Political Activities

The Company encourages its employees to become informed voters and participate in the political process. However, participation is entirely voluntary, and must be done on personal time. Employees may not engage in any conduct which gives the appearance that the Company is endorsing a particular candidate or party for political office (i.e., employees must make it clear that they are speaking and acting for themselves, and not on behalf of the Company).

The Company will comply with any applicable state and local laws that require the Company to provide employees with time off from work to vote.

Practical Guidance

• Contributions of Company funds, property, or services to political candidates, parties, or committees are not allowed without the express approval of the Legal Department.

• Employees may not pressure or solicit other employees to make political contributions or participate in the support of any political party or candidate.

• Cooperating with or participating in political or economic boycotts raises legal concerns and may subject you or the Company to civil and criminal penalties. Employees who wish to participate in or support a boycott must consult with the Legal Department.