Political Process Commitments & Contributions
In addition to Travelers Institute activities, Travelers directly engages in the public policymaking process through the Travelers Government Relations team. Given that Travelers operates in a highly regulated and competitive industry, it is important for the company to evaluate and appropriately engage at both the state and federal levels. We believe our active participation in the political process is in the best interest of our shareholders, our employees and the communities in which we conduct business.
Our Government Relations staff gather input from various business lines, senior management and our Legal staff when analyzing public policy issues and lobbying priorities. Many of the issues we focus on – such as insurance regulation, regulatory modernization, catastrophe and terrorism risk insurance, and tort and class action reform – have a direct impact on the availability and pricing of the products and services we provide to our customers and on the performance of our businesses.
Travelers is committed to participating in the political process in a transparent, thoughtful and responsible manner, consistent with the company’s Code of Business Conduct and Ethics and in compliance with all applicable legal requirements. Our policy titled Commitment to Participation in the Political Process, which has been approved by our senior management, outlines our approach to participation in the political process and discusses Board and management oversight of such participation. We annually review and, as appropriate, update our political activity policy.
Highlights of our current policies and practices with regard to political campaign contributions and expenditures and lobbying activity include the following:
Board Oversight and Governance around Political Activities
Travelers conducts its political activities, including lobbying, under the oversight of the Nominating and Governance Committee of the Board, which is composed solely of independent directors. Our Head of Government Relations and General Counsel review all corporate political campaign contributions and expenditures, as well as all dues and other payments made to relevant trade associations and other organizations. Lobbying activities on behalf of Travelers require prior approval of the company’s Government Relations professionals. Further, the Head of Government Relations reports semiannually to the Nominating and Governance Committee of the Board regarding political contributions and expenditures made by Travelers, including dues and other payments made to relevant trade associations and other organizations, lobbying activities and public policy issues of priority to Travelers. In addition, the Nominating and Governance Committee oversees our policy regarding political activities and any changes to that policy. The Nominating and Governance Committee provides the full Board with a report on the company’s political activities at least twice per year.
As noted above, the Nominating and Governance Committee’s oversight of political activities includes the company’s membership in, and other support of, trade associations and other organizations. Our Government Relations staff and trade association colleagues promote and advance our position on issues having a direct or indirect impact on our business. Our membership in a particular trade association does not suggest that we agree with such association’s position on every issue, nor does it suggest that Travelers joined such association primarily due to its lobbying activities.
No Corporate Contributions to Federal Candidates or Political Party Committees
In accordance with current applicable law, political contributions to federal candidates and federal political party committees may not be, and are not, made by Travelers. Such contributions may be made by our political action committee, The Travelers Companies, Inc. Political Action Committee (T-PAC), which is not funded by corporate funds, but rather by the personal funds given voluntarily by our employees. T-PAC’s Contributions Committee, whose objective is to advance the best interests of Travelers and its shareholders, makes decisions concerning the use of those funds. T-PAC reports this spending in filings with the Federal Election Commission, which are publicly available.
Disclosure of Political Contributions
Our participation in the political process is governed by law, in addition to internal policy. Travelers complies with all applicable laws and regulations pertaining to political campaign contributions at the federal, state and local levels, including those requiring specific disclosures.
These extensive disclosures required by applicable laws and regulations provide further transparency and public access to information regarding the scope of our political involvement.
Pursuant to our current political activity policy and based in part on shareholder input, Travelers discloses, semiannually in political contributions reports on our website, corporate contributions to state and local candidates, candidate campaign committees and other political entities organized under 26 USC § 527. In our political contributions reports, we also provide a link to the Federal Election Commission website containing reports filed on behalf of T-PAC.
We also file federal lobbying reports under the Lobbying Disclosure Act and periodic (e.g., monthly, quarterly, semiannual) state lobbying reports under the relevant state lobbying laws. Such filings not only disclose lobbying costs but also specifically identify the issues and government entities lobbied.
No Direct Independent Expenditures
Travelers has not made any direct independent expenditures, at either the federal or state level, and does not have any plans to do so during the current election cycle. Direct independent expenditures, if any, would consist of funds spent by Travelers itself on communications in support of, or in opposition to, a candidate’s campaign, without coordination with the candidate. Our political activity policy provides that Travelers may not make direct independent expenditures in a candidate campaign unless, and only if, it believes that an exception to that policy is justified by business need and it obtains the prior approval of the Nominating and Governance Committee or its Chair. If any such direct independent expenditures are made, Travelers would disclose them on its website in the same manner and at the same time as it discloses campaign contributions.
No Grassroots Lobbying or Payments to Tax-Exempt Organizations That Endorse Model Legislation
Travelers currently does not engage in grassroots lobbying and did not make any payments in 2022 to influence the outcome of ballot measures. Travelers is currently not a member in, nor does it make payments1 to, any tax-exempt organization that writes and endorses model legislation.
Participation in Trade Associations
Travelers joins trade associations and similar organizations to further its commercial interests, educate its employees or enhance its ability to serve customers. Travelers’ membership in a particular trade association does not suggest that it agrees with such association’s position on every issue, nor does it suggest that Travelers joined such association primarily due to its lobbying activities. Importantly, trade associations operate on an independent basis. Disclosure of Travelers’ membership in, or other support of, trade associations may not – and often does not – represent Travelers’ lobbying activity or policy positions.
On an annual basis, Travelers discloses on its website the lobbying allocation for trade associations and/or social welfare organizations to which it pays dues of $25,000 or more.
1 Travelers pays registration fees for employees to attend meetings of the National Association of Insurance Commissioners and the National Council of Insurance Legislators.