Political Contributions
Northrop Grumman Corporation, a leading provider of solutions that protect our national security, is also engaged in the democratic process to elect leaders and participate in the political environment at the federal, state and local level. In keeping with our principles of good governance and the highest standard of ethics, the processes for direct corporate contributions, political action committee contributions and membership in trade associations are subject to detailed oversight by the corporation.
- Policy Regarding Independent Expenditures that Advocate the Election or Defeat of Federal Candidates
Employee Political Action Committee
Employees of Northrop Grumman Corporation meeting certain FEC eligibility requirements can voluntarily join the company’s political action committee, Employees of Northrop Grumman Political Action Committee ("ENGPAC" or "the PAC"). In addition to supporting the federal election campaigns of congressional candidates, ENGPAC supports national political organizations and leadership Political Action Committees. Participation in ENGPAC offers our employees the opportunity to pool their resources to support candidates for office who are supportive of national security. ENGPAC contributions are made on a bi-cameral and bipartisan basis. PAC membership is both voluntary and disclosed inside the corporation only to those involved in PAC administration.
The PAC is administered by the corporation's Government Relations department. All PAC expenditures and contributions are made following an internal review process in our corporate Government Relations office. To ensure compliance with all applicable election laws and regulations, robust internal controls are in place and an external firm acts as a final review before any contribution is made using ENGPAC funds.
2011 ENGPAC 
Federal Campaign Contributions
Direct Political Contributions
At the state and local level, the Company has concluded that as a matter of policy, it will not make any direct contributions to candidates or their political action committees. The Company makes contributions to national-level gubernatorial associations to help ensure that its perspective is represented on matters of state and local policy. In 2011, Northrop Grumman contributed to three organizations that are classified under the Internal Revenue Code as section 527 organizations. These are the Democratic Governors Association, the Republican Governors Association and the Southern Governors Association. Contributions were made in the following amounts to these organizations, respectively, in 2011: $85,000; $50,000; and $15,000.
Policy Regarding Independent Expenditures that Advocate the Election or Defeat of Federal Candidates
The U.S. Supreme Court determined in 2010 that corporations may make unlimited expenditures for independent communications to the general public that expressly advocate the election or defeat of a clearly identified federal candidate.
Northrop Grumman has no plans to spend corporate funds directly on such communications.
Should a future situation warrant Northrop Grumman's participation in independent expenditures that expressly advocate the election or defeat of a clearly identified federal candidate, the decision would require approval of the Policy Committee of the Northrop Grumman Board of Directors; would be consistent with the interests of Northrop Grumman’s shareowners; and would conform to applicable laws.
Northrop Grumman would be fully transparent with its disclosure of these expenditures, as it is with other political expenditures. This includes making all legally required filings, including with the Federal Election Commission, as well as disclosing the expenditures on our external website. Such independent expenditures would receive the same scrutiny as all of Northrop Grumman’s other corporate political expenditures, which includes an annual update with the Policy Committee of the Board of Directors on its political action committee and direct corporate political contributions and review of its political expenditure program on an annual basis.