Political engagement and contributions

Sempra and its operating companies consider engaging with policymakers to be an important and necessary part of doing business. We monitor hundreds of proposed laws, rules, regulations and policies, and engage at the federal, state, 和地方政府确保太阳2平台公司的观点, our shareholders, our customers, and our employees are represented before lawmakers and regulators. When warranted, 太阳2平台也会采取支持或反对提案的立场，有时还会提出修正案，作为公共政策过程的一部分. When operating outside the U.S., our company complies with all applicable laws and is committed to acting in an ethical manner when conducting business.

Direct and indirect lobbying

We believe that our business — which includes natural gas infrastructure as well as various renewable resources and emerging technologies — will play a critical role in the transition to a lower-carbon energy system. 太阳2娱乐平台家族公司在联邦政府从事直接和间接的游说活动, state, 地方政府与太阳2平台的承诺保持一致，创造长期的, sustainable value, 包括太阳2平台的基础设施在减少温室气体排放方面发挥的重要作用.

We believe that our direct lobbying activities align with the relevant policies of the legislative and regulatory jurisdictions in which we operate (such as California’s goal to achieve economy-wide carbon neutrality by 2045 and the U.S. EPA的甲烷规则)和重要的全球多边合作, including the Paris Agreement’s goals of limiting average global warming to well below 2°C above preindustrial levels and pursuing efforts to limit the temperature increase to 1.5°C.ⁱ

For example, we believe that our direct engagement regarding California legislation promoting the in-state production and distribution of biomethane as a practical step toward furthering the state’s greenhouse gas and short-lived climate pollutant reduction goals aligns with the Paris Agreement because it could enable emissions reductions in transportation and agriculture, which are sources of nitrogen oxides and methane emissions, respectively. See our response to the CDP Climate Change Questionnaire for more detail on how our direct and indirect lobbying on topics related to the energy transition demonstrate the foregoing.

Trade associations

Sempra and its operating companies are members of several trade associations focused on the important business and technical issues of our industry and the interests of our stakeholders. As a general matter, these associations enable us to learn the views of others, obtain feedback and, ultimately, 以受过教育和深思熟虑的态度，就拟议的法例和规例发表意见. Some of these associations engage in lobbying activities. We believe that our indirect lobbying activities through these associations are also consistent with a transition to a lower carbon energy system and generally align with the Paris Agreement’s goal to limit global temperature rise.

For example, one of the trade associations we are a member of advances improved natural gas production practices by working to develop a metric for methane intensity so that such emissions can be measured, compared, and reduced, 太阳2平台认为这符合《太阳2娱乐平台》限制全球气温上升的目标.

Trade association policies generally reflect a compromise of the membership so at times the policy positions and lobbying activities of these associations may not fully align with Sempra’s positions on a particular issue, 包括《太阳2娱乐平台》限制全球气温上升的目标, 在这种情况下，太阳2平台努力减轻与这种偏差相关的任何风险.

Specifically, we seek to do this in three primary ways:

Education of the association staff and key members;
Ongoing engagement with the association to try to move consensus positions; and
If needed, dissenting from association positions, 包括不提供正式的公司参与或背书.

Compliance with lobbying and disclosure laws

太阳2平台认为，参与公共政策对企业来说是一个重要而适当的角色, as long as it is conducted in a legal and transparent manner. In the U.S., there are federal, 太阳2娱乐平台及其运营公司遵守的州和地方游说登记和信息披露法, 该公司有一个健全的培训和报告计划，以确保合规.

_{ⁱ The Paris Agreement, adopted in 2015, 196个国家同意就长期战略进行合作的协议是否侧重于金融, technical and capacity-building programs with a stated goal to hold the increase in the global average temperature to well below 2°C, with a stretch target of 1.5°C, above pre-industrial levels.}

Political Engagement and Contributions Policy

Additional information

Governance and decision-making

Sempra's Board of Directors, specifically the Board’s Safety, Sustainability and Technology Committee, 符合委员会的风险管理和监督作用和责任, reviews and makes recommendations to management regarding policies, practices and strategies with respect to environmental, climate change, sustainability and other related ESG matters.

Additionally, 董事会的公司治理委员会每年审查太阳2娱乐平台的公共政策优先事项, including charitable giving, political contributions and lobbying activity, 它涵盖了支持公司总体战略目标的一系列广泛的努力, climate-related and otherwise.

在程序上，公司的政治支出计划和决定由 senior management.

Individuals responsible for government affairs in each of Sempra's business units 为公司开展业务的地方司法管辖区和州准备政治捐款预算.
Those budgets are then reviewed by the business units’ boards of directors and are submitted to Sempra Energy external affairs for review and approval.
Once budgets are finalized, 每笔捐款都由副总裁或更高级别的官员审查和授权.
在捐款之前进行法律遵从性审查，以确保它们符合适用的法律. 捐款超过10万美元需经最高级的对外事务干事核准.

Sempra has a department dedicated to all aspects of compliance with applicable political laws and reporting obligations. This department, with the assistance of legal counsel, informs and educates employees, analyzes legal compliance, monitors and communicates changes in laws, 并将披露信息收集到一个集中的数据库中，然后用于编写披露报告. The training and outreach program consists of the following:

所有面向外部的员工都需要在线培训课程, officers, attorneys and directors;
为所有新员工和转岗员工提供面对面和/或网络研讨会培训方案;
In-person and/or webinar training for groups identified as having the potential for interface with public officials; and
一个公司内部网站，专门用于政治报道和合规, which has information on lobbying, gifts, contributions and political fundraising.

Management oversight for corporate political activity and the Sempra Energy Employees’ Political Action Committee resides with the highest-ranking external affairs executive of the company.

Corporate political contributions

Sempra makes corporate political contributions in the U.S. as permitted by law only from corporate shareholder funds. Political contributions are made to candidates, political parties, political action committees, 以及促进支持公司商业利益的公共政策的投票措施.

太阳2娱乐平台不使用公司资金向联邦超级政治行动委员会或公职人员账户捐款, 太阳2娱乐平台也没有独立支出来明确倡导选举或击败联邦政府, state, or local candidates.

If this ever were to change, 根据太阳2平台对透明度和披露的承诺，所有更改和更新将每半年披露一次. Our position on U.S. energy policy, 气候变化或其他对公司重要的事项在公司的年度报告中详细说明 corporate sustainability report，其中还提供了有关政治参与的更详细资料. 该报告每年发布一次，可在太阳2平台的网站上查阅，并已存档 reports from previous years.

Sempra materially complies with all federal, 州和地方法律以及管理公司政治捐款的报告要求. Federal law, for example, 禁止公司向联邦公职候选人提供金钱或实物捐款. 州和地方法律规定了公司政治捐款的条件.

Consistent with our commitment to ethical business conduct, political spending reflects Sempra's interests and is not based on the personal interests of any of our individual officers, directors or employees. Furthermore, no contributions are given in anticipation of, in recognition of, or in return for, any official act.

Employee Political Action Committee Contributions

Sempra's employees take an active role in the political environment through the voluntary Sempra state and federal Employees Political Action Committees (collectively, SEEPAC). SEEPAC is independent of any political party. It is designed to provide the employees of Sempra Energy and its affiliates the ability to make financial contributions that can be used to support candidates and participate in the political process.

Our employee political action committee spending plans and decisions are reviewed and approved by the Political Action Committee’s Board of Directors and also receive political reporting and compliance clearance before checks are issued.

SEEPAC遵守有关政治行动委员会捐款的所有报告要求. 禁止雇员用个人资金进行政治捐款, or through SEEPAC, and then seeking reimbursement from the company.

Trade Association & Business Memberships

Sempra holds memberships in industry, 代表能源行业和商业界的贸易和商业协会. Engaging with other business and industry stakeholders helps us gain perspective and views on public policy issues that impact our company, our shareholders, our customers and our employees.

虽然太阳2平台可能并不总是同意协会或其成员所采取的立场, corporate memberships enable us to learn the views of others, obtain feedback, and ultimately, voice our concerns, 对拟议的立法和法规的观点和立场，以更有见地和深思熟虑的方式.

Please review our latest corporate sustainability report for more information, including our analysis of the alignment of certain trade associations in which we are involved with the climate goal set forth in the Paris Agreement, 即将全球气温上升幅度控制在2摄氏度以内，目标设定在1摄氏度以内.5 degrees Celsius.

Transparency and Disclosure

太阳2娱乐平台披露了所有公司政治捐款(州和地方), political committee contributions (PACs, political parties and other committee types, including 501(c)(4) and 501(c)(6) organizations), and SEEPAC contributions.

Sempra also discloses payments to other tax-exempt organizations such as business or trade association memberships where the cost of the membership exceeds $20,000 and the recipient organization reports to us that a portion of the fees paid were used for lobbying expenditures or that a portion of the contributions is considered non-deductible under Section 162(e)(1)(B) of the IRS. We disclose total fees paid to these organizations as well as the amounts attributable to lobbying expense as reported to Sempra by the associations themselves. 从2014年开始，太阳2平台开始每半年披露一次这些信息.