Political Disclosures

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Political Disclosures

Political Disclosures

 

Lockheed Martin is committed to participating in the political and public policy process in a responsible and ethical way that serves the best interests of our stockholders and customers.  We operate in the highly regulated global security industry, and our operations are affected by the actions of elected and appointed officials at many levels of government.  Our public policy activities include advocacy efforts at the federal and state levels, thought leadership regarding global security trends, and other important issues impacting the Corporation and our customers, educational outreach and promotion, and other related activities. 

Lockheed Martin complies with all applicable laws and regulations in connection with the Company’s political and public policy activities. Any political or other public policy activity in which Lockheed Martin engages, including political expenditures, comply with all internal policies and procedures, are made solely based upon the best interests of the Corporation and its stockholders, and are not based on personal agendas of individual directors, officers, or employees. 

Responsibility for managing and coordinating the Company’s political and public policy activities lies with its Lockheed Martin Government Affairs function.

Corporate Political Contributions and Expenditures

Independent Expenditures.  Lockheed Martin has not spent any direct corporate funds on independent expenditure communications to the general public that expressly advocate the election or defeat of a clearly identified federal candidate, and has no present plans to spend direct corporate funds on such communications.

International Contributions.  Lockheed Martin does not contribute money, assets, property or other things of value to any foreign candidates or political committees.

State Contributions.  In certain states where permitted by law, Lockheed Martin makes corporate political contributions in accordance with established criteria, including to candidates and political committees whose positions on business issues are important to the Corporation; candidates who represent geographic areas where Corporate facilities are located; or candidates who have leadership positions or committee assignments that are important to the Corporation’s interests.  All corporate contributions are fully disclosed with the appropriate state or local campaign finance authority, as well as published on this website.  

527 Political Organizations.  Since 2014, Lockheed Martin has not provided funding to 527 political organizations that are not registered as a federal or state political committee, with the exception of the National Governors Association (NGA) beginning in 2020. Lockheed Martin maintains membership in the NGA as a means to support our operations in all fifty states. In over half the states in which we operate we employ from a thousand to over twenty thousand people. We do not consult with the NGA regarding expenditures of their funds. The primary contact with the NGA is Robert Head, Vice President, Federal and State Government Relations and PAC Affairs.  

Political Action Committee.  In accordance with federal law, Lockheed Martin does not make corporate contributions to federal candidates or federal political committees.  The corporation supports the Lockheed Martin Employees’ Political Action Committee (LMEPAC), which makes contributions to federal and state candidates, political committees, party committees, and other section 527 political organizations. LMEPAC is funded exclusively through voluntary contributions from eligible employees and directors; employees participating in LMEPAC are not reimbursed, directly or indirectly, for political contributions or expenses.  LMEPAC supports federal and state political candidates who support national defense and other business issues of interest to the corporation.  Disbursements by LMEPAC are made solely based upon the best interests of the Corporation and its stockholders, and are not based on personal agendas of individual directors, officers, or employees.  All LMEPAC contributions are fully disclosed in reports filed with the Federal Election Commission (FEC) and can be accessed by going to the FEC website, as well as published on this website.

Trade Associations.  Lockheed Martin contributes to public policy debates by participating in trade and industry associations, as well as engaging directly in advocacy and grassroots communications efforts.  In the U.S. we advocate strong national defense, sustained space exploration, development of alternative energy technologies, corporate tax issues (including tax incentives for corporate research and development), export policy and international trade. 

We join trade associations that represent a broad spectrum of views on industry and policy issues important to our business interests.  Mission consistency is important to us, and we review our participation – with this in mind – on a regular basis.  While we do not always agree with the views of these groups, nor do we always agree with our industry peers, we are fully committed to collaborative problem-solving and to working within these industry structures. We believe that is the best way to address a problem, have the greatest impact, and get to the best outcome.

Our participation in trade associations is subject to management oversight by the Company’s Lockheed Martin Government Affairs function.  Lockheed Martin Government Affairs serves as the principal representative of the Company in trade and industry associations, as well as approves Company membership.

Lockheed Martin pays regular dues to several trade associations.  Some trade associations utilize a portion of membership dues for non-deductible state and federal lobbying and political expenditures.  Per the requirements of Section 162(e)(1) of the Internal Revenue Code, the trade associations to which we contribute must provide us with the percentage of our annual dues that are attributable to lobbying expenses.  A listing of the national-level trade associations to which Lockheed Martin paid dues of $25,000 or more in a single year and the portion of these dues not deductible under Section 162(e)(1) of the Internal Revenue Code are published on this website.

Lobbying Expenditures.  Lockheed Martin lawfully engages in the legislative process to communicate its views on legislative and regulatory matters affecting the Company’s business. 

Lockheed Martin’s Government Affairs function only engages in public policy and political activities directly related to the company’s business interests, such as national defense, space exploration, alternative energy technologies, corporate tax, export policy and international trade.  Lockheed Martin’s Ethics and Enterprise Assurance function assesses how our trade associations’ public policy positions align with our sustainability policy including climate-related issues. More information about our sustainability program can be found here.

 

Federal lobbying activities are regulated by the Lobbying Disclosure Act (LDA). In accordance with the LDA, the Company files quarterly disclosure reports with the Clerk of the House and Secretary of the Senate regarding payments for all federal lobbying activities.  These reports disclose all direct and indirect expenses related to lobbying, expenditures for grassroots efforts, and payments to trade associations that are used for lobbying.  The reports are available here.  (Search Field: "Registrant Name" Criteria: "Lockheed"). 

In states where the Corporation is engaged in advocacy efforts and is registered to lobby, the Corporation files reports as required with the appropriate state agency.  Lockheed Martin files all lobbying disclosure reports at the federal and state level in a complete and timely manner in accordance with applicable requirements.

Governance

All decisions regarding corporate political and public policy activities are managed by the Senior Vice President, Lockheed Martin Government Affairs, following coordination with individual Lockheed Martin elements in accordance with established policies and procedures. The Nominating and Corporate Governance Committee of the Corporation’s Board of Directors, which is composed entirely of independent directors, oversees our government affairs activities and political spending, receives reports from management on these matters, supervises the policies and reviews the purposes and benefits of these activities. The Corporation’s political activities are audited on a regular basis in accordance with the Corporation’s established audit schedule. Outside legal counsel provides regular guidance regarding compliance with all applicable laws and regulation of political activities.

Decisions regarding the Lockheed Martin Employees Political Action Committee are made by the PAC’s board of directors. The Board meets several times a year to set PAC policy and approve PAC budgets and contributions. The Board is composed of representatives from several Corporate functional areas and business units. The current members of the PAC board of directors are:

  • Chair: Shelly Stoneman  – Senior Vice President, Lockheed Martin Government Affairs
  • Treasurer: Robert Head –Vice President, State Government and Global Programs Support
  • Secretary: Donna Snyder – Vice President, General Counsel, Lockheed Martin Government Affairs
  • Mara Motherway - Vice President, Aeronautics
  • Paula Hartley – Vice President, Program Management, Missiles and Fire Control
  • Maryanne Lavan – Senior Vice President, General Counsel & Corporate Secretary
  • Maria Ricciardone – Vice President, Treasurer & Investor Relations
  • Woody Woodyard – Vice President, Corporate Communications, Enterprise Operations
  • Paul Lemmo – Vice President, Rotary and Mission Systems
  • Timothy Shephard – Vice President, Business Development Analysis, Space
  • Michael McBride – Vice President, Government Relations, Lockheed Martin Government Affairs