This policy sets forth basic principles governing PPG’s corporate political contributions and related activities, participation in supporting trade associations, and associated public reporting guidelines.
Corporate Political Contributions:
This policy requires that PPG act in accordance with all applicable state, local, and federal laws regarding corporate political contributions.
- Federal Elections: Federal law prohibits corporate political contributions to federal candidates or campaign committees. Accordingly, PPG does not make any such federal corporate contributions.
- State and Local Elections: State and local laws regarding corporate political contributions vary by jurisdiction. However, PPG does not make any corporate contributions to state or local campaigns or candidates even when permitted to do so by applicable law.
PPG does not make corporate contributions to 501(c)(4) organizations, to 527 political organizations, to support or defeat ballot initiatives, to Super PACs, or to political parties. Should a future situation warrant the use of corporate funds for one of these purposes, the contribution requires the approval of PPG’s Vice President, Corporate and Government Affairs, and will be disclosed in PPG’s voluntary disclosure of political contributions and activities referenced below. When reviewing any proposed contribution under this policy, the Vice President, Corporate and Government Affairs must consider whether the proposed contribution (a) complies with applicable laws, (b) complies with this policy, and (c) advances the interests of PPG and its shareholders.
Participation in Supporting Trade Associations:
Where permitted by applicable law, PPG may participate in supporting trade associations and industry groups representing PPG’s interests. PPG’s involvement with these organizations provides insights into important issues for our industry and the business community and to jointly advocate for public policies that support a healthy business environment for PPG. Because these trade associations represent a broad range of companies and industries, there may be instances where an association’s positions differ from those of PPG. Any trade association membership with total annual payments exceeding $50,000 must be reviewed and approved by PPG’s Vice President, Corporate and Government Affairs and will be disclosed annually in PPG’s voluntary disclosure of political contributions and activities.
Oversight and Compliance:
PPG’s fully independent Nominating and Governance Committee of the Board of Directors oversees PPG’s policies and practices regarding government affairs, public policy advocacy, and political spending and activities, which includes this policy, and receives a report regarding these matters at least annually. PPG’s Vice President, Corporate and Government Affairs is responsible for implementation of this policy and ensuring compliance with it. Any individual or employee informed of any actual or potential violations of this policy or any applicable law regarding corporate political activities is under an affirmative obligation to report the violation to their supervisor, PPG’s Vice President, Corporate and Government Affairs, PPG’s Chief Compliance Officer or the PPG Ethics Helpline.
Public Reporting and Voluntary Disclosure of Political Contributions:
PPG values transparency and accountability in its political contributions and activities. Any and all contributions made by PPG solely promote the business interests of PPG and do not reflect the political preferences of PPG’s officers, directors, or employees. PPG complies with all legally required disclosure requirements, including the Federal Election Campaign Act and Lobbying Disclosure Act. On an annual basis, PPG publishes its voluntary disclosure of political contributions and activities on its website, disclosing trade association memberships with total annual payments in excess of $50,000, contributions to 501(c)(4) organizations, and other political expenditures.
Policy effective January 11, 2022