Policy for corporate political contributions

As a large, diversified financial services company, Principal Financial Group, Inc.^® (Principal) and its subsidiary and affiliate companies are regulated by international, federal, state, and local laws. These laws have a significant effect on how the company operates, meets customers’ needs, and delivers long-term value to shareholders. The management team and the Board of Directors of Principal think it is in the best interest of the company to be active in the legislative and election processes, consistent with the highest ethical standards of corporate governance practices and all applicable laws.

Principal engages with international, federal, state, and local governments to help shape policies and regulations that not only impact how the company does business, but also its customers, shareholders, employees, and the communities we live in. Under the direction of Government Relations, the company is actively involved in lobbying activities at the international, federal, state and local levels including grassroots initiatives and involvement of senior management with key decision makers.

Contributions directly made to candidates’ campaigns for office are only made by our political action committees, PrinPAC and Principal S PAC (collectively “PACs”). Eligible employees donate money to the PACs, which in turn make direct candidate campaign contributions. All PrinPAC and Principal S PAC funds are voluntary donations from exempt employees, select agents, or retirees.

Expenditures by Principal to expressly advocate the election or defeat of candidates for public office are prohibited. Corporate contributions to any organization for other political purposes are prohibited except in very extraordinary and limited circumstances. Such contributions must:

Be made consistent with all applicable laws;
Promote the interests of the company;
Be made without regard for the private political preferences of executives of the company; and
Be publicly disclosed on the company website.

Further, any corporate contributions for allowed political purposes may be made only after review and approval as follows:

Government Relations must submit a report to the Chairman, Chief Executive Officer, and General Counsel of Principal detailing the proposed use of corporate funds for political purposes;
The Chairman, Chief Executive Officer, and General Counsel must approve the request for funds; and
A committee of the Board of Directors of Principal must approve the proposed use of any corporate funds for political purposes. The Board of Directors designates this committee and must be informed of any such action.

For the purposes of this policy, contributions for “political purposes” shall include: (i) contributions personally solicited by an elected or appointed public official or by others on their behalf and (ii) contributions for programs named for, dedicated to, or directed by an elected or appointed public official. Contributions for “political purposes” shall not include contributions of $10,000 or less to 501(c)(3) organizations with established charitable, non-profit missions where an elected or appointed official and/or a member of the official’s staff is a board member or is an honoree or attendee at a fundraising event. Contributions to 527 organizations which support or oppose candidates for office are expressly prohibited.

Principal will be prudent in the use of corporate funds for political purposes. With any request for contributions for political purposes, we will analyze the impact these contributions may have on our business, employees, shareholders, and the customers we serve.