About Altria Moving Beyond Smoking Responsibility Investors People & Careers Media Compliance & Oversight Our participation in political and public policy processes is subject to an extensive framework of laws, regulations, public disclosure, company policies and internal controls, including active oversight by Altria’s Board of Directors and senior management and regular internal audits. We maintain a robust political activity compliance and integrity program that comprehensively addresses our companies’ political and public policy activities. This program is based upon our Code of Conduct, which outlines key risk areas and the principles that should guide employees’ actions. Our political activity compliance and integrity program incorporates best practices and includes detailed policies and procedures to comply with the laws related to these public policy activities. Our rigorous internal controls and decision-making processes comprehensively address potential legal and reputational risks that could arise from our lobbying and political activities. Additionally, we systematically review both our political activity compliance program and our companies’ political activities, which has resulted in Altria Group being recognized as a leader for its commitment to political transparency and accountability. Management Oversight Because it is important that the diverse interests of our businesses and employees are considered by policy makers, Altria and its companies believe it is important to actively participate in the public policy process. However, we know such activities require proper oversight, including by our senior executives. The Senior Vice President of Government Affairs and Public Policy, who reports directly to Altria's CEO, leads the Government Affairs Department and oversees all of our legislative, political, and public policy activities. Each year, legislators introduce hundreds of legislative proposals that are important to our businesses and our stakeholders. The Government Affairs Department is responsible for engaging with federal, state, and local government officials regarding issues of concern to Altria, its employees, its shareholders, retailers, wholesalers, adult consumers, and many other stakeholders. More information regarding the issues Altria engages on can be found here. The Government Affairs Department includes Federal Government Affairs, State and Local Government Affairs, and Government Affairs and Public Policy, each of which is led by a vice president. The Senior Vice President of Government Affairs and Public Policy and the Government Affairs vice presidents work with the leaders of Altria's companies to develop our companies' public policy priorities and then implement and manage our lobbying, political, and public policy activities in support of these priorities. Additionally, these Government Affairs executives meet regularly with Altria's leadership team and other company leaders to discuss legislative, political, and public policy developments, ensuring that senior executives throughout Altria's companies are aware of Altria’s lobbying, political and public policy activities, providing additional oversight of these activities. As part of his oversight responsibilities, the Senior Vice President of Government Affairs and Public Policy works closely with Altria's CEO, the Law Department, and the Compliance & Integrity Department to ensure Altria's robust political activity compliance and integrity program systematically addresses our companies' political and public policy activities and to assess any reputational risks that may arise from such activities. Additionally, the Senior Vice President of Government Affairs and Public Policy provides the Altria Board of Directors and its Nominating, Corporate Governance and Social Responsibility Committee updates on the companies’ public policy activities. More information on those updates are provided in the Board Oversight section below. Board Oversight The use of company resources for political and public policy activities can be an important issue for shareholders and warrants strong governance and oversight both by senior executives and corporate directors. Consistent with our principles of good governance and high standards for ethical conduct, the Altria Board of Directors' Nominating, Corporate Governance and Social Responsibility Committee, which is comprised solely of independent directors, actively oversees our participation in the political and public policy processes and the political activity compliance and integrity program. Specifically, our companies provide updates on political and public policy issues as well as our legislative, political and regulatory engagements to the committee, including the companies' direct and indirect lobbying activities. Our companies also regularly update the committee regarding contributions to organizations involved in the public policy arena, including trade associations and other tax-exempt organizations. These updates — which may be made to either the full Altria Board of Directors or the Nominating, Corporate Governance and Social Responsibility Committee — occur a minimum of three times each year and are provided by senior Altria executives. Our updates provide the Altria directors information that allows them to exercise meaningful and robust oversight of our political and public policy activities. In addition, Altria shares extensive information about its participation in these areas on our website so shareholders and others can learn more about our political and public policy activities. Policies & Procedures Guiding our Involvement in the Public Policy Process There are many laws and regulations that govern a company’s public policy engagements, including laws that regulate direct lobbying, grassroots advocacy and other interactions with government officials. Altria and its companies are committed to complying with such laws and have established specific controls and oversight mechanisms for our activities. Our policies and procedures apply to interactions with government officials, including both direct and grassroots lobbying activities, as well as our support of third-party organizations such as trade associations and other membership organizations. Our comprehensive political activity compliance policies and procedures are designed to enable Altria and its companies to participate in the public policy process in ways that enhance shareholder value, are consistent with our Vision and Our Cultural Aspiration, and do not create potential legal or reputational risks for our companies. Among many important requirements, our policies prohibit employees from: engaging in the direct lobbying of government officials without approval from both the Altria Client Services (ALCS) Law department and the ALCS Government Affairs department; engaging in grassroots activities without approval from both the ALCS Law department and the ALCS Government Affairs department; and providing corporate contributions to non-profit organizations that are engaged in lobbying or political activities, including trade associations, without receiving the proper review and approval by the ALCS Law department. Policies & Procedures Guiding our Involvement in the Political Process Our companies may make corporate political contributions in the U.S. where permitted by law and company policy. Since 1978 our companies’ political action committee (PAC), which is now known as AltriaPAC has enabled employees and shareholders to pool their political contributions to support candidates who understand the legislative and regulatory issues important to our companies. Federal, state, and local laws impose significant restrictions on the political activities of corporations and their PACs. Altria’s companies have comprehensive policies and procedures to provide direction to employees who engage in the political process. These policies prohibit employees from: providing political contributions in anticipation of, in recognition of, or in return for an official act; seeking or receiving direct or indirect reimbursements for personal political contributions or expenses; pressuring or coercing fellow employees to make personal political contributions; and rewarding another employee or making employment decisions based in whole or in part on that employee’s personal political contributions. Approval Process for Political Contributions Every proposed political contribution must be legally permissible and in the best interests of the company making the contribution and our shareholders. Altria uses several guiding principles when selecting which candidates or committees receive PAC or corporate political contributions, including whether they: Share an interest in understanding our business and issues critical to their success; Share a philosophy consistent with our Vision and our Cultural Aspirations – the Altria Way; Demonstrate a commitment to governance, participating collaboratively in the democratic process, and constructive dialogue regardless of political philosophy; Have constituent relationships with Altria facilities in their district or state; Serve on a legislative committee with jurisdiction over issues of interest to Altria Group, Inc. and its companies; Are a member of congressional or state legislative leadership; and Facilitate engagement opportunities and build relationships with diverse candidates in support of our goals of Inclusion, Diversity, & Equity. PAC or corporate political contributions are made without regard to the private political preferences of any employee. Each corporate political contribution made by Altria Group and its companies requires written advance approval from: the relevant State Government Affairs Regional Director; the Vice President for State Government Affairs; the Senior Vice President for Government Affairs and Public Policy; and a Senior Assistant General Counsel in the Altria Client Services (ALCS) Law Department. Contributions over $100,000 require the written approval of Altria’s General Counsel or his or her designee. The AltriaPAC Board of Directors approve each PAC contribution. The Directors are employees of the Altria family of companies. Altria conducts regular trainings, compliance system reviews, and internal audits to ensure all PAC and corporate political contributions are made in accordance with the law and company policies. Leadership Altria is recognized as a leader in political activities disclosure by many entities, including the Center for Political Accountability-Zicklin Index of Corporate Political Accountability and Disclosure (CPA-Zicklin Index). In 2020, the CPA-Zicklin Index ranked Altria 4th among the S&P 500 in terms of the voluntary disclosures of its political spending and designated the company as a "trendsetter" in this area, for the fifth consecutive year. We also are active members of the Conference Board’s Committee on Corporate Political Spending, a committee of corporations dedicated to accountability, education and engagement on issues of political activity. Through our work with the Committee on Corporate Political Spending and through other constructive engagements, we hope to provide leadership on these issues within the broader corporate community. Learn more about the Committee on Corporate Political Spending. Operating Companies Philip Morris USA U.S. Smokeless Tobacco Co. 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