1. The Company shall not:

  • contribute to or make expenditures on behalf of any federal, state or local candidates for election, referendas or initiatives;
  • contribute to or make expenditures on behalf of political parties;
  • contribute to or make expenditures on behalf of political committees or other political entities organized and operating under 26 U.S.C. Sec. 527 of the Internal Revenue Code;
  • contribute to any charity or non-profit organization at the request of any federal, state or local governmental office holder or any candidate for such an office;
  • donate Company time, resources, products or services to any of the foregoing; or
  • pay for advertisements, printing or other campaign expenses.

For purposes of this Policy, each of the foregoing shall constitute “Company Political Spending.”

2. The Company and/or its employees may belong to trade associations and similar organizations (e.g., the National Association of Real Estate Investment Trusts, The Real Estate Roundtable, the National Association of Industrial and Office Properties, etc.) that are engaged in or that the Company anticipates may engage in lobbying or political spending. Any amounts spent by such trade associations or similar groups on lobbying or political spending shall not be attributed to the Company, provided that such activities are not controlled by the Company and are generally undertaken for the benefit of the industry or members of the organization as a whole.

3. The Nominating and Corporate Governance Committee of the Board shall receive an annual report from management confirming the Company’s compliance with this policy.

4. Personal, non-corporate contributions and expenses are not affected by this Policy. Under no circumstances shall an employee attribute any personal contribution or support to his/ her employment with Piedmont or be reimbursed directly or through compensation increases for personal political contributions or expenses.

5. The Company will not pressure or coerce employees to make personal political expenditures or take any retaliatory action against employees who do not.

6. The Associate General Counsel shall be responsible for taking appropriate measures to assure compliance with this Policy.