AIG may make political contributions and engage in political activities in support of candidates and parties at the federal and state levels where applicable laws and regulations permit. It is the policy of AIG that employees involved in lobbying, advocacy and political activities do so in accordance with the AIG Code of Conduct, AIG and AIG-related Entity Policies, Standards, Procedures, Guidelines or other policy-related documents, and in accordance with all applicable registration, disclosure and other laws, rules and regulations governing such activities.
All political activities carried out on behalf of AIG are managed by AIG’s U.S. Federal and State Government Affairs Groups, which work as appropriate with other company functions to determine which activities are permitted and consistent with AIG’s business strategy. Certain restrictions on political activities are detailed in the AIG Global Lobbying and Political Activity Policy. In the past, the Regulatory, Compliance and Public Policy Committee (“RCPPC”) of the AIG Board of Directors has reviewed the company’s policy on political expenditures and management has provided the RCPPC with a report on all political contributions that have been made since the last such report on at least an annual basis. Going forward, the Nominating and Corporate Governance Committee (“NCGC”) will perform such review and management will provide its report to the NCGC.
AIG suspended corporate political contributions in October 2008, and has not made any corporate contributions since that time to political candidates, parties, or committees; to Super PACs; to tax exempt organizations, such as 501(c)4s; for Independent political expenditures in support of or opposition to a campaign; for support of or opposition to Ballot Measures; or to 527 groups – with the exception of contributions (of $25,000 each in 2016) to the Democratic Governors Association and Republican Governors Association, both of which were instructed not to use AIG funds for political purposes). Any decision to renew making corporate contributions more broadly (such as to politically oriented 501(c)(4) organizations) would be taken by AIG management, and subsequent corporate contributions of that kind would be disclosed on the AIG public web site. Per AIG’s Code of Conduct, AIG funds or assets are never to be used for political purposes without first consulting with the Head of U.S. Federal and State Government Affairs or the Head of International Regulatory and Government Affairs.
AMERICAN INTERNATIONAL GROUP, INC. EMPLOYEE POLITICAL ACTION COMMITTEE and AMERICAN INTERNATIONAL GROUP, INC. EMPLOYEE STATE POLITICAL ACTION COMMITTEE (AIG PAC)
The AIG PAC was established to promote and facilitate the accumulation of voluntary employee contributions for the support of political parties and candidates for nomination or election to federal office in the United States, and for support of political parties and candidates at the nonfederal level in accordance with state and local law. All political contributions made by the AIG PAC are publicly disclosed and can be found at the Federal Election Commission at www.fec.gov. All AIG PAC contributions are made in accordance with applicable federal and state laws, and without regard for the private political preferences of AIG executives.
AIG PAC Governance
The contribution strategy of the AIG PAC is overseen by the PAC Board of Directors, operating under its bylaws. The AIG PAC Chairman, PAC Board of Directors and PAC Treasurer communicate regularly to review and plan AIG PAC activities and contributions. The PAC Board reviews planned activities to ensure they are aligned with AIG’s business interests and are bipartisan in nature. AIG PAC supports candidates from both major political parties who share AIG’s vision and values or providing business and personal security associated with insurance solutions. AIG PAC may contribute to federal and state candidates or committees as appropriate and permissible by applicable laws.
In consultation with outside counsel, AIG developed processes governing political spending, and its Government Affairs and Compliance Departments work together to ensure its policies and procedures are strictly maintained.
The following are (i) the members of the AIG Employee Political Action Committee Board of Directors and the Bylaws of the AIG Employee Political Action Committee and (ii) the members of the AIG Employee State Political Action Committee Board of Directors and the Bylaws of the AIG Employee State Political Action Committee:
Federal Lobbying Disclosure Act (LDA) Compliance
The Lobbying Disclosure Act of 1995 (“LDA”), as amended by the Honest Leadership and Open Government Act of 2007, governs lobbying of both the Congress and the Executive Branch. In compliance with the LDA, AIG files quarterly lobbying reports (LD 2s) which publicly disclose all federal lobbying activities. In accordance with the LDA guidelines administered by the Clerk of the House and the Secretary of the Senate, AIG reports all expenses related to lobbying, including: 1) overhead cost; 2) Travel; 3) a portion of employee salaries that were spent on lobbying activities or preparing for lobbying contacts; 4) fees paid to outside lobbying consultants; and 5) portions of trade association dues that are deemed nondeductible and are related to lobbying activities. In addition, all issues that the company is currently lobbying and the entities lobbied are disclosed. Past LD2 reports can be found at https://disclosures.house.gov/ld/ldsearch.aspx. Reports for the last year are below.
AIG Trade Association Fees Allocated to Lobbying or Political Activities
AIG belongs to various trade associations that assist in advocating public policies affecting AIG and the insurance sector. Links below reflect the portion of AIG’s payments to trade associations (whose annual fees are $25,000 or more) that was allocated to lobbying activities.