United Parcel Service Inc

Lobbying Governance

AI Extracted Evidence Snippet Source

## Political Contributions and Lobbying

#### Overview

Responsible participation in the political process is important to our success and the protection and creation of shareowner value. We participate in this process in accordance with good corporate governance practices. Our Political Contributions Policy ("policy") is summarized below and is available at www.investors.ups.com. In addition, we have recently committed to expanding our reporting around lobbying and trade association memberships.

- The Nominating and Corporate Governance Committee oversees the policy;

#### Oversight and Processes

- Political contributions are made in a legal, ethical

and transparent manner that best represents the
interests of stakeholders.

- Political and lobbying activities require prior

approval of the UPS Public Affairs department and
are subject to review (and in some cases prior
approval) by the Nominating and Corporate
Governance Committee.

#### Lobbying and Trade Associations

- Public Affairs coordinates our lobbying activities,

including engagements with federal, state, and
local governments. UPS is also a member of a
variety of trade associations that engage in
lobbying.

- Lobbying activities require prior approval of

Public Affairs.

- The Nominating and Corporate Governance
Committee regularly reviews UPS's participation in
trade associations that engage in lobbying to
determine if our involvement is consistent with

#### Political Activity Transparency

- We believe we are transparent in our political

activities.

- We publish a semi-annual political contribution

report, which is reviewed and approved by the
Nominating and Corporate Governance Committee.

- The report provides:

– Amounts and recipients of any federal and state

Company political contributions in the United
States (if any such expenditures are made);
and

– The names of trade associations that receive

$50,000 or more and that use a portion of the
payment for political contributions, as reported
by the trade association to the Company.

- Corporate political contributions are restricted;

- We publish a semi-annual political contribution

report on our investor relations website; and

- Eligible employees can make political contributions

through a Company-sponsored political action
committee ("UPSPAC"). UPSPAC is organized and
operated on a voluntary, nonpartisan basis and is
registered with the Federal Election Commission.

- Senior management works with Public Affairs on

furthering our business objectives and protecting
and enhancing shareowner value.

- The Chief Corporate Affairs Officer reviews political

and lobbying activities and regularly reports to the
board and the Nominating and Corporate
Governance Committee.

UPS business objectives and whether participation
exposes the Company to excessive risk.

- Lobbying activities are governed by comprehensive

policies and practices designed to facilitate
compliance with laws and regulations, including
those relating to the lobbying of government
officials, the duty to track and report lobbying
activities, and the obligation to treat lobbying
costs and expenses as nondeductible for
tax purposes.

- The report is available on our investor relations

website at www.investors.ups.com.

- We also publicly file a federal Lobbying Disclosure

Act Report each quarter, providing information on
activities associated with influencing legislation
through communications with any member or
employee of a legislative body, or with any
covered executive branch official. This report
discloses expenditures for the quarter, describes
the specific pieces of legislation that were the topic
of communications, and identifies the individuals
who lobbied on behalf of UPS. UPS files similar
publicly available periodic reports with state
agencies reflecting state lobbying activities.

https://investors.ups.com/sec-filings/all-sec-filings/content/0001090727-23-000015/0001090727-23-000015.pdf

## I. Governance

UPS is committed to maintaining robust governance policies and practices that benefit the long-term interests of all stakeholders. We regularly review and update our corporate governance policies and practices in response to the evolving needs of our business, shareowner and other stakeholder feedback, regulatory changes and other corporate developments.

The Board's oversight responsibilities include strategic planning, risk management, succession planning, human capital management, executive compensation, compliance, internal audit, political engagement and financial reporting. This includes oversight of climate-related matters as a part of the Company's overall business strategy.

The Board considers climate-related risks in numerous ways, including through its standing committees. The Board's Risk Committee is responsible for oversight of management's identification and evaluation of enterprise risks, including the Company's climate-related risks. Economic, environmental and social sustainability risks and opportunities are considered as part of our comprehensive enterprise risk management program. Under our enterprise risk management process, risks, including climate-related, are identified, prioritized and assigned an owner, who is responsible for developing mitigation plans. The Risk Committee reviews these items on at least an annual basis.

The Board's Nominating and Corporate Governance Committee has additional oversight responsibility for climate-related risks and opportunities. This committee receives regular updates and discusses the Company's progress toward its sustainability-related goals, as well as the associated risks and opportunities, with feedback from these discussions shared with the full Board.

The Board's Audit Committee is responsible for overseeing the annual engagement of the independent third party that performed a review (limited assurance) on UPS management's assertion that the disclosures in our 2023 GRI Content Index as of and for the year ended December 31, 2023 are presented in accordance with the GRI Sustainability Reporting Standards, as well as an examination (reasonable assurance) on management's assertion relating to the Statement of Greenhouse Gas Emissions for the year ended December 31, 2023, in accordance with attestation standards established by the AICPA.

The full Board oversees the development of the Company's climate-related goals. Additionally, the Board regularly reviews the Company's risks, opportunities and progress with respect to its climate-related goals. Included as a part of these reviews are reviews of the Company's annual sustainability reports prior to publication.

UPS provides Board members with various opportunities to develop and enhance their knowledge of climate-related topics. For example, UPS facilitates a director engagement program in which directors meet with individual Executive Leadership Team ("ELT") members, visit Company operations, participate in employee events and receive in-depth subject matter updates outside of regular Board meetings, including efforts to meet existing sustainability goals. [...] ## IV. Risks Presented by Misaligned Lobbying

We work to ensure that, to the greatest extent possible, UPS's direct lobbying and that of our trade associations, remains aligned with our emissions reduction and climate goals. Our analysis indicates that our direct and indirect lobbying largely supports these efforts.

In some cases, differing approaches to policy and technology challenges may be characterized by those who disagree with a particular policy or technology approach as misaligned with achieving emissions reduction and climate goals. But, in many cases, these different approaches do not actually represent a misalignment. In evaluating these cases, we examine them in the context of the complex public policy landscape. For example:

###### • We have strongly advocated for the inclusion of RNG as part of incentive programs and regulatory schemes that seek to reduce emissions from the transportation sector. Renewable Natural Gas (RNG), or biogas, is gas produced from methane emitted through the decomposition of animal manure, food waste, forest management waste, wastewater sludge, and garbage. RNG projects capture this methane and redirect it away from the environment, repurposing it as an energy source for vehicles. Because of the avoided emissions associated with capturing methane that would otherwise be released into the atmosphere, the use of RNG as a transportation fuel can reduce carbon emissions significantly more than other alternative fuels. For instance, the RNG produced from animal waste on dairy farms used by UPS has an average carbon intensity of -200 gCO2e/MJ. This means that for every megajoule of energy produced by the RNG, a quantity of greenhouse gases with the global warming potential equivalent to 200 grams of CO2 is removed from the atmosphere. This fuel is our most effective tool to reduce greenhouse gas emissions from our ground fleet based on current technologies. Some groups do not believe that utilizing RNG is an effective strategy to combat emissions from the transportation sector and instead advocate for transitioning only to vehicles

with zero tailpipe emissions. While these divergent views lead to different approaches to reducing GHG emissions, our support for RNG does not represent a misalignment with our climate goals.

###### • The American Trucking Associations has advocated for performance-based and technology-neutral emissions reductions standards rather than technology-specific mandates. ATA's position reflects concerns that technology mandates are a less effective and more costly approach to reducing greenhouse gas emissions from the transportation sector than performance-based emissions standards. ATA worked on and supported two separate Environmental Protection Agency/National Highway Traffic Safety Administration regulations establishing first-ever standards for truck engine and vehicle GHG emissions and fuel consumption standards (known as Phase 1 and Phase 2 respectively) to promote a new generation of cleaner, more fuel-efficient trucks. We believe ATA's advocacy for solutions that reduce greenhouse gas emissions while taking into consideration vehicle capability, technology readiness, and manufacturing costs aligns with our climate goals.

###### • The Low Carbon Fuels Coalition advocates for Clean Fuels Standard (CFS) policies that require fuel suppliers to reduce the carbon intensity of transportation fuels. Our experience with existing CFS programs is that they are an effective and efficient way to rapidly increase the use of lower carbon fuels in the transportation sector. Last year, the California Air Resources Board reported that, thanks to the state's CFS program, clean fuels replaced over 50% of the diesel used in the state in the first quarter of 2023. Some groups oppose CFS policies because they believe market-based policies will not reduce emissions within timeframes or at the scale required to mitigate climate change or deliver emissions reductions benefits to affected communities. We believe that CFS programs are an important policy tool to combat climate change and promote greater use of low-carbon fuels.

https://investors.ups.com/_assets/_9eabd0229202a7278e9a56989f99d6da/ups/files/pages/sustainability/political-engagement-policy/UPSClimateLobbyingReport.pdf

We also consider stakeholder engagement an essential aspect of corporate governance and consult regularly with a diverse and global set of stakeholders focused on climate change and emissions issues. We report on these engagements and on our energy consumption and emissions goals in our annual corporate sustainability report, which can be found at about.ups.com/social-impact/reporting.

https://about.ups.com/content/dam/upsstories/assets/governance/UPS-Statement-Climate-Change-05102021.pdf

## Political Engagement Policy

Political Engagement Policy Report July - December 2024

Previous reports archive »

## I. Overview

United Parcel Service, Inc. ("UPS" or the "Company") presents the Company's viewpoint regarding legislation and regulations to appropriate levels of federal, state and local government. UPS maintains an active program to inform government officials of the Company's views, business, and the benefits which the public derives from UPS's services. Participation in public policy discussions is crucial to maintaining UPS's shareowners' long-term economic interests.

This UPS Political Engagement Policy (the "Policy") describes UPS's practices relating to political contributions and expenditures, as well as the practices relating to UPS's lobbying activity. It does not apply to contributions to political parties, candidates or committees that support elections outside of the United States. The Policy should be read in conjunction with the *Political Activities and Contributions* policy in the *UPS Code of Business Conduct* (UPS\_Code\_Business\_Conduct\_2013.pdf)

The Policy is designed to ensure that UPS's political contributions and lobbying activities are consistent with the Company's core values, benefit the long-term interests of shareowners, and comply with all applicable laws. The Policy is also intended to provide stakeholders with additional information about political engagement oversight and reporting.

The Board of Directors (the "Board") has adopted the Policy.  The Board delegated to the Nominating and Corporate Governance Committee of the Board (the "Committee") the administration of the Policy.  The Committee and the Board receive regular updates from management on the Company's political engagement activities.

## III. State and Local Elections

The Policy generally prohibits any state and local corporate political contributions or expenditures unless approved by the Nominating and Corporate Governance Committee (the "Committee").

## IV. Political Contribution and Expenditures and the UPS Political Action Committee

The Policy generally prohibits any corporate political contributions or expenditures unless approved by the Committee. Political contributions and expenditures are made through a voluntary employee-funded Company-sponsored political action committee ("UPSPAC"). The President of the UPS Public Affairs Department oversees UPSPAC and regularly reports to the Committee concerning UPSPAC activities.

## V. Lobbying Activities

UPS participates in the public policy process in order to advance the interests of the Company and its shareowners. All lobbying activities are conducted in compliance with federal and state laws and regulations, and in a manner that is consistent with the Company's values and strategies.

The UPS Public Affairs department coordinates the Company's lobbying activities, including engagements with federal, state, and local governments. All lobbying activities require the prior approval of the UPS Public Affairs Department. The UPS Public Affairs Department works with senior management to identify opportunities for furthering the Company's business objectives, thereby protecting and enhancing shareowner value.

The President of the UPS Public Affairs Department reviews all UPS lobbying activities and regularly reports to the Board and the Committee concerning lobbying activities. The Company engages in lobbying activities that align with the annual priorities set out by the state and federal Public Affairs teams.

## VI Trade Associations

The Company expresses its interests in matters of public policy and industry standards and practices. At times, the most efficient way to accomplish this goal is through associations with third parties. UPS carefully weighs the benefits and obligations of any organization or association before joining. UPS also continually monitors its involvement to ensure that its interests are being properly represented and that the resources UPS commits are being used wisely. If an organization or association takes policy positions contrary to those of the Company, UPS actively advocates its point of view by working from within the organization. Given the variety of business issues in which many associations and other groups are engaged, UPS does not necessarily agree with all positions taken by every organization in which it is a member. In these circumstances, the Company weighs the utility of continued membership against the consequences of differing positions or opinions.

## VII. Reporting

The Company complies with all applicable laws and regulations regarding reporting requirements for political contributions and lobbying activities. In some case, UPS goes beyond what is legally required in reporting. Following is a list of reports related to our political engagement activities.

1. UPSPAC Reporting

UPSPAC contributions and disbursements, including amounts and recipients, can be viewed on the Federal Election Commission website at www.fec.gov under the *PAC and party committee reports* section. UPSPAC's year-end and monthly reports can be found at UNITED PARCEL SERVICE INC. PAC - committee overview | FEC**.**

2. Lobbying Reporting

The Company's federal lobbying reports provide information on activities associated with influencing legislation through communications with any member or employee of a legislative body or with any covered executive branch official. The reports also provide disclosure on expenditures during the quarter, describe the specific pieces of legislation that were the topic of communications, and identify the individuals who lobbied on behalf of the Company. The reports can be found on the websites of the Clerk of the House (http://lobbyingdisclosure.house.gov/)  and the Secretary of the Senate (http://www.senate.gov/legislative/Public\_Disclosure/LDA\_reports.htm)

UPS spent approximately $8.6 million in 2023 on federal lobbying. Approximately 9.5% of this amount was associated with indirect lobbying by trade associations. Priority issues at the state and federal level in 2023 included:

* Alternative Fuel Taxes
* CHIPS Act
* Corporate Tax
* Cross Border Security
* Customs Modernization, Trade Facilitation & De minimis
* E-Commerce Policy
* Enforcement of Cross-Border Trade and Security Policies
* Federal Aviation Administration Reauthorization
* Regulated Goods Shipping
* Joint Employer Rule
* Labor & Employment Regulations
* Heat Injury and Illness Prevention
* Pilot Flight & Duty Time
* Global Supply Chains Policy
* Tariff Policy
* Tort Reform
* Infrastructure Investment and Jobs Policy

The Company files similar periodic reports with state agencies reflecting state lobbying activities, which are also publicly available. UPS lobbies in all 50 states and territories on a variety of issues as described above.

3. UPS Political Engagement Policy Reporting

i. Corporate Political Contribution Reporting

Although Company policy is to generally prohibit corporate political contributions or expenditures, if approved by the Committee, any contributions or expenditures made by the Company in the United States will be disclosed. The Company will report any such contributions or expenditures on a semi-annual basis on its website at Political Contributions :: United Parcel Service, Inc. (UPS). For the purpose of this paragraph, the words "contributions" and "expenditures" include direct and indirect monetary contributions to candidates, as defined by 26 U.S.C. §162(e)(1)(B), and contributions to political committees, ballot measures and political parties. The report shall address compliance with this policy and shall be presented to the Committee for approval prior to publication. Trade Association Political Contribution Reporting

ii. Trade Association Political Contribution Reporting

UPS annually notifies its trade associations to not use UPS dues for political contributions or expenditures. If any trade association that receives total payments of $50,000 or more in a given year from UPS uses a portion of UPS dues or payments for political contributions or expenditures that if made directly by UPS would not be deductible under Section 162(e)(1)(B) of the Internal Revenue Code, then the Company will report these amounts and the names of the associations semi-annually on its website at Political Contributions :: United Parcel Service, Inc. (UPS). Prior to publication, the report will be presented to the Committee for approval.

iii. Trade Associations Memberships and Lobbying Reporting

Certain trade association memberships will be disclosed on the Company's website at Political Contributions :: United Parcel Service, Inc. (UPS). This includes the name of any association that received $25,000 or more in membership dues in a given year and the percentage of dues used by the trade associate for lobbying purposes that, if expended directly by UPS, would not be deductible under Section 162(e)(1)(A) of the Internal Revenue Code. Prior to publication, the report will be presented to the Committee for approval.

iv. Other Organizations Memberships and Lobbying Reporting

Certain memberships at other organizations that draft model legislation or conduct lobbying will be disclosed on the Company's website at Political Contributions :: United Parcel Service, Inc. (UPS). This includes the name of any organization that received $25,000 or more in membership dues (inclusive of any additional member fees associated with participation in that organizations working groups or taskforces) in a given year. Prior to publication, the report will be presented to the Committee for approval.

v. Climate Lobbying Report:  This report provides an overview of the climate goals and climate policy principles that inform the climate lobbying activities in which UPS engaged in, both directly and indirectly, through trade associations in 2023.

## VIII. Amendments and Waivers

The Committee will periodically review the Policy and recommend any amendments to the Board for approval.  The Committee must also approve any waivers to the Policy.  Any waiver that involves corporate political contributions or expenditures may be approved only if designed to promote the interests of the Company and its shareowners, and without regard for the private political preferences of the Company's officers and directors.  If a waiver from the Policy is approved, any corporate contributions or expenditures will be reported as described above.

https://investors.ups.com/corporategovernance/political-engagement-policy

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]UPS's Chief Corporate Affairs Officer regularly reports to the Nominating and Corporate Governance Committee regarding UPS's sustainability efforts and lobbying activities. The Board also monitors UPS's memberships in trade associations and other tax-exempt organizations that engage in lobbying. Furthermore, UPS's decision-making process for lobbying activities is transparent.
UPS's Public Affairs department works with senior management on furthering business objectives and on protecting and enhancing long-term shareowner value.

CDP Questionnaire Response 2022

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]No, and we do not plan to have one in the next two years

CDP Questionnaire Response 2023

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]UPS's Chief Corporate Affairs and Sustainability Officer regularly reports to the Nominating and Corporate Governance Committee regarding UPS's sustainability efforts and lobbying activities. The Board also monitors UPS's memberships in trade associations and other tax-exempt organizations that engage in lobbying. Furthermore, UPS's decision-making process for lobbying activities is transparent. UPS's Public Affairs department works with senior management on furthering business objectives and on protecting and enhancing long-term shareowner value. We set a goal to achieve carbon neutrality by 2050 across Scope 1, 2, and 3 emissions (as measured in CO2e and using market-based Scope 2 emissions). Our targets are based on sound engineering principles. We do not currently believe that, based on such principles, scalable solutions for aircraft exist at this time that would allow for the achievement of a science-based target by 2030 or 2035, as required by the Science-Based Targets initiative ( SBTi).

CDP Questionnaire Response 2023