In 2012, Boeing did not expend any corporate funds for political contributions to federal, state, or local candidates or to section 527 entities or Super PACs, or for electioneering communications or independent expenditures. In addition, Boeing's policy is to prohibit trade associations and other third-party organizations from using Boeing's membership dues and other contributed funds for any election-related political expenditure.
2012 political expenditures by The Boeing Company Political Action Committee (BPAC), a voluntary, nonpartisan political action committee established by The Boeing Company in accordance with federal law, are set forth here. BPAC is governed by an Advisory Committee comprised of Company employees and funded solely from the voluntary personal contributions it receives from its members, who are employees of the Company eligible to be solicited for and to make contributions under federal election law. BPAC provides direct contributions to the campaigns of candidates seeking federal offices, as well as selected state campaigns where such contributions are allowed. BPAC makes contributions under the supervision of the Senior Vice President, Government Operations in compliance with applicable laws and regulations. Authority to approve BPAC contributions has been delegated to the BPAC Treasurer (Vice President, Strategy & Advocacy). BPAC contributions are made on a nonpartisan basis in support of candidates who support business issues of importance to the Company and its shareholders. The Senior Vice President, Government Operations reviews BPAC spending with the Company's Board of Directors annually.
The Company does not make contributions that are prohibited by law, such as corporate contributions to candidates for federal office or to national political party committees, or contributions to candidates for state or local office in states or localities where corporate contributions are prohibited.
Certain states and localities permit corporate contributions to candidates and political parties. It is the policy of the Company to make political contributions in such states and localities when the Company determines contributions to be in the best interests of the Company and its shareholders. The Company also may make contributions in support of, or in opposition to, specific ballot issues in which the Company has a substantial interest. In 2012, the Company did not make any contributions from corporate funds to state or local candidates or political parties or ballot initiatives.
The Company's process for approving corporate political contributions in state and local elections and ballot initiatives is as follows. First, the Board of Directors would authorize a budget for such contributions, and any such contributions would be made within that budget and in compliance with applicable laws and regulations. Authority to approve any such contributions has been delegated by the Board of Directors to the Chief Executive Officer who, in turn, has delegated authority to approve specific contributions within the established budgets to the Senior Vice President, Government Operations. Any corporate political contributions would be recommended by the Government Operations organization and reviewed for compliance by the Vice President and Assistant General Counsel, Government Operations and an outside firm before being presented to the Senior Vice President, Government Operations. Any direct contributions would be made on a nonpartisan basis in support of candidates and committees who support business issues of importance to the Company and its shareholders. Any corporate political contributions shall be disclosed on this website on at least a semi-annual basis.
As noted above, it is Boeing's policy to prohibit trade associations and other third-party organizations from using Boeing's funds for any election-related political expenditure. Boeing has requested and received written assurance of adherence to that policy by its largest trade associations. Boeing continues to communicate its policy to other groups with which it is associated, in each case to request that Boeing's corporate funds are not used by such groups for election-related political purposes.