Certain states and localities permit corporate contributions to candidates and political parties. It is the policy of the Boeing Company to make political contributions in such states and localities when the Company determines such 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, state or local ballot initiatives in which the Company has a substantial interest. Since 2010, the Company has not made any contributions from corporate funds to state or local candidates or political parties. Also, Boeing has not expended any corporate funds since 2011 in support of or opposition to ballot initiatives, or since 2012 for political contributions to section 527 entities. Boeing also has not contributed and does not contribute corporate funds to Super PACs, or for electioneering communications or independent expenditures. Corporate contributions to federal candidates are prohibited by federal law, and Boeing accordingly makes no such contributions.
Furthermore, it is Boeing's practice and policy to prohibit outside organizations such as trade associations 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 order to prevent the use by such groups of Boeing's corporate funds for election-related political purposes. Moreover, Boeing regularly reviews each of its outside affiliations, including a review of any advocacy undertaken by such third-party groups, to ensure continued overall alignment with Boeing’s interests and business strategy. Any continued support for such organizations must be approved by the Executive Vice President, Government Operations, on at least an annual basis.
Boeing uses corporate resources in order to support Boeing’s viewpoint on important public policy issues, including expenditures for external entities who advocate on Boeing’s behalf. Any such advocacy requires the prior approval of Boeing’s Executive Vice President, Government Operations, is overseen and managed by Boeing’s Government Operations organization, and is conducted in accordance with applicable law, sound corporate practice, and our high standards of ethical conduct. Boeing files lobbying disclosure reports with the United States Congress, which are available here and here. Boeing files similar reports where required at the state level. Lobbying activities are defined and tracked internally. As outlined in the Company's internal procedure on Lobbying and Byrd Amendment Activities, Boeing complies with federal regulations as outlined in, but not limited to, the Lobbying Disclosure Act (LDA) and the Byrd Amendment. Data and reporting required by the Lobbying Disclosure Act (LDA) are disclosed and available publically on the LDA Report homepage. Training is provided to employees on these requirements as well as responsible behaviors. In addition, Boeing’s Executive Vice President, Government Operations, reports regularly to Boeing’s Board of Directors on the Company’s lobbying and other advocacy activities.
If the Company were at some point in the future to resume the use of corporate funds for state and local political contributions, it would employ a rigorous review and approval process to ensure that the expenditures are in the best interests of the Company and its shareholders. The Company's process for approving corporate political contributions in state and local elections and ballot initiatives requires the Board of Directors to authorize a budget for such contributions. Such contributions would be made within that budget, in compliance with applicable laws and regulations, and in accordance with the specific authority granted by the Board of Directors, including any delegations to the Chief Executive Officer and/or the Executive 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 law firm before being presented to the Executive Vice President, Government Operations for review and approval. Any corporate political contributions would be made without regard to party affiliation and solely on the basis of a candidate’s policy positions on business issues of importance to the aerospace industry and to the Company and its shareholders. Any corporate political contributions are disclosed on this website on an annual basis.
The 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 executives and is 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 may direct contributions to the campaigns of candidates seeking federal offices, as well as selected state and local campaigns, ballot initiatives, and section 527 entities where such contributions are allowed. BPAC makes contributions under the supervision of the Executive 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, National Strategy and Engagement). BPAC contributions are made without regard to party affiliation and solely on the basis of a candidate’s policy positions on business issues of importance to the aerospace industry and to the Company and its shareholders. The Executive Vice President, Government Operations, reviews BPAC’s budget and activity with the BPAC Advisory Committee semi-annually and with the Company's Board of Directors annually.