Integrity Standard - Political Activity and Community Involvement

Policy
Federal laws restrict the use of corporate funds in connection with federal elections, and there are similar laws in many states. It therefore is the policy of the Company that neither Company name, the Company funds, nor Company facilities shall be used directly or indirectly for political purposes on behalf of candidates for political office, political parties or elected incumbent office holders at any level, federal, state or local, except as permitted by law and the Company’s Political Activity Policy. The Company will not reimburse employees for contributions to political candidates or causes.

The Company is committed to playing a leadership role in fulfilling our social responsibility. Our efforts to meet our obligations will vary from location to location. The Company’s local presence and commitment will be coordinated at the corporate level and shaped by local needs and opportunities. Employees are encouraged to participate in community programs.

Employees are encouraged to vote and participate fully in the political process. However, except as permitted by Company policy, we cannot use Company resources to vote and be active in political activities. Employee participation in non-corporate political activity is strongly encouraged, but must be done on our own time and at our own expense. The Company complies with the requirements of all applicable laws entitling employees to excused “time off” for voting.

Nothing in this Standard prohibits eligible salaried employees from voluntarily participating in the Company’s Political Action Committee (PAC) activities nor does it prohibit the Company from bearing the administrative expense of establishing and operating federal or state Political Action Committees (PACs) in conformance with Company policy and with applicable federal and/or state legal requirements.

The Company's management may, from time to time, distribute memos or sponsor activities to bring political and public policy issues to the attention of employees. These activities may include participation by public officials or candidates for public office. Any such activities by the Company shall be for the purpose of encouraging employee participation in the public policy dialogue and shall not constitute endorsement of any particular candidate, officeholder or political party. Equal opportunity will be afforded all rival candidates and political parties.