Effective Date: June 7, 2019
Lowe’s Companies, Inc. (“Lowe’s”) engages with federal, state and local government officials through outreach and lobbying activities regarding issues that matter to the retail industry, our company, customers and shareholders. Lowe’s adheres to our Code of Business Conduct and Ethics when participating in the political process and interacting with public officials. This Policy sets forth basic principles concerning political contributions, trade associations and lobbying activities, and it applies to Lowe’s and its associates.
Governance and Oversight
The Nominating and Corporate Governance Committee (the “Committee”) of the Lowe’s Board of Directors, comprised entirely of independent directors, has oversight of Lowe’s government relations activities in connection with its political contributions, trade association memberships, lobbying activities and Lowe’s Companies, Inc. Political Action Committee (“LOWPAC”). At least annually, we provide the Committee with an itemization of LOWPAC contributions and lobbying expenditures and information regarding our memberships with and payments to trade associations.
The Vice President of Government Affairs manages our political and government affairs programs and has responsibility for ensuring that all Lowe’s legislative and regulatory practices are in compliance with U.S. federal and state laws, regulations and reporting requirements.
Lowe’s does not make contributions from corporate funds to political campaigns, super political action committees or political parties. Additionally, Lowe’s does not make independent expenditures or contributions to other political entities organized under Section 527 of the Internal Revenue Code or to special interest groups organized under Section 501(c)(4) of the Internal Revenue Code to support political activities.
Lowe’s maintains memberships in national and state trade associations specific to business and retail industry interests. We may not always support every position taken by these associations or their other members; however, these associations provide significant benefits to Lowe’s by providing access to their business, technical and industry expertise. They host forums for their members and lobby on behalf of members on various public issues and policies that impact our company and ability to conduct business.
These associations are not expected to use the financial support that Lowe’s provides for campaign contributions or to influence the outcome of specific elections or ballot initiatives.
Lowe’s may provide information, analysis and opinions to legislators and government leaders to help them better understand the industry and make informed decisions. These decisions could affect the retail industry, our company, customers and shareholders. Lowe’s abides with applicable U.S. federal, state and local laws when we engage in lobbying activities.
Political Action Committee
Lowe’s is affiliated with LOWPAC, an employee political action committee, that supports candidates and other political committees supportive of Lowe’s business interests. LOWPAC is funded by voluntary employee contributions. The determination of a political contribution is made by LOWPAC’s board of directors, which consists of the Vice President of Government Affairs and other members of the senior leadership team spanning corporate and operational roles. The personal political views or affiliations of any Lowe’s director, officer or associate are not considered when determining contributions. All LOWPAC contributions are reviewed and approved in advance by the Vice President of Government Affairs and, when necessary, the General Counsel. Lowe’s provides administration support to LOWPAC, as permitted under applicable law.
Compliance and Disclosure
Lowe’s is fully committed to complying with all applicable U.S. federal, state and local laws regarding interactions with public officials, political contributions and expenditures, including reporting and disclosing the following activities:
- To the extent that Lowe’s makes any contributions from corporate funds to support ballot measures that are consistent with Lowe’s business interests and public policy agenda, Lowe’s will disclose those amounts publicly, on an annual basis.
- A list of the trade associations to which Lowe’s paid dues in the past calendar year and the percentage of Lowe’s annual dues that are attributable to lobbying expenses can be found at http://www.loweslink.com/llmain/Trade_Associations.htm.
- Reports of lobbying activities will be filed at the websites of the U.S. House (http://lobbyingdisclosure.house.gov) and the U.S. Senate (https://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm). Reports of lobby activities at state level are filed with the applicable state government offices and are publicly available.
- The Federal Election Commission (“FEC”) regulates the disclosure of the contributions to be raised and spent by LOWPAC. Reports filed by LOWPAC are available on the FEC website at http://www.fec.gov.
If you need more information, please contact Lowe’s Government Affairs at 704-758-1000. If you are aware of any violation of this Policy, please contact your manager, the Compliance Department at email@example.com or call the Lowe’s EthicsPoint hotline at 1-800-784-9592.