Engagement in the Political Process
LyondellBasell (LYB) believes active participation in the political process is essential to our long-term success. LyondellBasell advances our public policy agenda through direct lobbying, involvement in various trade associations and the LyondellBasell 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 directly and through trade associations, is subject to oversight by LyondellBasell senior management and CEO. In addition, the LYB PAC Board is responsible for the management of all PAC activities, including the approval of all PAC distributions.
Political Contributions
LyondellBasell does not make direct political contributions to political parties or candidates using company resources (including monetary and in-kind services), even where permitted by law. All political contributions are made solely through the LYB PAC, which is funded voluntarily by employees. All financial contributions strictly adhere to federal and state laws regarding contribution limits on amount and source, criteria and reporting requirements. LyondellBasell 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 LyondellBasell employee at any level across the organization.
Public Policy and Advocacy
Our advocacy activities are directed toward advancing LyondellBasell 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. LyondellBasell's strategy is grounded in safe and reliable operation of all assets. Contributions are based upon advancing our business goals in a broad range of public policies, including, but not limited to: promoting a stable and predictable regulatory framework for our operations; fair and equitable tax policies that promote economic investment, job creation and global competitiveness; improving energy efficiency and sustainability programs, policies and activities; advancing innovation and technology in manufacturing, recycling and infrastructure; improving work development programs to meet the needs of industry; and are consistent with the company’s public policies on sustainability, advancing a circular economy and addressing climate change. Moreover, LyondellBasell 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.
LyondellBasell 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 senior management. LyondellBasell's positions on many key issues are available through a variety of sources, including this website, our Sustainability Report, Principles for Public Policy for Sustainability, annual proxy statement and press releases. Our lobbying and political contributions are aligned with these positions.
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
LyondellBasell 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.
LyondellBasell 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. LyondellBasell reviews these memberships annually to assess their business value and alignment with its policies and priorities. The Managing Director of Government Relations has oversight over memberships in U.S. trade associations.
The portion of dues paid to U.S. based trade associations to which we contribute $50,000 or more annually that is used for lobbying or political activities are disclosed in our U.S. Political Activity Report.
LyondellBasell'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 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 PAC operations are governed by the LYB PAC By-Laws. LyondellBasell 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 Managing 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 LyondellBasell internal audit department every four years.
Key factors to be considered for LYB PAC contributions include the following:
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Proven support for industry and company issues
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Effective advocate for industry
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LyondellBasell facility in district
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Leadership positions and key committee assignments
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Integrity and character of the candidate
Compliance, Oversight and Disclosure
The Department of Government Relations and the LYB PAC Board have oversight for LyondellBasell’s engagement in the political process. Management of our participation in the political process in the U.S. is overseen by LyondellBasell's Chief Legal Officer, who reports to the company CEO. The LYB PAC Board maintains responsibility for ensuring all LyondellBasell 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, 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:
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LYB PAC contributions
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Corporate Contributions to candidates, parties and political action committees;
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Contributions and expenditures made with the intent to participate in any political campaign or referendum;
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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
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Independent expenditures made by the company itself; and
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The portion of any membership dues and other payments to trade associations that are used for political purposes
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
LyondellBasell is assessed annually by the Center for Political Accountability (CPA) and has received a First Tier score on CPA's Zicklin Index, which measures transparency and accountability in corporate political spending. To learn more about the CPA Zicklin Index and our 2022 score, click here.
