Like many companies, Rockwell Collins participates in the U.S. political and regulatory process to ensure our company's interests are appropriately represented. In accordance with our Standards of Business Conduct, these activities are conducted with the highest standards of ethics and in accordance with all laws and regulations. Specific activities include:
Rockwell Collins Employee Political Action Committee
The Rockwell Collins Employee Political Action Committee (EPAC) is a voluntary, nonpartisan association of eligible Rockwell Collins employees that contributes to candidates for federal or state office who support Rockwell Collins' public policy objectives. The EPAC is governed by an advisory council comprised of senior management from across the company. The president of the EPAC is our company's Senior Vice President, Washington Operations.
The EPAC is regulated by the Federal Elections Committee (FEC) and contribution information may be found by searching for the Rockwell Collins Employee Political Action Committee (formerly the Rockwell Collins Good Government Committee) on the FEC website, www.fec.gov.
Rockwell Collins joins trade associations to share with other companies our business experiences and expertise and to also be part of the broader and important public education regarding major issues of concern to our company and to the aerospace and defense industry.
A portion of the membership dues of some of these trade associations may be non-deductible under the Internal Revenue Code because the association participates in lobbying or is involved in political campaigns. The following are the trade associations to which Rockwell Collins paid dues in excess of $50,000 last year, part of which was non-deductible: U.S. Chamber of Commerce, Aerospace Industries Association, The Business Roundtable and General Aviation Manufacturing Association.
Corporate Political Expenditures
It is the general policy of Rockwell Collins to not make direct or indirect corporate political contributions to state and local candidates or organizations operated in accordance with Internal Revenue Code section 527 (e.g., political action committees). It is the company's policy to also not make independent corporate expenditures for independent communications to the general public that expressly advocate the election or defeat of a clearly identified federal candidate or that are intended to influence the outcome of a ballot measure. No such corporate section 527 contributions or independent corporate expenditures were made in the previous calendar year. If such company contributions or expenditures were to be made, they would be made solely to promote the company's interests and without regard to the private political preferences of any company officer. The company will continue to monitor these areas for legislative, judicial or regulatory changes and will review its position on such expenditures periodically. Any such expenditure will be made in accordance with all laws and regulations and will be consistent with our standards of business conduct.
Federal lobbying activities are regulated by the Lobbying Disclosure Act (LDA). In full compliance with the LDA, Rockwell Collins' lobbying activities and expenses are disclosed to the U.S. Congress on a quarterly basis. These reports are publicly available at the U.S. House of Representatives Office of the Clerk website, clerk.house.gov.
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