Political Activity Policy 

Eastman believes that it is important for our business, stockholders, employees, customers, and communities that we engage and actively participate in the political process. Decisions made at the federal, state, and local levels impact our business and the lives of those around us, and we believe our advocacy efforts are an effective and constructive means of working with regulators, legislators, and other relevant parties to strengthen and protect our business and communities. This policy sets forth basic principles concerning Eastman’s political contributions, political action committees, lobbying activities, and trade association participation.

Individual Political Engagement

Eastman encourages personal participation in the political process, consistent with applicable laws and Company policy. Eastman employees must follow the laws governing participation in political affairs, including political contributions, lobbying, and gift giving. Employees are free to give a personal contribution to a party, committee, or candidate on their own behalf, but are prohibited from making any contribution of Company funds, or from seeking reimbursement of contributions, including petty cash, property, or services to any political party or committee, or to any candidate or holder of any office of any government without specific, prior approval from Eastman's Government Affairs Department and the Law Department.

Any employee who is considering seeking public office should be aware of applicable Company personnel policies and should discuss the matter with Eastman's Government Affairs organization, as well as their management and Human Resources representative. To prevent a conflict of interest and assure compliance with applicable law, at no time should Eastman's name, information, property (including personnel, office space, computers, email accounts, telephones, copiers, etc.), time, or other resources be used for political activities not specifically sponsored by the Company or approved by Eastman's Government Affairs Department.

Corporate Political Engagement

Any contribution by the Company to a political party or candidate must be done in accordance with all applicable laws. To ensure compliance with contribution laws, no political contribution of any kind, either direct or indirect, shall be made by the Company or on its behalf without the express authorization from Eastman’s Government Affairs Department and the Law Department.

U.S. federal election laws permit corporations to establish political action committees which may make contributions to federal candidates, state candidates (as permitted by law), and other committees. Eastman maintains, as a separate legal entity from the Company, a federal political action committee (“EastmanPAC”) which is registered with the Federal Election Commission. EastmanPAC is funded in accordance with applicable federal and state law on a voluntary basis by eligible employees and directors of Eastman and makes contributions to U.S. federal and state candidates. Every EastmanPAC contribution is reported to the Federal Election Commission (FEC), and those reports are made public on the FEC website. View EastmanPAC's contributions. The PAC Contribution Approval Process and the PAC Contribution Guidelines set forth how EastmanPAC contributions are established and governed.

As a matter of policy, Eastman rarely makes direct corporate political contributions to political candidates, political party committees, ballot committees, or political action committees, even when permitted to do so by applicable law. Pursuant to state law, however, Eastman does operate, through a separate legal entity, the Eastman State of Tennessee PAC, which is funded by corporate funds and only supports Tennessee state candidates. View Eastman State of Tennessee PAC contributions. Further, it is Eastman’s general policy not to directly support or oppose ballot initiatives or to make direct independent expenditures that advocate the election or defeat of federal, state, or local candidates, despite the law permitting corporations to make such expenditures. Eastman, however, could support or oppose ballot initiatives in the future if the initiative would materially and directly impact the interests of the Company and our stockholders and employees. View Corporate Political Spending Guidelines.

In addition to the regular management by Eastman’s Government Affairs Department, Law Department and the EastmanPAC Advisory Council, Eastman’s Board of Directors and the Board’s Health, Safety, Environmental and Security Committee (the members of which Committee are all of the Board’s independent non-employee directors) review and oversee the Company’s involvement in political activities and government policy and political contributions policies and spending semi-annually. Such review and oversight allows continued application of Eastman’s high ethical standards, transparency in the Company’s political involvement, and ensures that the Company’s political involvement is in the best interests of stockholders and the Company.

Lobbying and Participation in Trade Association and Business Organizations

Eastman is committed to complying with all applicable laws relating to lobbying activities, including those requiring disclosure of our activities at the federal, state and local levels. The Lobbying Disclosure Act, and subsequently, the Honest Leadership and Open Government Act, established U.S. guidelines for reporting federal lobbying activity, and most states (and many municipalities) require reporting of lobbying activities (including grassroots activities) at the state and local levels. Often employers and employees who engage in lobbying must register in order to conduct lobbying activities. Moreover, external parties hired to engage in lobbying activities or make lobbying contacts must also register. Specifically, employees of Eastman's Government Affairs/Public Affairs Department are authorized to engage in federal, state, local and foreign lobbying activities on behalf of Eastman. No other employee is authorized to approve lobbying activities on behalf of Eastman unless such approval is granted by the Government Affairs/Public Affairs Department. Lobbying registrations and disclosures are made publicly available via U.S. government agency websites. Eastman includes all of this information (including the portion of dues used by U.S. trade and business associations for lobbying activities) in the quarterly lobbying activity reports filed with the U.S. Congress, as required by law. Eastman also provides access to these quarterly lobbying activity reports on the Company's website.

Eastman participates in direct advocacy on certain public policy issues that we believe are important. As part of our advocacy efforts, we participate in a number of trade organizations and industry groups representing the interests of our industry and the broader business community. While Eastman may not always support every position taken by these organizations or their other members, we believe our participation in these organizations is important and furthers Eastman’s goals. Payments to these organizations and groups, including membership fees and dues, are not to be used for election-related activity at the federal, state or local levels, including contributions and expenditures for candidates, ballot initiatives, political party committees or political action committees. Eastman has no participation in or payments to organizations that develop and promote model legislation. Proposed memberships in and contributions to trade and business associations are reviewed by Eastman’s Government Affairs Department and such memberships are reported annually to Eastman’s Board of Directors and its Health, Safety, Environmental and Security Committee.

For its federal lobbying disclosures, Eastman receives information from its U.S. trade and business associations identifying the portion of Eastman dues and payments used by those groups for lobbying activity. For those trade associations to which Eastman contributes $50,000 or more annually, Eastman also provides the following information: 


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