First Solar Corporate Political Contributions Policy Statement
Guided by First Solar’s Code of Business Conduct and Ethics, and committed to compliance with all applicable laws, First Solar participates in the political process to help shape public policy, legislation and other governmental actions that are consistent with First Solar’s business objectives. First Solar believes corporate participation in the public policy process is an important means of enhancing shareholder value and is fundamental to democratic societies. First Solar is committed to being transparent about its political engagement.
Corporate Political Contributions
U.S. law prohibits companies from making contributions to candidates for federal office, but many states allow corporate contributions to state & local candidates, committees, political organizations and ballot issue campaigns. Consistent with federal and state law, First Solar makes bipartisan contributions to political candidates and initiatives that support strong public policy and sustainable market growth for First Solar’s business. In making such contributions, we evaluate a candidate’s position on issues of concern to the Company. Contributions are not based on the personal preferences of individual company leaders. We base our contribution decisions on the best interests of the Company, and on what we believe would support sound public policy. Among the factors that we consider in determining whether to support a candidate are:
- Whether the candidate sits on a committee that addresses legislation affecting First Solar’s business or renewable energy and sustainability policy;
- Whether the candidate represents a state or jurisdiction within which First Solar operates;
- The candidate’s committee standing and ranking;
- The candidate’s elected political leadership position and voting record; and
- The candidate’s personal characteristics, including integrity and effectiveness.
First Solar Political Action Committee
The First Solar Political Action Committee (First Solar PAC) was formed in 2010 to promote good citizenship and further business interests that are of concern to the Company. Funds in the First Solar PAC come directly from voluntary contributions from eligible employees. Beyond administrative support, as permitted under U.S. election laws, no corporate funds are used to support the First Solar PAC. Participation in the First Solar PAC is voluntary, and its activities are governed by a voluntary employee board of directors that manages funds, approves budgets, and considers contributions to individual candidates. Employee contributions to, and disbursements from, the First Solar PAC are regulated by federal and state laws and are managed by the First Solar PAC board of directors under guidelines governing its operations, including the selection and approval of contributions to candidates.
The First Solar PAC may make contributions to candidates for federal office or to candidates for state office in states in which direct contributions by the Company are prohibited by law. Contributions from the PAC program generally support candidates, parties, or committees whose views on specific issues are consistent with First Solar’s interests. Consideration is given to candidates who represent the communities we serve and who show support for policies and initiatives that are important to the Company. PAC program contributions are made without regard to the private political preferences of the Company’s executive management team or any other Company executive.
Trade Association Memberships
Like many major corporations, First Solar is a member of various industry trade organizations. Many of these organizations engage in lobbying activities, and some operate their own political action committees. First Solar may not necessarily agree with every position taken by each organization of which it is a member or of the other members of such organizations, but believes that, on balance, membership in and contributions to such organizations are consistent with promoting public policy aligned with the Company’s overall business objectives. When First Solar makes payments to these organizations, including membership fees and dues, we restrict the organization from using the funds for any election-related activity at the federal, state, or local level, including contributions and expenditures (including independent expenditures) in support of, or opposition to, any candidate for any office, ballot initiative campaign, political party committee, or PAC. The Company will disclose in its Political Activity Report any contribution to a PAC affiliated with a trade association.
Compliance, Monitoring and Oversight
The First Solar Code of Business Conduct and Ethics guides us in all that we do. The Code, which is grounded in our Company’s values, provides basic guidelines of business practice, as well as professional and personal conduct, that all employees are expected to adopt and uphold. The Code and policies thereunder specifically cover how our employees may engage in the political process and how we interact with representatives of government on behalf of First Solar.
All political activities carried out on behalf of First Solar are managed by the Public Affairs Department, which utilizes a third-party service provider in the administration of its political activity program. Political contributions using corporate funds are reviewed and approved by the Company’s Vice President for State & Local Government Affairs; any contributions above a threshold amount are subject to additional review and approval by the Company’s Chief Financial Officer. The Public Affairs Department reports annually to the Nominating and Governance Committee, which is comprised solely of independent members of our Board of Directors, on significant policies and practices concerning political contributions, political contributions made with corporate funds, payments to trade associations which may be used for political purposes, and political activity priorities in light of the Company’s public policy objectives.
First Solar maintains a robust government relations and political activity compliance program. We are committed to complying with internal policies, all relevant state, federal, and international laws and regulations and applicable state and local restrictions on corporate political activity.
Disclosures
The Company is committed to promoting transparency in our disclosures to the public. We recognize that there is public interest in corporate political activity, and publish on the First Solar website (www.firstsolar.com) a Political Activity Report, updated annually, which will disclose information relating to:
- Contributions to candidates, parties and political action committees;
- Any contributions and expenditures made with the intent to participate in any political campaign, ballot initiative or referendum;
- Any payments to 527 organizations, independent expenditure committees, 501(c)(4) groups and other tax-exempt organizations that may use with our knowledge such funds for political purposes; and
- Any independent expenditures made by the Company itself.
We also disclose these contributions and expenditures through filings as required by federal and state laws. Information regarding First Solar Political Action Committee contributions to individual candidates is available on the Federal Election Commission website: http://www.fec.gov/.
Additional Information
For additional information concerning First Solar’s political activities and related policies and procedures, contact First Solar’s Public Affairs Department.
Guided by First Solar’s Code of Business Conduct and Ethics, and committed to compliance with all applicable laws, First Solar participates in the political process to help shape public policy, legislation and other governmental actions that are consistent with First Solar’s business objectives. First Solar believes corporate participation in the public policy process is an important means of enhancing shareholder value and is fundamental to democratic societies. First Solar is committed to being transparent about its political engagement.
