Political Contributions and Activities Policy

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Political Contributions and Activities Policy

State Street Political Contributions and Activities Policy Statement

At State Street, reputation and integrity are two of our most important assets. State Street recognizes that, as a service provider to government entities globally and at the state, city and municipal level throughout the United States, it is subject to laws and regulations which may limit or prohibit, or require reporting of political contributions by certain of our employees. We also recognize that political contributions made on behalf of the Company should reflect the Company's interests.

This policy statement identifies the fundamental principles and practices applicable to State Street and its employees. These principles and practices stem from our primary ethics document, the State Street Standard of Conduct, and also our Political Contributions and Activities Policy, both of which, in addition to this policy statement and referenced disclosures, are annually reviewed by the Board of Directors and Nominating and Corporate Governance Committee.

Standards for Employees:

State Street values its employees' rights to participate in the political process as individual citizens. All employees may participate in the political process by making political contributions from personal funds, subject to applicable legal limits and in accordance with applicable law. Due to the nature of their job responsibilities or function, certain employees, must pre-clear their personal political contributions made to a U.S. federal, state, county or local public official or political entity. State Street will not, under any circumstance, reimburse or otherwise compensate employees for any such contribution. Employees engaging in political campaign activities are expected to do so as private citizens, and must at all times make clear that their views and actions are their own and not those of State Street. Also, employees may not use State Street's resources to further their own personal political activities or use coercive solicitations to pressure other employees to make political contributions to, or to support or oppose, any candidate, election, referendum or political cause or to engage in political fundraising activities.

Standards for the Corporation:

The laws of many countries, including the United States, set strict limits on political contributions made by corporations. In accordance with our Standard of Conduct, only the Chief Executive Officer may authorize the use of corporate resources in connection with political activities.

State Street participates in and pays membership dues to a number of industry trade organizations. Participation in these organizations is important to gain industry insight, foster relationships and professional opportunities within the business and to collaborate on topics of mutual interest. We request that each of our principal trade organizations refrain from using our membership dues:

  • for contributions to U.S. federal campaigns, state or local candidate campaigns, political party committees or political committees (including, PACs and independent expenditure committees);
  • to influence directly or indirectly the election of a federal, state or local candidate; or
  • for contributions to any other political organization exempt from U.S. federal income taxes, such as organizations organized and operated under IRS Code Section 527.

Our principal trade organizations, which are listed on our Lobbying Activities page, are those trade organizations to which we pay annual membership fees in excess of $50,000 and, for these purposes, which notify us that a portion of those fees is nondeductible for U.S. income tax purposes. We expect our principal trade organizations to comply with this request.

State Street understands that corporate political contributions may be of interest to various constituencies, including some of our shareholders, clients or employees. We therefore voluntarily make the following disclosures publicly available on a specifically designated section of our website:

2021 Statement on Future Political Contributions

January 11, 2021

As we continue to learn more about the assault on our Capitol on January 6, it has become clear that these attempts to subvert our democracy are much broader than the horrifying events of that day. The culpability for this untenable challenge to our Constitution and American values goes beyond the criminals that attacked our Capitol, and falls to a number of our elected leaders as well who, in effect, perpetuated the lies and untruths about the outcome of the 2020 presidential election.

While we are respectful of and encourage diverse political beliefs, any attempt to overturn the results of a legitimate election subvert the very system in which we live and conduct business and must be universally condemned. Our democratic system is an idea and an ideal that relies on the rule of law and the peaceful transition of power to sustain itself.

State Street will not support lawmakers or candidates who demonstrate views or engage in activities that are intended to undermine legitimate election outcomes. As a result, our Political Action Committee (PAC) will not contribute to lawmakers who supported last week’s efforts to undermine our democracy. Additionally, we will establish a process to evaluate contributions prospectively to ensure we are not supporting any candidate whom we believe are subverting the core democratic principles of our Constitution, especially election outcomes.

We call on all of our country’s leaders to come together, reject this violence and preserve the foundations of our democracy in order to serve the American people and unify these United States.