Political Disclosure

Overview

All political activities of BWXT Technologies (“BWXT”) are managed from the highest levels of the Company and are in accordance with applicable laws and our government relations policies. Under the BWXT Governance Committee Charter, the Governance Committee of our Board of Directors has responsibility for reviewing and monitoring the Company’s conduct of government relations activities, including any political action committees. 

The Senior Vice President and Chief Corporate Affairs Officer (“CCAO”) leads BWXT’s government relations and political activities, is a member of the Company’s senior leadership team, and reports directly to BWXT’s Chief Executive Officer. The CCAO reports to the Governance Committee at least annually on the Company’s political and lobbying activities, including with respect to the BWXT Employee Political Action Committee ("BWXT PAC"). The CCAO also works closely with the Legal department to ensure the Company’s political activities comply with all legal requirements, company policies, including our political activity policy, and the highest ethical standards. Together, the CCAO and Legal department strive to ensure that all political activities are conducted in accordance with the standards articulated in the Company’s Code of Conduct and government relations policies relating to lobbying, political activities and political contributions.

All political activities are carried out in support of Company objectives, issues of importance to the aerospace and defense industry, the Company and its shareholders, and are not based on the personal preferences of individual employees, executives or board members. BWXT actively participates in public policy debates at the federal level. The Company’s government relations initiatives are intended to educate and inform officials and the public on a broad range of public policy issues in furtherance of its business objectives.

Corporate political contributions

BWXT does not contribute corporate funds to federal, state or local candidates, section 527 organizations, Super PACs, ballot measures or any other election-related matters including independent expenditures or other communications to the general public related to the support or opposition of candidates. Further, while the Company does not contribute to politically-aimed 501(c)4 organizations, we are a member of several local civic leagues and economic development organizations in the communities in which we operate. We do not join or contribute to these organizations for political purposes, but with an aim to enhance each community.

BWXT Employee Political Action Committee

BWXT allows eligible employees to make voluntary contributions to the BWXT PAC. BWXT PAC is not funded using corporate dollars. The purpose of BWXT PAC is to use employee contributions to support candidates for federal office, and to certain organizations, such as the Democratic Congressional Campaign Committee and the National Republican Congressional Committee, which are operated in accordance with Internal Revenue Code (“IRC”) Section 527. BWXT PAC is governed by a separate Board of Directors comprised of members of BWXT’s Corporate leadership team and representatives from non-executive functions, operating in accordance with BWXT PAC’s bylaws.

In addition to its bylaws, BWXT PAC adheres to the following principles:

• Participation by eligible employees is always voluntary;
• BWXT PAC does not seek, request or expect any specific benefit for its contributions to candidates or any official act;
• BWXT PAC reports contributions to elected officials and candidates as required by law, and to PAC contributors regularly;
• BWXT PAC contributions are intended solely for individuals seeking U.S. federal elective office; and
• BWXT PAC will only make contributions to leadership PACs, multi-candidate PACs, or organizational or association PACs, after careful and deliberate consideration by the Board of Directors of BWXT PAC.

The Board of Directors of BWXT PAC considers the following factors in deciding the timing and amount of contributions to candidates:

• Membership on key committees that consider critical legislation;
• Whether the candidate serves or has the potential to serve in a leadership position;
• Candidate’s voting record and views on issues critical to our businesses;
• Whether the candidate represents a state or district where BWXT has a facility or employees;
• The competitiveness of the election; and
• The character and integrity of the candidate.

BWXT PAC is registered with the Federal Election Commission (“FEC”). All contributions made by BWXT PAC are reported per the FEC's required filing schedule. A full list of candidates and committees to which BWXT PAC has contributed can be found here.

Trade associations

In the ordinary course of business, BWXT participates in, and pays membership dues to, certain trade associations. Membership in trade associations can provide a number of benefits including: facilitating the Company's ability to stay abreast of technical issues and emerging industry standards; providing educational opportunities for employees; supporting workforce development initiatives; reporting on trends relevant to the Company’s business; and engaging in public advocacy and education on behalf of the membership. Some trade associations utilize a portion of membership dues for non-deductible lobbying regarding issues of common concern to members. Under IRC Section 6033(e)(1), trade associations are required to inform contributors of the portion of annual dues, if any, attributable to lobbying expenses. BWXT does not make payments to trade associations or other tax-exempt organizations that are designated for election-related purposes.

A listing of any 501(c)(6) associations to which BWXT paid dues or made contributions of $25,000 or more and the portion of such payments, if any, not deductible under IRC Section 162(e)(1), are set forth in the Trade Association Payment Listings.

Lobbying activities

BWXT responsibly and lawfully engages in the legislative process to communicate its views on legislative and regulatory matters affecting the Company's business and its various constituencies. All contacts and communications with elected or appointed officials on behalf of the Company must be pre-approved by the CCAO or her designee, as a means of ensuring that such engagements adhere with applicable legal requirements and Company policies and align with BWXT shareholder interests and the Company’s values. BWXT has in place regular lobbying reporting procedures and mandatory annual training to ensure the accuracy, timeliness and oversight of its lobbying disclosures.

BWXT’s federal lobbying activities are conducted in full compliance with the Lobbying Disclosure Act and all internal lobbying-related policies. As such, the Company's lobbying activities and expenses, as defined by IRC Section 162(e), are reported to the U.S. Congress on a quarterly basis. In addition, the Company files semi-annual reports detailing certain Federal Election Commission Act contributions, honorary contributions, presidential library contributions, and payments for event costs. These reports are publicly accessible at the U. S. House of Representatives Office of the Clerk and the U.S Senate Office of Public Records websites.