Public Policy Engagement and Political Participation
Adopted by the Board of Directors on January 25, 2022
Engagement in the policymaking process is important to the success of American Airlines. As a global airline, our Company is subject to numerous laws and regulations that govern various aspects of our business in the United States and around the world. We regularly express our views regarding policies that might impact our business, team members, shareholders and other stakeholders – and we are committed to participation in policy and political processes in a manner consistent with exemplary corporate governance practices.
In this spirit, we also encourage our team members to be active in our democratic society and provide them with opportunities to do so through the American Airlines Political Action Committee (“PAC”), funded entirely with voluntary team member contributions.
Political Contributions
Our Standards of Business Conduct prohibit the use of corporate funds or resources to help or promote any political candidate or party without prior approval from the Company’s Ethics Office. All political activities, including financial contributions by the Company or its Political Action Committee, are made in support of issues important to our Company and the aviation industry, and to our team members’ and shareholders’ interests in the Company. They are not based on the personal political preferences of individual team members, executives or board members.
Our Company does not use corporate funds to contribute to candidates, political party committees and political action committees, including Super PACs and political committees organized under Section 527 of the Internal Revenue Code to promote the election or defeat of candidates for office. We also do not use corporate funds to make independent political expenditures or electioneering communications. If we make payments to other tax-exempt organizations, such as 501(c)(4)s, that the recipient may use for political purposes, we will publicly disclose those payments in our Political Contributions Report.
On rare occasions, we may use corporate funds to support or oppose state and local ballot initiatives if we believe an initiative would materially affect our business or the transportation infrastructure in the communities we serve. If we make any such contribution, we will disclose the amount and recipient in our Political Contributions Report. We will maintain a five-year archive of this information and will update these reports semi-annually.
Read our Political Contributions Report Opens PDF in a new window
Participation in Trade Associations
As part of our public policy engagement, we are members of several trade and industry associations, such as Airlines for America (“A4A”), the International Air Transport Association (“IATA”), Business Roundtable and the United States Chamber of Commerce. You can read a list of our trade associations and the portion of the dues we pay our principal trade groups that may be used for lobbying. Our involvement with those organizations allows us to gain insight into core issues for the airline industry and the business community and to advocate jointly for public policies that support an efficient, healthy, competitive industry and business environment. Our work with A4A and IATA in particular allows us to benefit from the opportunity to share technical expertise and operational knowledge that strengthens the safety, customer service and efficiency of our operations. Our Company is also a member of other associations and various chambers of commerce and similar organizations around the world and at the state and local level that may engage in public advocacy. Management regularly reviews and approves these memberships to ensure consistency with our Company’s public policy objectives.
American Airlines’ lobbying on climate policy reflects our commitment to reach net zero emissions by 2050 and our support for the goals of the Paris Agreement to limit the average rise in global temperature to well below 2°C above pre-industrial levels and to pursue efforts to limit it to 1.5°C. While we recognize that our trade associations’ policy positions may not align with our own on every policy, we believe it is important to have alignment on policies that will help our company and our industry transition to a net zero future. In 2022, we intend to assess the extent to which the climate lobbying activities of the principal trade groups of which we are a member are consistent with the goals of the Paris Agreement. To the extent we find mis-alignment, we will use our influence to work to make their policy positions consistent with the goals of the Paris Agreement. We intend to make this assessment available on our website and update it annually.
Federal disclosures regarding our lobbying activities are publicly available. Our public disclosure includes, among other things, our aggregate annual spending on trade association membership dues spent on lobbying. With respect to federal lobbying activity, we file Lobbying Disclosure Act Registration and Reports (Form LD-2) with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives, which reflect the specific bills and issues on which the Company engaged, as well as the total lobbying expenses our Company incurred during each calendar quarter.
Lobbying Disclosure Act Registration and Reports
Voluntary Political Participation by Team Members
Our team members are free to support the political process in a variety of ways on their own, such as through personal financial contributions or volunteering for candidates or organizations of their choice. However, their personal political activities must not suggest the Company’s support and must not be conducted on Company time or involve any unlawful use of Company resources. Team members may not make or commit to political contributions on behalf of American Airlines, and American Airlines will not reimburse or otherwise compensate a team member for their personal political contributions.
The American Airlines PAC, registered with the Federal Election Commission (“FEC”) and certain state and local campaign finance authorities, allows eligible team members to voluntarily pool their resources for political contributions to federal, state and local candidates. The PAC is funded solely by voluntary team member contributions and makes contributions on a bipartisan basis under our contribution policies and in support of our public policy goals. In deciding whom to support, the PAC prioritizes candidates who represent the communities we serve, who serve on relevant committees or in leadership positions, and who have shown support for policies important to our Company’s long-term interests. All American Airlines PAC contributions are made without regard to the personal political preferences of individual directors, officers and team members.
Oversight, Governance and Compliance
American Airlines maintains a robust compliance program for advocacy and political activity, with oversight by senior and experienced leadership. We are committed to complying with this policy and with the letter and the spirit of all relevant state, federal and international laws and regulations. This commitment and our organization and leadership help focus our public policy engagement on the issues most relevant to the long-term interests of our Company, team members, customers and shareholders.
The Corporate Governance, Public Responsibility and Safety Committee (“the Committee”) of our Board of Directors oversees this policy and the Company’s public policy engagement, political contributions and principal trade association memberships. The Committee, which is comprised entirely of independent directors, receives and reviews updates on these efforts at least annually. The Committee also reviews and approves changes to this policy.
Our Senior Vice President for Corporate Affairs and Chief Government Affairs Officer (“SVP/CGA”), who reports to the Chief Executive Officer, oversees our public policy engagement, including any use of funds to further our regulatory and public policy interests. The SVP/CGA leads American Airlines’ Global Government Affairs department, which is responsible for the day-to-day implementation of our public policy engagement and political contributions and compliance with this policy and with applicable laws. The Global Government Affairs department works closely with American Airlines’ Chief Legal Officer and with outside counsel dedicated to government affairs and political law compliance matters to ensure adherence with all related rules and regulations and with best practices.
The SVP/CGA also is responsible for administration and supervision of the American Airlines PAC, with oversight by the Board of Directors’ Corporate Governance, Public Responsibility and Safety Committee. We report American Airlines PAC donations to the FEC (FEC ID No. C00107300) and certain state and local campaign finance authorities as required by law.