Political Contributions and Lobbying
Issues arise in the political process at federal, state and local levels that directly affect Oxy's business and stakeholders. Because legislative and regulatory changes can have substantial impacts on the company and its stakeholders, Oxy believes that it is necessary for the company to help inform the discussion of such issues and to do so in an ethical and transparent manner. To that end, Oxy may, from time to time, make political campaign contributions or engage in lobbying and other political activities. While the expenditures for these areas vary from year to year depending on the political cycle and the legislative or regulatory issues in the forefront, we believe that they are modest for a company of Oxy's size. With respect to political contributions, such contributions will only promote the interests of the company, and not the personal political preferences of its executive officers or directors. We always have a process in place to ensure that these activities and expenditures comply with all applicable laws and company policies, including those summarized in Oxy's Code of Business Conduct. Oxy conducts periodic trainings and internal audits to ensure all PAC and corporate political contributions are made in accordance with the law and company policies.
Oxy's written policy on political activities broadly defines what a political contribution is for the purposes of the policy. It covers campaign contributions and other politically related expenses by or on behalf of Oxy, and they are made only with the approval of the Board of Directors, the Government Affairs Committee or their designees. The Government Affairs Committee approves all political contributions and reports directly to the Board of Directors. The Vice President, Government Relations is the current chairperson of the Government Affairs Committee, and the other members of the Government Affairs Committee are: the Senior Vice President and Chief Financial Officer; the Vice President, Land, Regulatory, Governmental Relations and Corporate Affairs; and the President of Oxy Energy Services.
Political Campaign Contributions
Under federal election law, Oxy may not contribute corporate funds directly to federal candidates or political parties. Oxy is authorized to establish and fund the administrative expenses of an employee political action committee (PAC). Oxy currently has one authorized PAC — the Oxy Petroleum Corporation Political Action Committee (OXYPAC).
Funded entirely by employees' personal, voluntary contributions, OXYPAC contributes to qualified federal, state and local candidates and multicandidate committees, regardless of party affiliation, who share the interests of Oxy. OXYPAC's activities are transparent and comply with applicable laws.
Information on federal and state political campaign contributions made by OXYPAC is filed with the Federal Election Commission (FEC) as well as various state agencies. OXYPAC's FEC filings may be viewed on the FEC website. However, to simplify access to such information, Oxy annually posts a list of OXYPAC contributions, categorized by jurisdiction, candidate and amount for the most recently ended fiscal year.
Oxy's Political Contributions Archive presents a list of non-OXYPAC political campaign contributions made by Oxy and its subsidiaries during a fiscal year, including any contributions with respect to ballot initiatives. All of the foregoing contributions and expenditures are subject to the same review and approval procedures described above, and all comply with applicable disclosure requirements. Oxy's policy is to include in its website all contributions that are subject to disclosure requirements. Historic reports of these OXYPAC and non-OXYPAC contributions are available in the Political Contributions Archive.
Oxy's Government Relations group provides the international and domestic government affairs services for Oxy and, in that capacity, is responsible for all federal and state political contacts by Oxy. Government Relations' mission is to provide advice, advocacy, information, policy analysis and support on legislative, regulatory, international and political issues of importance to the company in meeting its operational and financial goals. These issues and their relative priority change from time to time. However, the specific federal issues that Oxy engaged in lobbying during the last calendar quarter are listed in the quarterly lobbying reports filed with the U.S. Congress. Information about Oxy's state lobbying is available in periodic filings made with various states. Certain foreign countries, the federal government, each state, and certain local jurisdictions have laws requiring registration and reporting by lobbyists and sometimes by their employers. Oxy reports its federal lobbying to the U.S. Congress in public, quarterly lobby disclosure reports that can be viewed online via the U.S. Senate's Lobbying Disclosure Electronic Filing System website. These reports include Oxy's direct lobbying expenses (e.g., salaries, office rent, etc.), as well as the portion of the dues paid to trade associations that is used for lobbying purposes. As noted above, the reports also list in detail the issues on which Oxy engaged in lobbying.
Trade Associations and Industry Groups
Oxy is a member of and an active participant in many trade and industry groups. Membership in these groups is necessary to stay abreast of issues impacting Oxy's business segments. While generally not the primary purpose of these organizations, many actively engage in lobbying on industry issues. These organizations represent a broad range of members and interests, and Oxy does not always share the views of these organizations and their other members. At the direction of the Board of Directors, the Government Affairs Committee reviews, assesses and approves of Oxy's membership in such trade associations.
Oxy annually provides a list of U.S. Trade Associations of which Oxy is a member and to which it paid annual dues in excess of $50,000. The federal issues on which such associations or groups engaged in lobbying are included in the lobbying disclosure forms filed by such organizations, which are available via the U.S. Senate's Lobbying Disclosure Electronic Filing System.
Personal and Grassroots Activities
Oxy encourages its Directors and employees to participate in the political process by voting, volunteering their personal services on their own time and by making personal political contributions. However, Directors and employees are not reimbursed or compensated by Oxy for any political contribution.