## Management and Oversight Lumen values responsible corporate governance and participates in the political process to formulate policies that benefit our employees, customers, shareholders, and the communities we serve. In making political contributions, Lumen is committed to complying with laws and regulations governing the political process including campaign finance and disclosure rules.
Management of Lumen's participation in the political process is the responsibility of the Vice President, Public Policy and Government Affairs. This position reports directly to Lumen's Executive Vice President, General Counsel & Secretary.
Public policy updates are provided periodically to Lumen's Board of Directors and/or its designated board committees, including periodic reviews of the company's political strategy, contributions and activities. The risks associated with political and lobbying activities are managed in accordance with the company's enterprise risk management framework. In that regard, the Board of Directors and/or its designated board committees oversee compliance with the Company's policies and procedures regarding political contributions and activities.
The Nominating and Corporate Governance Committee reviews and approves the company's political policies, practices and expenditures on a periodic basis. The Nominating and Corporate Governance Committee is composed of outside directors that meet the independence requirements of the New York Stock Exchange.
In addition, the company's Internal Audit personnel and Corporate Ethics and Compliance Department assess the risk related to political activities, including spending, in connection with the company's annual risk assessment process.
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https://assets.lumen.com/is/content/Lumen/lumen-political-contribution-report-jan-1-through-june-30-23
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The Sustainability Management Committee—composed of people from across the organization—designs and oversees our companywide sustainability program, including cybersecurity and data privacy, business ethics, network reliability, and climate change. They are responsible for driving the sustainability agenda under the guidance and oversight of the Lumen Board and senior leadership. [...] We regularly solicit and receive a broad array of input and feedback from internal and external stakeholders, such as employees, investors, and customers. We also routinely engage with the Nominating and Corporate Governance Committee and members of the Lumen Board regarding our sustainability initiatives, using feedback to enhance and drive our program forward. [...] The Lumen Nominating and Corporate Governance Committee conducts quarterly ESG reviews and has the primary responsibility for ESG oversight based upon its charter. The committee works with our management team to evaluate our ESG program and identify meaningful ESG and financial factors. It also routinely assesses our disclosure and communication plans for strength and effectiveness. The Lumen Board of Directors annually reviews the ESG program and its initiatives, while the Risk and Security Committee, Human Resources and Compensation Committee, and Audit Committee all periodically review specific topics that are part of our ESG program. [...] In 2022, we updated our Anti-Corruption Policy and further improved our program by implementing a new policy and process to manage public policy and lobbyist business courtesies in response to continual risk assessment.
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https://ir.lumen.com/files/doc_downloads/2022/11/lumen-2022-esg-report.pdf
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Our Board and NCG Committee oversee our political initiatives and annually review Lumen's political and lobbying activities and related budgets. We strive to advocate public policy solutions that best serve our stakeholders. Our semi-annual Political Contributions Reports provide transparency in this process, demonstrating ethical corporate governance and promoting confidence in the democratic process. Specifically, our Reports disclose our corporate political contributions and those of our political action committees in accordance with applicable federal and state campaign finance laws and contributions to trade associations and 501(c) (4) organizations. Although not part of this proxy statement, our most recent Political Contributions Reports can be located on our website at lumen.com.
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https://ir.lumen.com/files/doc_financials/2023/ar/413614-1-_19_Lumen_NPS-AR-Combo_WR_R1.pdf
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## Management and Oversight Lumen values responsible corporate governance and participates in the political process to formulate policies that benefit our employees, customers, shareholders, and the communities we serve. In making political contributions, Lumen is committed to complying with laws and regulations governing the political process including campaign finance and disclosure rules.
Management of Lumen's participation in the political process is the responsibility of the Senior Vice President, Public Policy and Government Affairs. This position reports directly to Lumen's Executive Vice President, General Counsel & Secretary.
Public policy updates are provided periodically to Lumen's Board of Directors and/or its designated board committees, including periodic reviews of the company's political strategy, contributions and activities. The risks associated with political and lobbying activities are managed in accordance with the company's enterprise risk management framework. In that regard, the Board of Directors and/or its designated board committees oversee compliance with the Company's policies and procedures regarding political contributions and activities.
In addition, the company's Internal Audit personnel and Corporate Ethics and Compliance Department assess the risk related to political activities, including spending, in connection with the company's annual risk assessment process.
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https://assets.lumen.com/is/content/Lumen/lumen-political-contribution-report-january-through-june?Creativeid=e7f79290-f143-4e7e-863b-c99ec82a382f
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Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Involvement in organizations such as trade associations is assessed prior to active participation and is relevant across the organization in all countries. Lumen's Public Policy Group is also engaged if changes or new initiatives may have an impact on regulatory or public policy for the Company.
A further means of ensuring actions that can influence policies remain consistent with our climate change strategy is achieved through the Sustainability Committee. This Team includes the functional groups across the organization that would be involved directly or indirectly in influencing public policy related to climate change. Consistency is achieved, in part, through consultation with our Chief Compliance Officer and General Counsel (as needed). In general, public policy activities are geared towards increasing and expanding the adoption of broadband internet which can significantly reduce the carbon footprint of our customers and their business partners.
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CDP Questionnaire Response 2022
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Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]No, and we do not plan to have one in the next two years
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CDP Questionnaire Response 2023
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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?[…]Involvement in organizations such as trade associations is assessed prior to active participation and is relevant across the organization in all countries. Lumen's Public Policy Group is also engaged if changes or new initiatives may have an impact on regulatory or public policy for the Company.
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CDP Questionnaire Response 2023
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