Schlumberger is politically neutral, and has a long standing policy (set forth in our Code of Conduct) against making financial or in-kind contributions to political parties or candidates, even when permitted by law. Our policy prohibits the use of Company funds or assets for political purposes, including for contributions to any political party, candidate or committee, whether Federal, state or local.
As a result of the Company's policy of political neutrality, Schlumberger does not maintain a political action committee (“PACs”), nor does it contribute to any third-party PACs or other political entities organized under Section 527 of the Internal Revenue Code.
Like other major companies, Schlumberger belongs to trade and industry associations in the United States to which Schlumberger pays annual dues. Schlumberger joins such associations when they add value to the Company, its stockholders and employees.
The Company's policy restricts trade and industry associations from using Schlumberger funds to directly or indirectly engage in political expenditures. To help ensure that the associations do not use any portion of the dues or other funds paid by Schlumberger for political contributions, Schlumberger annually informs the U.S. associations of our policy prohibiting any such use of Company funds. In addition, Schlumberger receives, from each U.S. trade association to which the Company pays any amounts annually, a confirmation that the Company’s dues or other expenditures paid will not be used for contributions to political parties or candidates.
For the calendar year 2016, the Company believes that all U.S. trade and industry associations to which the Company paid any membership dues or made other payments, have satisfactorily provided confirmation regarding their compliance with our policy.
Below is a list of U.S. trade and industry associations to which Schlumberger paid $50,000 or more in dues or expenditures in 2016: