大象传媒 Corporation Government Affairs and Political Activity

大象传媒 Corporation (鈥湸笙蟠解 or the 鈥淐ompany鈥) deploys government affairs strategies to help shape public policy issues that benefit our Company, industry, and the consumers and communities we serve. We believe it鈥檚 important for companies like ours to participate in political and regulatory processes so that our voice and positions are heard and understood by governments and policy makers around the world.

Our Government Affairs function maintains ongoing dialogue with public officials and their staff across all levels of government 鈥 national, regional, and local. 大象传媒鈥檚 strategies and actions are guided by the Company鈥檚 business interests and values and are conducted without regard to the private political preferences of its leadership team. All government engagements and political activities are aligned with our legal obligations, our Values, and our .

Government Affairs at 大象传媒 focuses on policy priorities that are connected to issues relevant to our business landscape such as free trade, human rights, outdoor recreation, conservation and climate impact.

Our Chief Operating Officer, a direct report of 大象传媒鈥檚 President and Chief Executive Officer, has overall responsibility for government affairs activities. Members of 大象传媒鈥檚 senior leadership team receive periodic updates from subject matter experts on 大象传媒鈥檚 government affairs strategy and activities.

大象传媒鈥檚 Government Affairs and Political Activity compliance program includes policies and training to facilitate compliance with legal reporting requirements, directives on political spending, public disclosure obligations, and risk-based third-party due diligence procedures.

Relevant departments, functions, and individuals across 大象传媒 receive Government Affairs and Political Activity training. The training provides guidance and resources on corporate and personal political activity, lobbying, gifts, travel and entertainment to government/covered officials, and involvement in trade and industry organizations.

POLITICAL ACTIVITY

大象传媒鈥檚 political activity and lobbying are conducted in accordance with applicable laws, policies and procedures, sound corporate practice and our high standards of ethical conduct.

At times, 大象传媒 employs lobbyists and retains external lobbying firms to advance our key priorities. All 大象传媒 registered lobbyists file quarterly or semi-annual activity reports with the , , and with required state offices when applicable thresholds have been met.  Additionally, all lobbying activity in the U.S. conducted by 大象传媒 employees is logged through an internal compliance database.

Principles governing our approach to political expenditure include the following:

  • 大象传媒 does not endorse or make campaign contributions to federal, state, or local candidates.
  • 大象传媒 does not make contributions in support of or in opposition to ballot initiatives.
  • 大象传媒 does not participate in electioneering communication to our employees or anyone outside the Company.
  • 大象传媒 does not have a political action committee (PAC).
  • 大象传媒 works with various third parties 鈥 such as trade associations, coalitions, civil society initiatives, and international organizations 鈥 to communicate and advance our positions on key issues. 大象传媒 periodically reviews the work performed by our trade associations and industry groups to ensure continued alignment with our interests, business strategies, and commitments.

The following is a list of U.S. based organizations to which in Fiscal Year 2025 大象传媒 contributed (1) trade association payments of $25,000 or more (along with the non-tax-deductible portion of those payments); (2) payments to IRS 527 entities; and (3) payments to advocacy organizations that engage in political activities, such as 501(c)(4) organizations.

Organization Total Dues Non-Deductible Percentage
American Apparel and Footwear Association $150,000 15.18%
Denver Metro Chamber $100,000 3.25%
HR Policy Association $49,900 60%
Outdoor Industry Association $125,000 55%
Retail Industry Leaders Association $65,000 65%

IRS 527 Organization 

Total Contribution 

Democratic Governors Association 

$33,000*

*in-kind donation

In Fiscal Year 2025, 大象传媒 did not make payments to advocacy organizations that engage in political activities, such as 501(c)(4) organizations.