Entergy Corp

Lobbying Governance

AI Extracted Evidence Snippet Source

**Public Policy & Advocacy**

Entergy Corporation's success depends on sound public policies at the national, state, and local levels.
We are involved in a number of legislative and regulatory initiatives in a broad spectrum of policy
areas that can have an immediate and dramatic effect on our operations. Through our participation
and that of our employees, we promote legislative and regulatory actions that further our business
objectives.

**Entergy Political Contributions and Political Action Committee Activity**

- Corporate Political Contributions

Political contributions of all types are subject to extensive governmental regulation and
public disclosure laws and reporting requirements. Entergy is fully committed to complying
with all applicable campaign finance laws and has procedures in place to assure that
corporate political contributions are made in compliance with applicable laws and will be timely
reported.

Federal law prohibits Entergy from supporting candidates for federal office while some states
permit corporate contributions to state and local candidates or ballot issue campaigns. It is
the policy of Entergy and its subsidiaries that corporate contributions may not be made directly
to federal, state, or local candidates. Our policy also prohibits Entergy and its subsidiaries from
making direct independent expenditures. Corporate contributions to federal, state, and
local political associations and organizations, including ballot measure committees, may be
made by Entergy and its subsidiaries with the requisite approval. At the state level, approval
of the President of the appropriate subsidiary is required, and at the federal level, approval
of the Senior Vice President, Federal Policy, Regulatory and Governmental Affairs is
required. All contributions are reviewed to ensure compliance with applicable laws and
regulations. Entergy also places the limitations below on its political contributions:

o Political contributions shall comply with all applicable laws and regulations related
to ethics in government, lobbying, and political contributions.
o Political spending will reflect Entergy's interests and not those of its individual officers
or directors.
o No political contribution will be given in anticipation of, in recognition of, or in return for any
official act.
o Employees will not be reimbursed for personal political contributions or expenses, either
directly or through compensation increases.

- Trade Associations

We also participate in federal, state, and local issues through our membership in various trade
organizations which we join to represent various business and industry interests. In addition,
we actively promote the economic health of the jurisdictions we serve through our activities
with chambers of commerce.

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- Social Welfare Organizations

We also make contributions to non-profit groups that are organized and operated to promote
social welfare. These groups may also engage in political activities so long as such activities do
not become their primary purpose. We support these groups to further guide policies and
legislation that affect our business.

- Entergy Political Action Committees

Entergy has established the Entergy Corporation Political Action Committee ("ENPAC")
to encourage its employees to participate in the political process. Entergy employees who
are defined as executive, professional and administrative personnel may make voluntary
contributions to ENPAC. ENPAC is independent of any political party or candidate.

ENPAC is governed and operated by eligible employees of Entergy and is comprised of
four local committees representing ENPAC members in each jurisdiction. Each committee
has a local board or steering committee responsible for reviewing and approving state and local
political contribution requests. The federal committee reviews and recommends federal
political contribution requests. ENPAC contributions go directly to support political
candidates and political associations or organizations at both the state and federal levels.

**Lobbying Activities**

Because Entergy, its customers and stakeholders are directly affected by legislation and/or
regulatory policies that are advanced at all levels of government, we actively participate in the
debate as laws and regulations are developed.

- Corporate Governance

We engage in lobbying activities at the federal and state level and have policies and procedures
in place to ensure that we conform to any and all applicable laws and regulations pertaining to
lobbying activities, as well as our commitment to act with integrity in all of our activities.

- Lobbying

We employ registered lobbyists, both federal and state, to support our legislative and regulatory
activities. Our internal lobbyists are selected after thorough review and with the approval of the
senior governmental affairs officer at the appropriate entity.

To assist us with our advocacy and policy analysis work, we engage external lobbyists.
These lobbyists are carefully vetted and selected by the senior governmental affairs officer
in the appropriate entity. As part of their contractual agreement, external lobbyists must agree
to fully comply with all laws and regulations as they apply in the political jurisdiction where
they are engaged.

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**Disclosure Policies**

- Annual Publication of a Report on Political Contributions

Entergy complies fully with all federal, state, and local laws and reporting requirements
governing ENPAC and corporate political contributions. We also publish, and make available
to our stakeholders, an annual report, which includes:

1. Information about Entergy's political contributions to candidates for election to
political office, political parties, political committees and political entities organized
under Section 527 and 501(c)(4) of the Internal Revenue Code;
2. The dollar amounts of the portion of more than de minimis annual dues or payments made
by Entergy to trade associations that are not deductible under Section 162(e)(1) of the
Internal Revenue Code; and
3. Disclosure of Entergy's sponsorship of ENPAC and the purpose, governance
mechanisms and that information about ENPAC's activities can be found on the Federal
Elections Commission website.

- Federal and State Lobbying Activity

Entergy, its subsidiaries and lobbyists are required to file lobbying reports with the Congress
and appropriate state agencies. These reports include information about the issues lobbied,
agencies contacted and expenditures incurred. At the federal level lobby reports can be
reviewed at [www.house.gov](http://www.house.gov/) for the US House of Representatives, and at [www.senate.gov for](http://www.senate.gov/)
the US Senate. State reports are available on the appropriate state agency website.

**Board Oversight**

Entergy's Board of Directors plays an important role in our public policy engagement and political
participation. The Corporate Governance Committee of the Board is apprised of public policy
issues that may potentially affect the reputation of Entergy and the utility industry and is responsible for
ensuring alignment of the company's policy advocacy efforts with Entergy's policies and values. At
least annually, our Corporate Governance Committee reviews the report on our political contributions
before it is published and receives an update on our lobbying activities.

https://cdn.entergy.com/userfiles/content/investor_relations/pdfs/PublicPolicy-Advocacy-Policy.pdf

Entergy's Board has adopted a Public Policy and Advocacy Policy that outline our principles governing political and lobbying activities, including our policy prohibiting corporate contributions directly to federal, state, or local candidates. Annually, we publish an Advocacy and Political Contributions Report listing our contributions to political and social welfare organizations and the portion of dues paid to trade associations that are used for lobbying activities where dues equal or exceed $50,000. The report also explains where detailed information concerning our lobbying activities, as well as the activities of our employee political action committees, may be found. See our [Corporate Governance webpage for these documents.](https://www.entergy.com/investor_relations/corporate_governance/) [...] Entergy's Board of Directors plays an important role in our public policy engagement and political participation. The Corporate Governance Committee of the Board is apprised of key public policy issues that may affect Entergy's business and is responsible for ensuring alignment of the company's policy advocacy efforts with Entergy's policies and values. At least annually, our Corporate Governance Committee reviews the report on our political contributions and payments to trade associations that use a portion of the dues for lobbying activity before it is published and receives an update on our lobbying activities. [...] Within Entergy management, the company's federal lobbying activities are overseen by Entergy's Senior Vice President — Federal Policy, Regulatory and Governmental Affairs, who also approves the participation or the engagement of individuals and/or entities that perform any federal lobbying activities on our behalf. At the state and local level, these activities must be approved by the applicable subsidiary's vice president of external or governmental affairs. All lobbyists engaged by Entergy are carefully vetted and selected by the senior governmental affairs officer in the appropriate entity. As part of their contractual agreement, external lobbyists also must agree to fully comply with all laws and regulations as they apply in the political jurisdiction where they are engaged.

https://cdn.entergy.com/userfiles/content/investor_relations/pdfs/Climate-Policy-Priorities-Advocacy.pdf

The board leverages the expertise of its committees to review specific risks within their respective areas of responsibility, and committee meetings are scheduled to allow all board members to participate in these discussions. The board's corporate governance committee has responsibility for oversight of the company's overall sustainability program and strategy and environmental, social and governance reporting. This responsibility is met, in the first instance, by assuring that recognized sustainability risks are being addressed by the full board or an appropriate board committee. Additionally, our audit committee receives annual reports from our sustainability and environmental policy group on Entergy's greenhouse gas reduction progress and other climate-related activities. Table 5 below provides information on sustainability oversight by all of Entergy's board committees. [...] Corporate Overall corporate sustainability strategy and policies, including with respect to climate change and corporate governance social responsibility; corporate governance issues; governmental, regulatory, public policy and public relations matters; public advocacy activities, including memberships in trade associations that engage in lobbying activities; shareholder concerns [...] Audit Environmental compliance and auditing; Ethics and compliance; market and credit risks; cybersecurity risks; vendor and supply chain risks; financial reporting processes and risks; other strategic risks and general risk oversight [...] Personnel Executive compensation policy and incentive plan design; employee and human resource issues; employee training and development; talent management; employee and contractor safety; organizational health; diversity, inclusion and belonging, and supplier diversity.

https://cdn.entergy.com/userfiles/content/environment/docs/2022-Climate.pdf

Entergy's Board of Directors plays an important role in our public policy engagement and political participation. The Corporate Governance Committee of the Board is apprised of key public policy issues that may affect Entergy's business and is responsible for ensuring alignment of the company's policy advocacy efforts with Entergy's policies and values. At least annually, our Corporate Governance Committee reviews the report on our political contributions and payments to trade associations that use a portion of the dues for lobbying activity before it is published and receives an update on our lobbying activities. Within Entergy management, the company's federal lobbying activities are overseen by Entergy's Senior Vice President — Federal Policy, Regulatory and Governmental Affairs, who also approves the participation or the engagement of individuals and/or entities that perform any federal lobbying activities on our behalf. At the state and local level, these activities must be approved by the applicable subsidiary's vice president of external or governmental affairs. All lobbyists engaged by Entergy are carefully vetted and selected by the senior governmental affairs officer in the appropriate entity. As part of their contractual agreement, external lobbyists also must agree to fully comply with all laws and regulations as they apply in the political jurisdiction where they are engaged.

https://cdn.entergy.com/userfiles/content/environment/docs/2023-CDP-Climate.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Entergy's Board of Directors plays an important role in our public policy engagement and political participation. The Corporate Governance Committee of the Board is apprised of key public policy issues that may affect Entergy's business and is responsible for ensuring alignment of the company's policy advocacy efforts with Entergy's policies and values. At least annually, our Corporate Governance Committee reviews the report on our political contributions and payments to trade associations that use a portion of the dues for lobbying activity before it is published and receives an update on our lobbying activities.
Within Entergy management, the company's federal lobbying activities are overseen by Entergy's Senior Vice President — Federal Policy, Regulatory and Governmental Affairs, who also approves the participation or the engagement of individuals and/or entities that perform any federal lobbying activities on our behalf. At the state and local level, these activities must be approved by the applicable subsidiary's vice president of external or governmental affairs. All lobbyists engaged by Entergy are carefully vetted and selected by the senior governmental affairs officer in the appropriate entity. As part of their contractual agreement, external lobbyists also must agree to fully comply with all laws and regulations as they apply in the political jurisdiction where they are engaged.

CDP Questionnaire Response 2022