American International Group Inc

AIG may make political contributions and engage in political activities in support of candidates and parties at the federal and state levels where applicable laws and regulations permit. It is the policy of AIG that employees involved in lobbying, advocacy and political activities do so in accordance with the AIG Code of Conduct, AIG and AIG-related Entity Policies, Standards, Procedures, Guidelines or other policy-related documents, and in accordance with all applicable registration, disclosure and other laws, rules and regulations governing such activities.

All political activities carried out on behalf of AIG are managed by AIG's U.S. Federal and State Government Affairs Groups, which work as appropriate with other company functions to determine which activities are permitted and consistent with AIG's business strategy. Certain restrictions on political activities are detailed in the AIG Global Lobbying and Political Activity Policy. In the past, the Regulatory, Compliance and Public Policy Committee ("RCPPC") of the AIG Board of Directors has reviewed the company's policy on political expenditures and management has provided the RCPPC with a report on all political contributions that have been made since the last such report on at least an annual basis. Going forward, the Nominating and Corporate Governance Committee ("NCGC") will perform such review and management will provide its report to the NCGC.

Governance actions detailed in this report include our efforts to engage with government and regulatory officials to shape and understand evolving climate change policy frameworks, our continued advocacy for open, rules-based and sustainable trade through our Global Trade Series; and the incorporation of Culture of Integrity and Risk Management goals into annual...

##### Lobbying and Public Policy\n\nWe regularly communicate with government and regulatory officials regarding the issues that impact our company to better understand and safeguard the interests of our business and stakeholders.\n\nOutreach to government officials and regulators at the state, federal and international levels encompasses a broad array of insurance industry issues such as product design, market conduct and governance-related matters. In recent years, ESG-related risk management, disclosures and business practices have become part of those discussions.\n\nThroughout 2023, there were active and significant regulatory developments in the form of newly proposed, issued or implemented rules, regulations and frameworks that impose, or will impose once effective, new requirements, including ones related to climate change-related governance, risk management, disclosures, stress testing and scenario planning. For more information on these new and proposed requirements, see page 12 of [our 2023 Form 10-K. The new requirements, as](https://www.aig.com/content/dam/aig/america-canada/us/documents/investor-relations/10-k/aig-form-10-k-2023.pdf.coredownload.pdf) well as proposed requirements (if and when\n\nWe continue to actively monitor the regulatory landscape surrounding these issues. Outreach to policymakers and regulators is typically focused on gaining a better understanding of the scope of regulations and other initiatives or is in response to requests to dialogue on our progress and internal initiatives. We take appropriate measures to conduct our engagement in compliance with local regulations, disclosure requirements and reporting requirements.\n\n###### External Organizations\n\nWe belong to various external organizations and associations ("Associations"), such as trade groups and think tanks that advocate for or comment on public policies affecting AIG and the insurance sector.\n\nDuring 2023, we continued to monitor and assess potential areas of misalignment between our climate policies and values and the policies of the Associations to which we belong. We do not believe that our memberships are incongruous with our climate policies and values but we also\n\ninitiatives, policies, advocacy and messaging of these Associations is limited.\n\nTo read more about our review and the disclosure of our Association memberships, lobbying disclosures and political donations practices, see [our Political Activities and Contributions website.](https://www.aig.com/about-us/leadership-and-governance/political-engagements)

###### Lobbying and Public Policy

We regularly communicate with government and regulatory officials regarding the issues that impact our Company to better understand and safeguard the interests of our business and stakeholders.

The vast majority of our outreach to government and regulatory officials at the state, federal and international levels remains focused on traditional areas of activity within the insurance industry such as insurance product design, market conduct and governance-related matters. In recent years, however, regulators in the United States and in other major countries in which we operate have increased their scrutiny of financial institutions' and other companies' risk oversight, disclosures and practices in connection with climate change and other ESG issues.

Throughout 2022, there were active and significant regulatory developments on these issues in the form of newly proposed, issued or implemented rules, regulations and frameworks regarding climate change and other ESG issues that impose, or will impose, once effective, new requirements, including requirements related to climate change-related governance, risk management, disclosures, stress testing and scenario planning. For more information on these new and proposed requirements, see page 12 [of our 2022 Form 10-K. The new requirements,](https://www.aig.com/content/dam/aig/america-canada/us/documents/investor-relations/10-k/aig-form-10-k-2022.pdf.coredownload.pdf) as well as proposed requirements (if and when adopted), could result in additional compliance and reporting costs. It is possible that some ESG rules enacted in international jurisdictions where AIG operates could impact AIG. Moreover, ESG-related rules and guidance may conflict with one another and impose additional costs on us or expose us to new or additional risks.

We continue to actively monitor the regulatory landscape surrounding these issues. Outreach to policymakers and regulators is typically focused on gaining a better understanding of the scope of regulations and other initiatives or in response to requests to dialogue on our progress and internal initiatives. We take appropriate measures to conduct our engagement in compliance with local regulations, disclosure requirements and reporting requirements.

###### External Organizations

We belong to various external organizations and associations ("Associations"), such as trade groups and think tanks that advocate for or comment on public policies affecting AIG and the insurance sector.

During 2022, we continued to monitor for potential areas of misalignment between our climate policies and values and the policies of the Associations to which we belong. AIG's participation in — and our ability to influence the various initiatives and associated messaging that occurs within — these Associations is limited.

To read more about our review and the disclosure of our Association memberships, refer to our Lobbying Report, which is available [on our website.](https://www.aig.com/home/about/corporate-responsibility/political-activities-and-contributions)

You can also find more information on lobbying disclosure and political donations [practices on our Political Activities and](https://www.aig.com/about-us/leadership-and-governance/political-engagements) **[Contributions website.](https://www.aig.com/about-us/leadership-and-governance/political-engagements)**

In 2022, AIG received a "First Tier" **designation for our political disclosure** and accountability policies and practices for election-related spending in the annual CPA-Zicklin Index published by The Center for Political Accountability and Zicklin Center for Business Ethics Research at the Wharton School of the University of Pennsylvania. This designation was given to leading U.S. public companies that received a score of 80% or higher on the Index, and AIG **received a score of 88.6%.

During 2022, AIG reviewed a select number of Associations to identify whether there was a misalignment in the climate risk policies and values of AIG, on the one hand, and the Association, on the other. The review was conducted by a team comprised of AIG's Government Affairs personnel, and involved assembling a list of Associations that were considered suitable for inclusion due to AIG's level of engagement with the Association, or the Association having well-publicized climate positions. [...] Finally, our review led us to identify a small number of Associations that have been the target of criticism for their climate risk positions and advocacy. For these Associations, the critiques are, in large part, based less on the Association's official public statements and policies, and more on perceptions of how their on-the-ground advocacy impacts progress on proposed climate risk regulation. For example, an Association may broadly support the Paris Climate Agreement, but may also criticize various U.S. Federal legislative proposals related to climate change initiatives. These critiques apply to a small number of our U.S. and non-U.S. Associations. In all such cases, AIG's participation in the Association's activities is modest, with little to no ability to influence the policy direction of the Association. Our membership allows us to stay informed of the group's activities and initiatives unrelated to climate risk, which is of value to AIG. For these Associations, AIG may voice concerns and/ or request that our dissenting view be formally noted on issues related to climate risk. We will continue to evaluate the trade-off between the benefits of membership vs. the costs (reputational and otherwise) of being viewed as implicitly supportive of the Association's climate risk positions.

During 2021, AIG reviewed a select number of Associations to identify whether there was a misalignment in the climate risk policies and values of AIG, on the one hand, and the Association, on the other. The review was conducted by a team comprised of AIG's Government Affairs personnel, and involved assembling an initial list of Associations that were considered suitable for inclusion in this initial review due to AIG's level of engagement with the Association, or the Association having well-publicized climate positions. [...] The next phase of activity was to identify any misalignment with our respective climate risk policies and values. The criteria used included a mix of objective and subjective elements, including whether the Association: - Has officially taken a position on climate change that acknowledged potential risks; - Has taken a public position on the Paris Accords; - Has taken other affirmative steps to participate in climate risk management initiatives, such as: o Promoting net-zero commitments; o Participating in external climate risk coalitions; o Forming internal working groups to study climate risk issues; or o Has conducted direct advocacy work on climate risk issues. We reviewed publicly available information such as websites, policy papers, statements from the organization's leadership and 3rd party assessments of each Association's activities. [...] For some of our larger and more active Associations, such as the American Property Casualty Insurance Association and the American Council of Life Insurers, we found that these organizations are generally participating in one form or another in policy discussions around climate change. Where our trade associations participate in climate-related discussions, it is often in the form of commenting on proposed regulation of climate risks. For think tanks, it is often in the form of providing research and data analysis on climate change risks in an effort to advance public policy discussions. While these Associations have, at times, offered constructive criticism on various climate risk regulatory initiatives[2], we believe these Associations are constructive participants in the public policy debates. Their views are broadly aligned with AIG's and we intend to continue to work collaboratively with them on climate change issues to pursue common goals. Finally, our review led us to identify a small number of Associations that have been the target of criticism for their climate risk positions and advocacy. For these Associations, the critiques are, in large part, based less on the Association's official public statements and policies, and more on perceptions of how their on-the-ground advocacy impacts progress on proposed climate risk regulation. For example, an Association may broadly support the Paris Climate Agreement, but may also criticize various U.S. Federal legislative proposals related to climate change initiatives. These critiques apply to a small number of our U.S. and non-U.S. Associations. In all such cases, AIG's participation in the Association's activities is modest, with little to no ability to influence the policy direction of the Association. Our membership allows us to stay informed of the group's activities and initiatives unrelated to climate risk, which is of value to AIG. For these Associations, AIG may voice concerns and/ or request that our dissenting view be formally noted on issues related to climate risk. We will continue to evaluate the trade-off between the benefits of membership vs. the costs (reputational and otherwise) of being viewed as implicitly supportive of the Association's climate risk positions.

In addition, in January 2021 AIG announced that it had suspended its limited Political Action Committee (PAC) activity for the foreseeable future. AIG also intends to review AIG's key relationships with trade associations to ensure their respective policies are aligned with AIG's values. [...] AIG regularly communicates with government and regulatory officials on certain issues impacting our business and other insurance industry-specific topics. We view such engagement as being in the interests of our business, shareholders, and clients. [...] AIG's state, federal and international advocacy issues in 2020 included insurance industry regulation, taxation, proposals related to pandemic relief, and retirement security. AIG engages with government and regulatory officials to understand the complex and evolving policy frameworks around climate change. All of our advocacy is done in compliance with local regulations and local disclosure and reporting requirements. [...] In compliance with the Lobbying Disclosure Act, AIG files quarterly LD2 reports, which publicly disclose all of our U.S. federal lobbying activities—including all lobbying-related expenses, all issues that the company is currently lobbying, and the entities lobbied. Past LD2 reports can be found on the U.S. Senate Lobbying Disclosure Website here. Similar requirements for lobbying activities exist in jurisdictions outside the U.S. where AIG also interacts with government and regulatory officials. AIG operates in compliance with the local requirements including registering on public lobbying registries regardless of whether they are mandatory or voluntary (e.g., EU). [...] On January 13, 2021, AIG suspended its limited Political Action Committee (PAC) activity for the foreseeable future. AIG does not make political donations outside the U.S. All political contributions made by the AIG PAC are publicly disclosed and can be found at the Federal Election Commission. All AIG PAC contributions are made in accordance with applicable federal and state laws, and without regard for the private political preferences of AIG executives. [...] AIG belongs to various trade associations that assist in advocating on public policies affecting AIG and the insurance sector, such as tax and accounting matters and regulations impacting product offerings. As of January 2021, AIG is reviewing its key trade association relationships to ensure their respective policies align with AIG's values. Where advocacy positions taken by industry and trade associations in which we are members diverge from our own, AIG may, depending upon its significance, voice our concern(s) and/or request that our dissenting view be formally noted, and/or escalate the matter to the attention of AIG senior management.

The Board, through the NCGC, oversees succession planning for the Chairman & CEO and our policies, practices and reporting with respect to current and emerging public policy issues of significance to the Company, including issues relating to climate, sustainability, corporate social responsibility, government relations and lobbying [...] The NCGC oversees and reports to the Board on succession planning with respect to the Chairman & CEO and oversees our policies, practices and reporting with respect to current and emerging public policy issues of significance to the Company, including issues relating to climate, sustainability, corporate social responsibility, government relations and lobbying.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]During 2021, AIG reviewed a select number of Associations to identify whether there was a misalignment in the climate risk policies and values of AIG, on the one hand, and the Association, on the other. The review was conducted by a team comprised of AIG's Government Affairs personnel, and involved assembling an initial list of Associations that were considered suitable for inclusion in this initial review due to AIG's level of engagement with the Association, or the Association having well-publicized climate positions. AIG is a large, global organization, with an employee population dispersed over more than 50 countries. Many of our employees are asked to join various external groups based on their professional backgrounds, personal industry contacts and areas of expertise, and those organizations may or may not be involved in the insurance industry. For the purposes of our review, we did not attempt to survey every external organization in which AIG or an AIG employee participates. Rather, we focused this initial review on a subset of Associations and will expand the scope in future reviews.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]AIG belongs to various external organizations ("Associations") that advocate for, or comment on, public policies affecting AIG and the insurance sector more broadly. These Associations include trade groups and think tanks, each of which participate in public policy discussions in different ways. Trade groups are typically member-driven, and the ability of any individual member to influence the activities of a trade group will vary greatly based on the level of membership, board representation, business size/market share of the member, and other factors. Think tanks typically operate independently from their members/donors. As a result, official positions of an Association of which AIG is a member, or otherwise participates, on any particular issue may be quite different than AIG's position.