Home Depot Inc/The

Oversight of Our Political Activity

Our Government Relations department, led by a vice president who reports to our general counsel, manages our political activity. The team carefully analyzes our engagement activities, trade association partnerships and political contributions, keeping in mind our key priorities and our core values. All of The Home Depot's political contributions are made to promote the interests of the company and without regard for the private political preferences of executives or directors. The Government Relations team is responsible for ensuring all PAC and corporate political contributions are made in accordance with the law and company policies. The team participates in regular trainings and performs routine reviews to monitor compliance.

[The Nominating and Corporate Governance Committee of our Board of Directors](https://ir.homedepot.com/corporate-governance/committee-charters/nominating-and-corporate-governance) provides additional oversight, conducting an annual review of our Political Activity and Government Relations Policy, the company's political contributions and payments to trade associations that engage in lobbying activities.

The Nominating & Corporate Governance Committee must approve in advance any public advertisement directly or indirectly paid for by the Company that expressly advocates the election or defeat of a candidate in which Home Depot is identified specifically as an advocate of such election or defeat. To date, the company has not made any expenditure for such electioneering communications, and has no present plans to make any such expenditures.

The Home Depot PAC's finances, governance and communications are governed by a PAC Board. The PAC Board is chaired by the vice president of Government Relations and is made up of representatives from each functional area of the business and each field division to ensure a wide range of experiences and perspectives.

We provide transparency in our actions by publishing annual reports of the company's political contributions and the aggregate dues paid to trade associations that engage in lobbying activities. We list trade associations to which our company makes yearly payments of $5,000 or more, and our PAC contributions are publicly available on the Federal Election Commission website.

Our Government Relations team carefully analyzes our engagement activities, trade association partnerships, and political contributions, guided by our top priorities and our eight Core Values. Our political donations are made to promote The Home Depot's interests, not based on the private political preferences of our executives or directors. We may not agree with every position taken by a candidate, elected official, or trade association we support, and a contribution to any individual or organization should not be taken to mean agreement with every position taken by that individual or group. However, we use several business-focused criteria and our Core Values to make decisions that will allow us to have a seat at the table to engage, both on the issues on which we align and those on which we disagree, to support our business, associates and communities. [...] Our Government Relations team, led by a vice president who reports to our General Counsel, manages our political activity. The team carefully analyzes our engagement activities, trade association partnerships, and political contributions for alignment with our key priorities, guided by our Core Values. The Government Relations team is responsible for ensuring all PAC and corporate political contributions are made in accordance with the law and Company policies. The team participates in regular trainings and performs routine reviews to monitor compliance. [...] The NCG Committee of our Board of Directors provides additional oversight, conducting an annual review of our Political Activity and Government Relations Policy, the Company's political contributions, payments to trade associations that engage in lobbying activities, and the Company's support of ballot initiatives. The NCG Committee must approve in advance any public advertisement directly or indirectly paid for by the Company that expressly advocates the election or defeat of a candidate in which The Home Depot is identified specifically as an advocate of such election or defeat. To date, the Company has not made any expenditure for such electioneering communications, and has no present plans to make any such expenditures.

###### GOVERNMENT RELATIONS

standing practice, we do not contribute
to presidential campaigns or endorse
presidential candidates.

- The Home Depot supports trade
associations that advocate on behalf of
the business community and retail sector
and reports annually the aggregate dues
paid to those associations that engage in
lobbying activities.

In deciding where we want to focus our
advocacy, these are some of our top
priorities:

- Driving sales by ensuring online-only
marketplaces follow the same rules
on accountability and transparency as
interconnected retailers

- Supporting our One Supply Chain
initiative by advocating for funding for
roads, ports and bridges and for laws
that allow safer, heavier trucks to reduce
loads and our environmental footprint

###### The Home Depot recognizes that laws at the federal, state and local level impact our business.

We actively participate, and encourage
our associates to participate, in the
[political process. Our Political Activity](https://ir.homedepot.com/~/media/Files/H/HomeDepot-IR/2020/political-activity-and-government-relations-policy_2019.pdf)
**[and Government Relations Policy](https://ir.homedepot.com/~/media/Files/H/HomeDepot-IR/2020/political-activity-and-government-relations-policy_2019.pdf)**
provides the framework for our political
activity. We engage in three key ways:

- Our Government Relations department
protects and expands our company's
ability to take care of our associates,
customers and shareholders
through effective regulatory and
legislative action. Our Government
Relations team works to optimize the
government's impact on the business
through effective lobbying, relationship
building and political engagement.

- We have a political action committee
(PAC) that connects our salaried
associates to the political process
and pools their personal contributions
to financially support pro-business
candidates who understand issues
of importance to The Home Depot
and our associates. As a long

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Protecting margins by working to get
laws passed that target sophisticated,
organized retail crime rings to reduce theft
and support free trade

- Taking care of our people by making sure
we have a say in laws that could affect
associate flexibility and career growth

###### Oversight of Our Political Activity

Our Government Relations department, led
by a vice president who reports to our general
counsel, manages our political activity. The
team carefully analyzes our engagement
activities, trade association partnerships
and political contributions, keeping in mind
[our key priorities. The Nominating and](https://ir.homedepot.com/corporate-governance/committee-charters/nominating-and-corporate-governance)
**[Corporate Governance Committee of](https://ir.homedepot.com/corporate-governance/committee-charters/nominating-and-corporate-governance)**
our Board of Directors provides additional
oversight, conducting an annual review of
the company's political contributions and
payments to trade associations that engage
in lobbying activities.

The Home Depot PAC's finances, governance
and communications are governed by a
PAC Board. The PAC Board is chaired by
the vice president of Government Relations
and is made up of representatives from
each functional area of the business and
each field division to ensure a wide range of
experiences and perspectives.

We provide transparency in our actions by
publishing annual reports of the company's
**[political contributions and the aggregate](https://ir.homedepot.com/~/media/Files/H/HomeDepot-IR/2020/Final%202019%20Political%20Corporate%20Contributions_3620)**
**[dues paid to trade associations that](https://ir.homedepot.com/~/media/Files/H/HomeDepot-IR/2020/Final%20Trade%20Association%202019%20Membership%20Report_3620)**
engage in lobbying activities. We list trade
associations to which our company makes
yearly payments of $5,000 or more, and our
PAC contributions are publicly available on
[the Federal Election Commission website.](https://www.fec.gov/)

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]The Home Depot engages with policymakers regarding business-relevant legislation, regulations, and initiatives. This engagement is both direct and indirect, via trade associations and coalitions. When engaging on matters related to climate, the Government Relations department reviews policies for alignment with the Company's climate strategy.

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?[…]The Home Depot engages with policymakers regarding business-relevant legislation, regulations, and initiatives. When engaging on matters related to climate, the Government Relations department reviews policies for alignment with the Company's climate strategy.