareholder value.
- **Oversight, Compliance, and Monitoring**
Annaly's political engagement and public policy activities are managed by the Corporate
Responsibility and Government Relations (CRGR) Team, which reports directly to the Chief Legal
Officer of the Company, in coordination with Legal and Compliance and Senior Management. The
Corporate Responsibility (CR) Committee of the Board of Directors (Board) oversees Annaly's
positions and practices on public policy matters, including compliance with this policy, and our
Senior Management reports to the Board or the CR Committee as needed on the Company's
legislative and regulatory priorities and advocacy initiatives. The CR Committee will periodically
review this policy and must approve any amendments to or deviations from this policy.
- **Political Contributions**
Annaly prohibits the use of corporate funds for any political contributions, including contributions
to Super PACs, political committees organized under Section 527 of the Internal Revenue Code,
and 501(c)(4) organizations that may use funds for political purposes. We also prohibit the use of
corporate funds for any independent political expenditures or electioneering communications in
direct support of or opposition to any candidates, parties, campaigns, or ballot initiatives.
Any decisions regarding political contributions and expenditures are based solely on promoting
the best interests of the Company and our shareholders, without regard for the private political
preferences of the Company's officers, directors, or employees.
- **Employee Political Action Committee**
Annaly maintains a federal political action committee (Annaly PAC), which is registered with the
Federal Election Commission. The Annaly PAC is funded exclusively through voluntary
contributions from eligible employees, which are not reimbursed by Annaly. As legally permitted,
Annaly supports the modest cost of administering the Annaly PAC for our employees, but does
not contribute any corporate funds to the Annaly PAC.
The Annaly PAC makes political contributions on a bipartisan basis in accordance with our
contribution policies and procedures and in support of our public policy goals. The Annaly PAC
also generally avoids independent expenditures and electioneering communications in support or
opposition to a candidate, out-of-cycle contributions, and contributions to presidential campaigns
or to state and local candidates. Corporate funds are not contributed to the Annaly PAC. As
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required by law, all political contributions accepted or made by the Annaly PAC are filed with the
Federal Election Commission on a monthly basis and are publicly available.
The Annaly PAC is managed by the CRGR Team, is subject to oversight by the Chief Legal Officer
of the Company in their role as Director of the Annaly PAC, and is fully compliant with all federal,
state, and local laws, regulations, and disclosures.
- **Trade and Business Associations**
As part of our engagement in the public policy process, Annaly is a member of several 501(c)(6)
trade associations and industry groups, such as the Securities Industry Financial Markets
Association (SIFMA), the Mortgage Bankers Association (MBA), and the Structured Finance
Association (SFA), that represent the interests of both the financial services industry and the
broader business community. These associations may engage in political activity on behalf of
their members and represent a broad range of perspectives on public policy issues, not all of which
we support. Our membership in these organizations is intended to accomplish a wide of range of
business objectives that could affect the Company's performance.
Membership in trade associations requires that we pay regular dues. Some trade associations
utilize a portion of membership dues for non-deductible state and federal lobbying and political
expenditures. Annaly does not make additional, non-dues payments to support a trade
association's political contributions or expenditures. Additionally, we instruct these organizations
and groups not to use our funds for any election-related activity at the federal, state, or local levels,
including contributions and expenditures (including independent expenditures) in support of, or
opposition to, any candidate for any office, ballot initiative campaign, political party, committee,
or PAC.
- **Advocacy Lobbying**
Annaly does not currently employ any lobbying firm or engage in any lobbying activities.
Although we do not have any plans to engage in lobbying in the future, we will disclose any such
lobbying activity where and as required by law.
- **Reporting and Amendments**
While Annaly prohibits the use of corporate funds for any political contributions or expenditures,
in the event the CR Committee approved an amendment to or deviation from this policy and the
Company thereafter were to make political contributions or expenditures, the Company would
disclose such contributions or expenditures on our website on a semi-annual basis.
For the purpose of this policy, the words "contributions" and "expenditures" shall include direct
and indirect monetary contributions to candidates, as defined by 26 U.S.C. ยง 162(e)(1)(B), and
contributions to political committees, ballot measures, 501(c)(4) organizations, and political
parties.