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Political Contributions

Alcoa encourages all employees to vote and be active participants in the political process and has established the following rules in this area:

  1. Unless the chief executive officer and general counsel of Alcoa provide their prior written approval, Alcoa funds, property, services, and things of value may not be donated to or used to aid or oppose any political party, candidate, or campaign. While such contributions have rarely been approved and made over the years, Alcoa has retained the flexibility to do so when it would be consistent with business needs and compliant with applicable law.

  2. Alcoa property and assets may not be used in any fashion to assist or oppose any referendum or other vote of the electorate on a public issue unless Alcoa’s chief executive officer provides her or his prior written approval and the general counsel confirms the legality of the use of such property and/or assets.

  3. Employees may not support a political party, candidate, or election campaign during work time, and employees may not be reimbursed for personal political activity.

No exception to these rules or prohibitions on political contributions has been approved in the last fiscal year.

In addition, in the annual Business Conduct Survey, officers, directors and designated employees certify compliance with the following statements regarding political contributions:

  • The use of Company funds, property, services or things of value for or in aid of political parties or candidates for public office is prohibited. Any exception requires the prior written approval of the General Counsel and the Chief Executive Officer of Alcoa.
  • No corporate asset may be used for or in aid of any committee whose principal purpose is to influence the outcome of a referendum or other vote or the electorate on a public issue, unless the legality is confirmed by the General Counsel of Alcoa and the written approval of the Chief Executive Officer of Alcoa is first obtained.
  • Employees are encouraged to participate in political activities as they see fit, on their own time and at their own expense. No reward, compensation or reimbursement for such activity or the expense thereof shall be made by the Company directly or indirectly.

Please see http://www.alcoa.com/global/en/about_alcoa/corp_gov/
policy_bus_conduct.asp
for more information on the Business Conduct Survey.

United States election laws do not allow the use of any corporate funds or resources for federal elections. Similar laws exist in many U.S. states. Although U.S. and many state election laws allow companies to sponsor and support political action committees for their employees, Alcoa does not sponsor such committees.

While other countries and some U.S. states may permit companies to donate funds directly to political parties and candidates, this is something Alcoa has rarely, if ever, done. The chief executive officer and general counsel must review in advance and approve in writing any such donation.

Alcoa has a responsibility to customers, shareholders, employees, and the communities where it operates to build an understanding and acceptance of the company’s position on public issues at all levels of government. It is acceptable for the company to express its view to government officials on subjects that might affect Alcoa’s welfare.

Communicating the company’s position on issues or matters of policy to government officials can subject the employee and the company to registration and reporting obligations at the federal or state level. In those cases, Alcoa complies with applicable laws.

While issues vary from country to country and region to region, some of the general issue areas in which Alcoa becomes involved include:

    Energy supply, price, and availability;
    Global climate change;
    Taxes;
    Mining;
    Recycling; and
    Health and safety

In addition to expressing the company’s position on various issues, Alcoa belongs to organizations in many countries that also interact with governments on public matters. Following is a sampling of these organizations.

Australia
Australian Aluminium Council
Business Council of Australia
Chamber of Minerals and Energy Western Australia
Chamber of Commerce and Industry Western Australia
Victorian Employers’ Chamber of Commerce and Industry

Brazil
The Brazilian Aluminum Association (ABAL)
The Brazilian Metals Association
American Chamber São Paulo & Brasilia
The Brazilian Corporate Council for Sustainable Development
The São Paulo State Federation of Industries

Canada
The Aluminum Association of Canada
Canadian Chamber of Commerce
Quebec Federation of Chamber of Commerce
Montreal Board of Trade
American Chamber of Commerce in Canada
Canada Iceland Chamber of Commerce

Europe
European Aluminium Association
Business Europe
AmCham EU
Eurometaux
Aluminium Federation Ltd. (ALFED)
Gesamtverband der Aluminiumindustrie e.V. (GDA)

United States
The Aluminum Association
U.S. Climate Action Partnership (USCAP)
The Business Roundtable
National Association of Manufacturers
U.S. Chamber of Commerce

Alcoa strongly supports national legislation and an international framework to address the critical challenge of climate change, and we work closely with other businesses, environmental groups, and governments to build support for such action. Some of the business associations that we support for other reasons disagree with us on this important issue. We have expressed our opposition to those positions within those organizations and work with other business members to make the case for mandatory caps on greenhouse gas emissions and a flexible market-oriented solution to make those reductions. For more background on Alcoa's position on climate change, please click here.
http://www.alcoa.com/global/en/environment/climate_change/
climate_overview.asp


Alcoa has requested information regarding lobbying expenses and political expenditures from trade associations and other tax-exempt organizations in the United States that received from Alcoa total dues or payments of $25,000 or more and who spend more than 10% of their revenues on lobbying activities. Based on the information we received in 2008, the following amount of Alcoa dues or payments that were used for lobbying or political expenditures is set forth below:

Organization Lobbying and Political Spending
$
Total
$
The Business Roundtable 108,357  
US Chamber of Commerce 35,000  
National Association of Manufacturers 8,500  
US Climate Action Partnership 95,000  
    246,857


Copyright © 2008 Alcoa Inc.
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