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Policy on Political Contributions and Expenditures

For Lobbying, Gifts and Travel for Government Officials

  1. Every day, governments make policy decisions that affect Air Products and its business operations. We therefore recognize our responsibility to our stakeholders to participate in the political process.

  2. Air Products will not use corporate funds to make direct or indirect political contributions to candidates in any country or region, even where allowed by law. However, we do use our resources to advance matters of public policy by educating public officials about our business. We also use our resources to facilitate employee contributions.

  3. All spending of corporate funds on public policy activities shall reflect the Company’s interests and not those of its individual officers or directors. All corporate spending on public policy matters is reported by the company to U.S. Secretary of the Senate and Clerk of the U.S. House under the Lobbying Disclosure Act (LDA) and Honest Leadership and Open Government Act (HLOGA) requirements, and annually to the Internal Revenue Service, which addresses both state and federal corporate public policy activity.

  4. Air Products utilizes a political action committee (PAC) to participate in the political process. The Air Products Political Alliance (PAC), whose membership comprises certain eligible Air Products employees who donate to the PAC, makes contributions to U.S. candidates who support the company’s business interests. Employee participation in the PAC is purely voluntary, and contributions are reported to the Federal Election Commission (FEC) and applicable state agencies as required by federal and state laws.

  5. Employees will not be reimbursed directly or through compensation increases for personal political contributions or expenses. The Company will not pressure or coerce employees to make personal political expenditures or take any retaliatory action against employees who do not. Details of employee contributions to the Air Products Political Alliance and its contributions to candidates and other political action committees are publicly available on the Federal Election Commission’s website.

  6. As permitted by law, corporate funds and facilities may be used to provide administrative support for the Air Products Political Alliance.

  7. Air Products strictly prohibits employees from giving or offering a federal, state, or local government official anything of value in order to influence his or her official conduct or to give a government official anything of value to thank him or her for specific official actions he or she performed or may perform.

  8. Air Products prohibits employees from providing gifts, travel or anything of value to Members of Congress, their staffs, employees or other federal government officials pursuant to the federal LDA, the HLOGA, and the U.S. House & Senate rules and all other applicable federal regulations.

  9. The Corporate Governance and Nominating Committee of the Board monitors the Company’s political activities through annual reports from members of management responsible for the activities.