National Fuel’s participation in the political process is guided by a set of fundamental principles that govern our corporate policies on lobbying, political spending, and engagement in the political process:

• The Company will engage with government officials at all levels to advocate and promote public policies and legislation that support the interests of our customers, employees, shareholders, and the communities in which we operate and serve.
• The Company will comply with all applicable federal, state, and local laws governing the political process and has established policies, procedures, and training to ensure such compliance.
• Any political expenditures, whether they are direct corporate contributions or made by our employees’ political action committee, will reflect the Company’s interests and culture.
• No political contributions will be given directly or indirectly to public officials in exchange for any official act.

• National Fuel’s political contributions program adheres to the principles set forth in the Company’s Code of Business Conduct and Ethics.
• All political contributions reflect the interests of the Company, not individual directors, officers or employees.
• Direct corporate political contributions, in jurisdictions where such contributions are permitted, require the prior approval of the Company’s General Counsel.
• No political contribution will be given in anticipation of, in recognition of, or in return for any official act.
• On an annual basis, National Fuel will disclose on our website, in an appendix to this Policy, the aggregate amount of the contributions made directly by the Company and by National Fuel PAC.

• National Fuel has established three voluntary, nonpartisan employee-funded political action committees (National Fuel Federal PAC, National Fuel Pennsylvania PAC and National Fuel New York PAC – collectively known as “National Fuel PAC”) to accept employee contributions and make political expenditures to support candidates for elected office in New York, Pennsylvania and Washington, DC.
• National Fuel PAC provides employees with a convenient way to voluntarily participate, learn more about key issues and collectively support public policy positions important to National Fuel and our stakeholders.
• The Company does not expect or require employee participation or contributions to National Fuel PAC in any way, nor are employees reimbursed for any political expenditures made to National Fuel PAC.
• Any contributions made by National Fuel PAC to candidates for public office shall be directed by the Company officer responsible for the Government Affairs Department and be governed by the PAC’s Executive Steering Committee.

• National Fuel utilizes contract lobbyists or employee lobbyists when advocating our positions at the local, state and federal levels with elected representatives and other government officials.  This political advocacy is directed by the leadership of our various operating divisions and is coordinated by the Company’s Government Affairs Department.
• National Fuel complies with the lobbying disclosure requirements of the federal government and each state in which we operate.  We also require our contract lobbyists to comply with all applicable state regulations regarding reporting and disclosing their activities.  Employees who are registered lobbyists on behalf of the Company must also comply with Company procedures for tracking and reporting activities and related expenses.
• In their interactions with elected representatives and other government officials,  National Fuel employee lobbyists are required to comply with all applicable federal and state laws, as well as the Company’s policies on political activities, lobbying, and providing or receiving gifts, meals, and entertainment as prescribed by the Company’s Code of Business Conduct and Ethics.
• Information about National Fuel’s reported political advocacy activities may generally be found on the website of the United States Congress for federal lobbying, and on the website of the Secretary of State or applicable ethics commission of each such state in which the Company operates.

• National Fuel is a member of a number of trade and business associations which provide expertise and insights on issues important to our industry and participate in the political process at the local, state and federal levels.
• National Fuel is also active in various local chambers of commerce as a means to promote local economic development in the jurisdictions in which we do business.
• National Fuel’s participation as a member of these associations comes with the understanding that we may not always agree with all of the positions of an organization or its other members.  However, we believe our participation in such organizations advances economic growth and other interests of the communities we serve.
• On an annual basis, National Fuel will disclose on our website, in an appendix to this Policy, the amount of trade and business association dues used for lobbying activities, as reported by each trade association to whom National Fuel pays annual dues in excess of $50,000.