At Boeing, oversight of political activities starts at the top. The Board of Directors directly appoints the Company’s top government affairs leader—known as the Executive Vice President (EVP) of Government Operations—and works closely with him on its oversight of our engagement in the political process. This oversight includes regular discussions with the EVP of Government Operations about the Company’s public policy priorities, the Company’s memberships in and payments to trade associations and other tax-exempt organizations, Boeing Political Action Committee (BPAC) strategy and expenditures, and the Company’s network of compliance procedures related to these activities. The Board’s Governance & Public Policy (GPP) Committee, comprised entirely of outside directors, leads the Board’s oversight activities with respect to and makes appropriate recommendations to the full Board about Boeing’s engagement in the political process. This oversight role by the GPP Committee is hardwired into the Committee’s governing charter, which can be found here. Together, the Board and the GPP Committee are committed to ensuring that our political activities align with the Company’s values, business strategies, and long-term shareholder interests.
The EVP of Government Operations also works closely with the Law and Global Compliance organization to ensure that the Company’s political activities adhere to all legal requirements and company policies and procedures, meet the highest ethical standards, and align with shareholder interests and Boeing’s values. Each year, the Company’s Compliance Risk Management and Enterprise Risk Visibility boards provide the Board of Directors with an update and overview of the effectiveness of the policies and procedures in place to ensure that the Company’s political activities meet these high standards. The Board also ensures that the Company’s political advocacy efforts are consistent with our long-term strategic imperatives. You can review the Company’s oversight and internal compliance procedures for political activities here.
Company Political Contribution Guidelines
Boeing policy prohibits the use of corporate funds or assets to support federal, state, or local political candidates, ballot initiatives, political parties, or section 527 entities. Boeing does not contribute corporate funds to Super PACs or use such funds for electioneering communications or independent expenditures.
Boeing policy also prohibits contributions to non-U.S. political candidates, parties, party officials, and/or advocacy groups. Finally, Boeing prohibits outside organizations, such as trade associations, from using Boeing's funds for any election-related political expenditure, and Boeing requires written assurance from these organizations of their adherence to this policy.
The Boeing Political Action Committee
BPAC is the sole method Boeing uses to make political contributions. BPAC is not funded by corporate dollars. Instead, BPAC is funded solely from the voluntary, personal contributions from its members, who are primarily Boeing employees and retirees.
BPAC may direct contributions to federal campaigns, as well as to state and local campaigns, ballot initiatives, political action committees, and political parties. BPAC conducts this work under the supervision of a 12-member BPAC Advisory Board comprised of senior leaders from the Company, including the EVP of Government Operations. All BPAC contributions are made on a nonpartisan basis and in accordance with objective criteria established by the Advisory Board and the EVP of Government Operations in compliance with applicable laws and regulations. Contributions are made 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, as well as a candidate’s integrity, character, and commitment to good government. Authority to approve BPAC contributions has been delegated to the BPAC treasurer. Before each two-year federal election cycle, BPAC prepares a budget of contributions that specifies proposed candidates to whom BPAC will be contributing and rationale. This budget is reviewed on a bi-annual basis after its initial approval, and BPAC also tracks and oversees all involvement with candidate fundraising events. Government Operations senior leaders meet on a bi-weekly basis with Boeing’s Law Department to review contribution requests and approve BPAC contributions. For state and local political contributions, a similar review and oversight process occurs annually. Under the supervision of Boeing’s Law Department, BPAC regularly undergoes audits by an outside law firm and independent auditor. The EVP of Government Operations reviews BPAC’s budget and activity with the Company's Board of Directors annually.
You can find a full list of all candidates and committees to which BPAC has contributed here.
Public Policy in Action
The EVP of Government Operations also must approve all Company political advocacy, including when we advocate that the public contact their elected representatives directly about important public policy issues. Boeing ensures that all such advocacy efforts are conducted in accordance with applicable law, policies and procedures, sound corporate practice, integrity, and our high standards of ethical conduct, and enable us to advance our priorities in a way that supports Boeing values.
Boeing complies with the requirements of the Lobbying Disclosure Act and the Byrd Amendment, as well as all state requirements. The EVP of Government Operations, working closely with the Law and Global Compliance organization, has put in place a comprehensive lobbying compliance program, including complete and timely lobbying registration and reporting.
You can find a full list of all federal lobbyists who have worked for Boeing and the issues on which they lobbied here and here.
You can find similar information for state-level lobbying here [WA, CA, TX, MO, and FL].
Trade Association Engagement
Boeing believes that executing on our long-term strategy includes actively engaging and sharing our viewpoints on public policy matters with industry and other associations. Government Operations closely monitors each of these 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. Government Operations leaders review all expenditures with the Company’s principal trade associations and other public policy groups at least annually with the Board’s GPP Committee to ensure alignment to our long-term strategy and monitor consistency with our interests and values. The Board also reviews all payments to trade associations and tax-exempt groups. This includes ensuring that the public and non-public positions taken by third-parties on issues such as climate change align with the Company’s public positions. In cases where our stated policy positions differ from those advocated by an organization that we support, the GPP Committee, together with the EVP of Government Operations, ensures that we engage constructively with that organization and, if necessary, reduce or withdraw our support.
You can find a listing of the major trade associations Boeing supports here, along with information about the portion of dues that each association uses for lobbying purposes.