Political Contributions

One facet of our advocacy is political contributions to elected officials. CSX supports candidates from across the political spectrum who generally advocate for our company’s competitive growth and key business objectives A direct campaign donation to an individual running for office constitutes a political contribution. The term political contribution also includes anything of value provided with the intention or reasonable expectation that it will be used to influence a federal, state, or local election. Recipients may include candidates running for federal, state, or local office, as well as political parties, political committees, ballot measure committees, 527 political organizations, 501(c)(4) non-profit organizations, or 501(c)(6) trade associations.

Political Contributions can be either monetary or in kind, such as goods, services, use of facilities, or anything else of value provided at no cost or at a discounted rate. As guidance, regular membership fees, such as dues paid to 527 political organizations, 501(c)(4) non-profit organizations, or 501(c)(6) trade associations are not considered political contributions unless they are specifically set aside for political purposes. Additionally, the purchase of tickets to an inaugural event, such as an inaugural dinner, would not be considered a political contribution, as it does not serve to influence the outcome of an election.

The CSX Government & Community Affairs team applies high ethical standards and judgement to each contribution made directly from CSX or through our established separate employee political action committee (PAC) known as the CSX Good Government Fund (CSX GGF). The GGF is a segregated account registered with the Federal Election Commission and is voluntary for eligible CSX employees. CSX records all state and federal candidate donations with the required agencies. CSX uses an independent external vendor to request checks for political donations which require supervisor approvals and quarterly internal reviews on compliance and process. A listing of CSX’s political contributions can be found at Political Contributions.

CSX works with external associations or advocacy organizations (501 c 4 (501 c 6), (527) in furtherance of its pursuit of good policy. These include chambers of commerce, governors’ associations, and railroad-related advocacy organizations. CSX policy positions may not wholly overlap with those of the external organizations we support, however, we reasonably observe overall engagement of these organizations. We also regularly make public a full record of the organizations CSX supports. A full list of these organizations can be found at Political Contributions.

CSX also supports political organizations or caucuses at the state and federal level. Each jurisdiction is subject to certain political contribution which CSX adheres to and publicly discloses.

CSX has a robust governance process around its political giving and government affairs. The CSX Government and Community Affairs team leads and coordinates decisions regarding political contributions made by CSX and the CSX GGF. Additional governance measures include:

• CSX’s Chief Legal Officer (the “CLO”) and CSX’s Governance and Sustainability Committee of the Board of Directors (the “Committee”) must approve any donation in excess of $50,000 to any individual candidate, political organization, convention sponsorship, or political caucus.
• The CLO and the Committee must be notified if CSX’s total accumulated political donations exceed $600,000 in a single calendar year (dues to 527 political organizations, 501(c)(4) non-profit organizations, or 501(c)(6) trade associations are not included in this sum).
• The CSX GGF is directly overseen by the CSX Good Government Fund Board which has its own bylaws and is comprised of a cross section of company-wide employees. In making such decisions, CSX shall only make Political Contributions that further the interests of CSX and shall comply with the provisions contained in this Policy.
• CSX occasionally supports a state ballot initiative but can only do so after prior written approval from the CLO and Vice President of Government Affairs. At least once a year, participation in state ballot initiatives should be reported to the CSX Board of Directors.
• CSX does not make contributions to ‘Super PAC’ or ‘Dark Money’ organizations.

The CSX Government and Community Affairs team shall be compliant with lobbyist registration and reporting at the local, state, and federal level and shall be the primary point of contact on all lobbying related activities.

CSX Government and Community Affairs team members will certify in writing on an annual basis to the Vice President of Government Affairs that they are aware of CSX’s Political Giving and Advocacy Policy and are compliant with lobbyist certifications in the jurisdictions of their responsibilities. The Vice President of Government Affairs shall be responsible for an annual policy review with members of the CSX Government and Community Affairs team. Non-compliance of this policy will be addressed pursuant to CSX disciplinary practices and other actions which CSX deems appropriate.