Eastman Chemical Co

Lobbying Governance

AI Extracted Evidence Snippet Source

Eastman is committed to complying with all applicable laws relating to lobbying activities, including those requiring disclosure of our activities at the federal, state and local levels. The Lobbying Disclosure Act, and subsequently, the Honest Leadership and Open Government Act, established U.S. guidelines for reporting federal lobbying activity, and most states (and many municipalities) require reporting of lobbying activities (including grassroots activities) at the state and local levels. Often employers and employees who engage in lobbying must register in order to conduct lobbying activities. Moreover, external parties hired to engage in lobbying activities or make lobbying contacts must also register. Specifically, employees of Eastman's Government Affairs Department are authorized to engage in federal, state, local and foreign lobbying activities on behalf of Eastman. No other employee is authorized to approve lobbying activities on behalf of Eastman unless such approval is granted by the Government Affairs Department. Lobbying registrations and disclosures are made publicly available via U.S. government agency websites.

Eastman participates in direct advocacy on certain public policy issues that we believe are important. As part of our advocacy efforts, we participate in a number of trade organizations and industry groups representing the interests of our industry and the broader business community. While Eastman may not always support every position taken by these organizations or their other members, we believe our participation in these organizations is important and furthers Eastman's goals. Payments to these organizations and groups, including membership fees and dues, are not to be used for election-related activity at the federal, state or local levels, including contributions and expenditures for candidates, ballot initiatives, political party committees or political action committees. Eastman has no participation in or payments to organizations that develop and promote model legislation. Proposed memberships in and contributions to trade and business associations are reviewed by Eastman's Government Affairs Department and such memberships are reported annually to Eastman's Board of Directors and its Environmental, Safety and Sustainability Committee.

For its federal lobbying disclosures, Eastman receives information from its U.S. trade and business associations identifying the portion of Eastman dues and payments used by those groups for lobbying activity. The Company includes this information in the aggregate in our quarterly lobbying activity reports filed with the U.S. Congress, as required by the Lobbying Disclosure Act (LDA).

https://investors.eastman.com/governance/Political-Engagement/Lobby-and-Trade-Associations/default.aspx

**Governance**

EastmanPAC is governed and overseen by an 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. The Executive Board supervises and directs the PAC's financial and administrative affairs, including approving financials and contribution recommendations as set forth by the Government Affairs organization. Ex officio members include employees of the Government Affairs organization. The Executive Board officers include a Chairman, Treasurer and Assistant Treasurer.

**Contributions**

The Executive Board evaluates all candidates on a bipartisan basis, basing its giving decisions on a number of factors, most importantly the policy stances of individual candidates. Strong consideration is also given to those who share Eastman's corporate values and our commitment to drive positive change in our communities.

* Eastman's presence in a candidate's state/district
* Demonstrates a commitment to supporting manufacturing and the chemical industry
* Key committee member or thought leader on issues of importance to Eastman
* House and Senate Leadership
* Alignment with Eastman's public policy priorities

All proposed U.S. political contributions by EastmanPAC are first reviewed by the Eastman Government Affairs team, which makes recommendations to the Vice President of Corporate Affairs for approval and submission on an annual basis to the Executive Board. Approved EastmanPAC contributions are submitted to the EastmanPAC Treasurer and Assistant Treasurer for disbursement and are publicly disclosed to the Federal Election Commission (FEC) in monthly filings and in the Political Contributions Report.

https://investors.eastman.com/governance/Political-Engagement/EastmanPAC-Guidelines-for-Contributions/default.aspx

Eastman's chief sustainability officer chairs the company's Sustainability Council which is responsible for Eastman's overall climate change strategy. This council, which includes Eastman's Chief Legal Officer who is responsible for government affairs among other areas of the company, reviewed and approved Eastman's public commitments and position on climate change. This ensures that Eastman's engagement activities are consistent with our overall climate change strategy. [...] Eastman's current strategy for allowance trading under all emission trading schemes is to properly manage compliance obligations of facilities worldwide by pursuing operating decarbonization and efficiency improvements wherever possible to minimize compliance and financial exposure. Eastman will then purchase allowances/compliance instruments to satisfy any net compliance obligations. If allowances allocated to the company exceed the current compliance obligations, allowances are generally retained for future compliance requirements. Eastman does not trade allowances speculatively and has participated in the Clean Development Mechanism (CDM).

https://www.eastman.com/content/dam/eastman/corporate/en/media-center/resources/eastman-climate-change-cdp.pdf

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Eastman's chief sustainability officer chairs the company's Sustainability Council which is responsible for Eastman's overall climate change strategy. This council, which includes Eastman's Chief Legal Officer who is responsible for government affairs among other areas of the company, reviewed and approved Eastman's public commitments and position on climate change. This ensures that Eastman's engagement activities are consistent with our overall climate change strategy.

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?[…]Yes

CDP Questionnaire Response 2023