Northrop Grumman Corporation is engaged in the democratic process at the federal, state and local levels, including expressing its views on important public policy issues. All political activities are in accordance with all applicable laws and are consistent with our principles of good governance and the highest standard of ethics. All political activities, including financial contributions, are made in support of company objectives. They are not based on the personal preferences of individual employees, executives, or board members.
Governance and Reporting
The company’s political activities are managed by the Chief Strategy and Development Officer, who reports directly to the Chief Executive Officer. In addition, the Policy Committee of the Northrop Grumman Board of Directors reviews and monitors the company’s political activities, including government relations strategy and the manner in which activities are conducted. This includes governance and compliance of the political action committee, the company’s policies and practices with respect to political contributions, and the company’s government relations activities, including lobbying. The Policy Committee receives regular reports on political activities.
Northrop Grumman files quarterly lobbying disclosure reports with the United States Congress, which are available here. The company files similar reports where required at the state level.
Northrop Grumman does not make contributions from corporate funds to candidates for state, local, or federal office or to political parties. The company also does not make any contributions from corporate funds to organizations classified under the Internal Revenue Code as section 527 entities or to any Super PACs, ballot initiatives, electioneering communications, or for independent political expenditures.
Should a future situation warrant the use of corporate funds for any of these activities, the decision would require Board approval, would have to be consistent with the interests of Northrop Grumman’s shareholders, and would have to conform to applicable laws. Northrop Grumman would be 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 Elections Commission (FEC), as well as disclosing any corporate political expenditures on this website on an annual basis.
Corporate contributions to federal candidates are prohibited by federal law, and accordingly, Northrop Grumman makes no such contributions. While the company generally refrains from contributing to 501(c)4 organizations, it does provide financial support to the Human Rights Campaign and the National Defense Information Sharing and Analysis Center.
Employee Political Action Committee
The Employees of Northrop Grumman Political Action Committee (ENGPAC) is a voluntary, nonpartisan political action committee established by Northrop Grumman in accordance with federal law. ENGPAC is governed by a Steering Committee comprised of company executives and is funded solely from the voluntary personal contributions it receives from eligible employees.
ENGPAC may provide contributions to the campaigns of candidates seeking federal offices, as well as selected state and local campaigns, national political organizations, and other political action committees. ENGPAC contributions are made under the supervision of the Chief Strategy and Development Officer in compliance with all applicable laws and regulations. All political expenditures made by ENGPAC are disclosed to the FEC and available here.
ENGPAC contributions are made without regard to party affiliation and based on a candidate’s policy positions on issues of importance to the aerospace and defense industry and to the company and its shareholders. The Policy Committee reviews ENGPAC’s operations annually.