Engagement in the political process is critical to our success. Our future growth depends on forward-thinking legislation and regulation that makes society safer and more energy efficient and improves public infrastructure.
When formulating policies and drafting laws that improve safety, security, energy efficiency and infrastructure, policymakers need to be fully informed about the commercial availability of products and services that can deliver real benefits and improvements. Policymakers risk missing opportunities to fully exploit technology or causing unintended consequences when making decisions without the benefit of information from the commercial sector. Our lobbying activities are designed to educate policymakers. We consistently advocate the need for technologically neutral solutions that allow robust competition in the private sector to deliver the intended policy results.
Below is a list of some of our top legislative and regulatory priorities:
- Policies and regulations that encourage the use of public utilities to deploy demand response technologies and smart grids to reduce electricity consumption;
- Emission reduction policies that reduce the use of global warming and ozone depleting refrigerants;
- Investment in the air traffic control system to make flying both safer and more energy efficient;
- Commercial building, permitting and construction codes that facilitate safer, more energy efficient construction and renovation;
- High-priority Department of Defense programs that support our national security;
- Tax, trade and other policies to ensure that our nation can compete on a level playing field around the globe; and
- Policies that impact the deployment of Industrial Internet of Things technology and software including data privacy and cybersecurity.
We have developed a strong team of government relations professionals that drive our lobbying programs and initiatives. Our government relations organization is led by a Senior Vice President of Global Government Relations, who reports directly to the Company's Senior Vice President and General Counsel. Members of the government relations organization work from a global network of offices.
To ensure alignment of legislative and regulatory priorities with business objectives, our Government Relations organization is aligned with the corporation’s business and regional leadership teams and is directly engaged in their core strategic processes. On an annual basis, the Government Relations team engages with the company’s senior business leaders to review long-term strategic priorities, identify associated public policy risks and opportunities, and develop prioritized action plans. The Senior Vice President and General Counsel and Senior Vice President of Government Relations also meet at least quarterly with Honeywell’s Chairman and CEO to ensure policy advocacy priorities are aligned to Honeywell’s overall business objectives.
We are committed to responsibly engaging in the political process and fully complying with all applicable laws and regulations, our principles of good governance, and our high standards of ethical conduct.
The law department oversees our lobbying activities. The Senior Vice President of Global Government Relations reports to the Senior Vice President and General Counsel and works closely with the Corporate Secretary and Chief Compliance Officer, whose organization ensures compliance with our political spending policy. The Senior Vice President and General Counsel, Senior Vice President of Global Government Relations and Corporate Secretary and Chief Compliance Officer meet regularly with our Chairman and Chief Executive Officer and his leadership team about legislative, regulatory and political developments.
With respect to Board of Directors oversight, our public policy efforts, including all lobbying activities, political contributions, and payments to trade associations and other tax-exempt organizations, are the responsibility of the Corporate Governance and Responsibility Committee (CGRC), which consists entirely of independent, non-employee directors. Each year the CGRC receives an annual report on the Company's policies and practices regarding political contributions. In addition, each year the Senior Vice President of Global Government Relations reports to the CGRC on trade association memberships and to the full Board of Directors on our global lobbying and government relations program. The CGRC's oversight of our political activities ensures compliance with applicable law and alignment with our policies, strategic priorities and our Code of Business Conduct.
In 2020, we established an Advisory Board of leaders representing a cross-section of Honeywell who meet regularly to review proposed HIPAC disbursements to elected officials to assess alignment with Honeywell’s foundational principles—Integrity and Compliance, Inclusion and Diversity, and Respect. In 2022, the Company expanded the Advisory Board’s mandate to include assessment of alignment with the Company’s sustainability goals and review of proposed disbursements of corporate and HIPAC funds to trade associations and other organizations. Neither the CEO nor anyone from his staff sits on the Advisory Board. The Advisory Board meets at the start of each Congress, and at least quarterly thereafter, to determine whether proposed recipients of HIPAC funding are eligible based on alignment with our foundational values. Advisory Board decisions are documented and reported quarterly to the HIPAC Board of Directors and to Honeywell’s Chairman and CEO. Honeywell’s Senior Vice President, Global Government Relations also includes notable Advisory Board decisions in his annual report to the Corporate Governance and Responsibility Committee (CGRC) of the Honeywell Board of Directors.
We have not made any political contributions using corporate funds since at least 2009 and have no intention of making such political contributions in the near future. We do not use corporate funds to make independent political expenditures in direct support of or opposition to a campaign.
Any and all contributions we make in support of federal and state political candidates, party committees and to support or oppose ballot initiatives are through the non-partisan Honeywell International Political Action Committee (HIPAC), which is funded exclusively through voluntary contributions from eligible U.S.-based employees. These contributions are not reimbursed by Honeywell. The PAC is subject to oversight by its board of directors, which includes the Senior Vice President and General Counsel and the Senior Vice President of Government Relations, and is fully compliant with federal, state and local regulations and disclosures.
With respect to tax-exempt organizations, such as those classified as a 501(c)(4)s, that can use funds for political purposes, Honeywell participation is typically funded by the PAC. No corporate contributions to such 501(c)(4) organizations were made in 2019.
Any use of corporate funds for political contributions requires approval from the company's Senior Vice President and General Counsel. These policies on political contributions are embedded in our Corporate Governance Guidelines and Code of Business Conduct.
We are a member of a number of 501(c)(6) trade associations that may engage in political activity. The trade associations to which we belong represent a broad range of perspectives on public policy issues, not all of which we support. Our membership in these organizations is intended to accomplish a wide of range of objectives:
- Support our commercial growth initiatives where we believe engaging in coalitions with other industry participants is likely to enable growth of end markets;
- Promote development of our internal technical and regulatory expertise as well as enable us to share with other companies our technical and regulatory expertise; and
- Assist in political advocacy and outreach, particularly related to public education efforts regarding major issues common to our industries.
Honeywell’s Senior Vice President and General Counsel and Senior Vice President of Global Government Relations review trade association memberships annually to assess their performance and to determine if continued membership is appropriate.
We engage with our trade associations on policy tracking and advocacy on a range of issues including: aerospace and defense, aviation regulations, chemicals, civil justice reform, climate change, codes and standards, corporate governance, cybersecurity, data privacy, energy, environmental regulation, export controls, immigration, infrastructure, labor, legal reform, oil and gas/petrochemicals, regulatory reform, safety, tax, trade and transportation.
Membership in trade associations requires that we pay regular dues. Some trade associations utilize a portion of membership dues for non-deductible state and federal lobbying and political expenditures. Membership in trade associations that would receive more than $50,000 in membership dues from Honeywell in any fiscal year is subject to prior approval by the Company's Senior Vice President and General Counsel and its Senior Vice President of Global Government Relations and reviewed at least annually with the Corporate Governance and Responsibility Committee. Honeywell instructs these organizations not to use funds received from Honeywell for any election-related activity at the federal, state or local levels, including contributions or expenditures in support of, or opposition to, any candidate for any office, ballot initiative campaign, political party, committee or Political Action Committee. Honeywell informs these organizations of this policy upon becoming a member and annually thereafter. Honeywell does not make additional, non-dues contributions to these organizations to support the organization’s political activities.
Currently, the aggregate amount of dues paid to trade associations receiving membership dues of $50,000 or more from Honeywell is less than $3.5 million annually. Honeywell is a member of 16 U.S. trade associations that receive membership dues of $50,000 or greater from Honeywell annually.
Some trade associations utilize a portion of membership dues for non-deductible purposes, such as lobbying. These associations provide Honeywell an estimate of the amount of our membership dues they use for non-deductible purposes.
Here is a list of the trade associations receiving membership dues of $50,000 or greater from Honeywell annually, and the corresponding non-deductible portion of the dues.
In 2022, using independently-prepared summaries of public positions taken these trade associations, Honeywell reviewed all trade associations with annual membership dues of $50,000 or greater to assess alignment with Honeywell’s sustainability objectives. The results of that report can be found here. Going forward, under the expanded role of the Advisory Board, all trade associations with annual membership dues of $50,000 or greater will be reviewed using the same process as applied to elected officials to ensure alignment with Honeywell’s foundational principles and sustainability goals.
As noted above, we have not made any political contributions using corporate funds since at least 2009 and have no intention of making such political contributions in the near future. Any and all contributions we make in support of federal and state political candidates is through the non-partisan Honeywell International Political Action Committee (HIPAC), which is funded exclusively through voluntary contributions from eligible U.S.-based employees, which are not reimbursed by Honeywell. Proposals regarding use of HIPAC funds are made by a HIPAC Executive Committee, consisting of senior managers representing Corporate and each of the Company's operating segments, which meets quarterly to discuss how HIPAC's political disbursements can promote the strategic business interests of the Company and U.S. economic growth.
Following the events that took place in Washington, DC on January 6, 2021, the Advisory Board determined that it would further evaluate recipients of proposed disbursements on criteria that include a demonstrated commitment to bipartisanship and upholding the democratic process.
Political disbursements made through HIPAC are made without regard to the personal partisan preferences of Company officers and executives. HIPAC spending decisions are made solely to promote the strategic business interests of Honeywell and are based on the following criteria: Honeywell's employee, supplier and/or customer base in legislators' districts/states; support for Honeywell's initiatives; leadership positions in the U.S. Congress or state legislatures; and, leadership positions on legislative committees that are relevant to Honeywell's businesses.
The Company retains outside auditors to conduct periodic audits of HIPAC practices and procedures.
All of the disbursements made by HIPAC in 2019 to federal, state, and local candidates and organizations, may be found in our HIPAC Disbursements Summary Report. This same information is in our reports filed with the Federal Election Commission (FEC); see instructions below.
Monthly reports filed with the FEC for prior periods can be accessed on the FEC’s website www.fec.gov.
Federal disclosures regarding our lobbying activities are publicly available. Our public disclosure includes, among other things, our aggregate annual spending on trade association membership dues spent on lobbying or political expenditures as well as HIPAC contributions to political candidates. Since 2011, information regarding these topics has been disclosed on this website, and the Company maintains an archive of this information, as well as information subsequently made available on this website. Disclosures from prior periods can be accessed via the links below.
- With respect to federal lobbying activity, we maintain and file Lobbying Disclosure Act Registration and Reports (Form LD-2) with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives, which reflect the particular bills and issues on which individual lobbyists had activity, as well as the total lobbying expenses incurred during each calendar quarter. Forms LD-2 for 2015, 2016, 2017, 2018, 2019, 2020, and 2021 each of which includes the aggregate amount of the company's spending on lobbying by calendar quarter, including trade association memberships. Reports for prior periods may be found on the Secretary of the U.S. Senate’s website.
- Honeywell and its registered federal lobbyists must also file semi-annual reports (Form LD-203) providing, among other things, HIPAC disbursements and personal, direct contributions to federal candidates. Forms LD-203 for 2015, 2016, 2017, 2018, 2019 , 2020, and 2021. Reports for prior periods may be found Secretary of the U.S. Senate’s website .
Honeywell reports lobbying activities to several states and localities. To view Honeywell’s state and local lobbying disclosures, click on the states highlighted in blue below. This will provide you either with a copy of the most recent report or with a link to the jurisdiction’s lobbying disclosure website. In jurisdictions where a direct link is not available, please search “Honeywell” to locate the report.
|State||2021 Reported Expenses1||2022 Searchable Website||2022 Company Linked Website|
|Los Angeles, California||$120,404.00||Los Angeles|
|Miami-Dade County Public Schools, Florida||$0.002||Miami-Dade Co Public Schools|
|Orange County Public Schools, Florida||$0.002||Orange County Public Schools|
|New Jersey||$197,919.35||New Jersey|
|New York||$45,000.00||New York|
|North Carolina||$33,036.00||North Carolina|
1This figure does not include political contributions.
2Lobbyist compensation is not reported in this jurisdiction.
3In-house lobbyists are not required to file reports.
4Predicted salary is reported in a range on the lobbyist's registration and is included here.
5Contract lobbyist expenditures are not attributed to a particular client on the reports and are therefore not included in this amount.
6The applicable reporting period is November 1, 2020, through October 31, 2021.
7Compensation and/or expenses are reported according to a range set by the state.
8The applicable reporting period is May 1, 2020, through April 30, 2021.
9Where states report expenses in a range, the highest end of the range is included in this figure.
© Prepared by State and Federal Communications, Inc. 2/28/2022