Engagement in the Political Process
LyondellBasell (LYB) believes active participation in the political process is essential to our long-term success. LYB advances our public policy agenda through direct lobbying, involvement in various trade associations and the LYB Political Action Committee (LYB PAC). Transparency and accountability are embedded into LYB’s public policy, political spending and lobbying actions. The company maintains policies and procedures consistent with our Code of Conduct that support continued compliance with applicable political laws and regulations. Our engagement, including public policy advocacy and management of the LYB PAC, is subject to oversight by LYB’s Management Board. In addition, all PAC spending is reviewed and approved by the LYB PAC Board.
LYB generally does not make political contributions other than through the LYB PAC, which is funded voluntarily by employees. If LYB were to make a political contribution to candidate committees and other political organizations, we would do so only as allowed by applicable laws in the United States. All financial contributions strictly adhere to federal and state laws regarding contribution limits on amount and source, criteria and reporting requirements. LYB refrains from making political contributions in any country other than the United States. All political contributions are made without regard to the personal political affiliations or views of any individual LYB employee at any level across the organization.
Public Policy and Advocacy
Our advocacy activities are directed toward advancing LYB’s business interests, to foster the protection and advancement of strong petrochemical and refining industries and not the personal political preferences of our executives or employees. LYB’s strategy is grounded in safe and reliable operation of all assets. LYB supports policies promoting reasonable regulations based on sound science; fair and equitable tax policies that promote economic investment, job creation and global competitiveness; and transportation infrastructure to meet the needs of our industry. Moreover, LYB policy prohibits directors and employees from using company resources to promote their personal political views, causes or candidates, and specifies that the company will not directly or indirectly reimburse any personal political contributions or expenses.
LYB has an established practice to determine which public policy issues are important to the company. This process includes soliciting input from relevant business and functional departments. Key issues are discussed and prioritized by members of management.
In all of the company’s advocacy activities, we are committed to the highest standards in corporate responsibility, compliance and transparency. The company discloses its U.S. federal, state and local lobbying activity and expenditures as required by law.
Trade Associations and Policy Development Organizations
LYB is a member of numerous trade associations that provide a venue for the petrochemical and refining industries to lend our voices to issues that impact our industry. As a trade association member, we seek to advance collaborative and constructive approaches to industry engagement with policymakers and other stakeholders to advance sound public policy. While we may not always agree with the positions taken by an association or its members, corporate memberships enable us to voice our concerns, perspectives and positions on proposed legislation and regulations.
LYB also participates in a variety of issue advocacy coalitions and alliances that seek to advance policy proposals focused on key priorities for the petrochemical and refining industries and the company. LYB reviews these memberships annually to assess their business value and alignment with its policies and priorities. The Director of Government Relations has oversight over memberships in U.S. trade associations.
LYB makes available annually a report of dues paid to U.S.-based trade associations to which LYB contributes $50,000 or more annually.
LYB's Political Action Committee
As permitted under U.S. law, the company operates a political action committee that is registered with the U.S. Federal Election Commission. The LYB PAC is a mechanism to enable eligible U.S. employees to voluntarily support candidates for elected office who share LYB’s perspectives and approaches to public policy issues. The contributions made by the PAC are not funded by corporate funds but are fully funded by voluntary employee contributions. Contributions to LYB PAC are entirely voluntary and are governed by the LYB PAC By-Laws. LYB provides administrative support to the PAC, as permitted under federal law. The LYB PAC is governed by its Board of Directors that is made up of executive officers and senior management, including the Chief Legal Officer and the Director of Government Relations. The PAC Board of Directors supervises and directs the PAC's administration, solicitation campaigns, contributions, and compliance with applicable law and LYB PAC’s By-Laws. The LYB PAC is audited by an LYB internal audit department every four years.
Key factors to be considered for LYB PAC contributions include the following:
- Proven support for industry and company issues
- Effective advocate for industry
- LYB facility in district
- Leadership positions and key committee assignments
- Integrity and character of the candidate
Compliance, Oversight and Disclosure
The Department of Government Relations and the LYB PAC Board have oversight for LYB’s engagement in the political process. Management of our participation in the political process in the U.S. is the responsibility of the Director of Government Relations, who reports directly to LYB’s Chief Legal Officer, who reports to the company CEO. The PAC Board maintains responsibility for ensuring all LYB political activities promote ethical and transparent engagement, advance the company purpose, and comply with applicable laws and reporting requirements. The Policy Committee, a duly authorized oversight committee made up of company executives and members of the Management Board, reviews and approves the company’s U.S. policy on political expenditures.
We are committed to transparency with regard to our political activity, and publish a Political Activity Report semi-annually which discloses:
- LYB PAC contributions
- Corporate Contributions to candidates, parties and political action committees;
- Contributions and expenditures made with the intent to participate in any political campaign or referendum;
- Payments to 527 organizations, independent expenditure committees, 501(c)(4) groups and other tax-exempt organizations that may use such funds for political purposes; and
- Independent expenditures made by the company itself; and
- The portion of any membership dues and other payments to trade associations that are used for political purposes
The Management Board is periodically updated on the company’s political, lobbying and other grassroots advocacy activities.
We also file quarterly reports regarding our U.S. federal lobbying activities with the Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate. These reports are available by searching for "Lyondell Chemical Company PAC" as a "Registrant" on the U.S. Senate's website below: http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm