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    (EXAMPLE: 'PACKAGING AUTOMATION')

    Government Relations

    Political Disclosure and Accountability

    Management Approach

    WestRock believes that it is a fundamental right and obligation of all citizens to engage in responsible dialogue about the laws, regulations and government policies that affect them. We strongly believe that active engagement in the political and regulatory processes is an important means of protecting our commercial, employee and stakeholder interests. When it is in the best interest of our company, we interact with public officials through a variety of channels, including professional lobbyists as well as grassroots lobbying communications.

    All forms of political engagement undertaken by or on behalf of WestRock, including, without limitation, lobbying, trade association participation and political contributions, must comply with all U.S. and international laws, this policy and our Code of Conduct.

    Global Activities

    WestRock is a global company with operations throughout North America, South America, Europe, and Asia Pacific. We work cooperatively with local, regional and national governments in the countries where we operate. From time to time, legislative, regulatory and other political issues may arise in these jurisdictions that affect our operations. After careful consideration and approval of senior management, WestRock may engage in dialogue with government officials on issues that affect our business goals and objectives. We engage in political activity and spending outside of the United States as permitted by, and in strict compliance with, applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act.

    Participation in Trade Associations

    WestRock is a member of several trade associations and other organizations that provide information and assistance on public policy issues of concern to our business. We participate in groups such as the American Forest & Paper Association, the National Association of Manufacturers, the American Benefits Council, and the US-China, US-India and US-Brazil Business Councils not only to influence policy decisions, but to gain information that will help us improve our global operations. We value the diversity of opinions found within these groups and sometimes take positions contrary to those of these organizations when we believe it is the right thing to do.

    Our membership in these organizations is intended to accomplish a wide of range of objectives which support our initiatives where we believe engaging in coalitions with other industry participants is beneficial to our business and compliant with our antitrust policies. The company makes payments to these trade associations, including paying membership fees and dues. On an annual basis, we track the portion of the company’s payments to trade associations that were used for non-deductible lobbying expenditures per the rules and regulations of the Internal Revenue Service. Click here to see a detailed list of payments made to trade associations that the recipient organization may use for political purposes.

    U.S. Political Contributions

    WestRock Employee Political Action Committee (PAC)

    The WestRock PAC is a voluntary, non-partisan political action committee that is registered with the U.S. Federal Election Commission. The PAC allows employees to pool personal, voluntary financial contributions to candidates seeking federal elective office who support issues important to our business, our employees and other stakeholders. The WestRock PAC only makes political contributions to candidates who we believe have integrity and have demonstrated a commitment to ethical political conduct. We also consider the geographical area of the candidate’s representation, the candidate’s position or voting record on key issues affecting our industry and our company, as well as the candidate’s committee assignments and legislative leadership positions.

    Employee contributions to the WestRock PAC are voluntary, and no employee is required to participate in or fund the PAC’s efforts. WestRock’s political spending through the PAC reflects our interests as a company and not those of any individual director, officer or employee’s personal political preferences. No political spending is given in anticipation of, in recognition of or in return for any official act.

    The PAC files monthly reports of receipts and disbursements with the Federal Election Commission (FEC), as well as pre-election and post-election FEC reports. Click here for the FEC database of PAC contributions and enter “WESTROCK POLITICAL ACTION COMMITTEE” or “Committee ID: C00117424”.

    Corporate Contributions

    WestRock uses corporate resources to support our position on important public policy issues. Individual state and local laws govern contributions to candidates running for election to state and local offices. The Government Relations department, with oversight from the Advisory Board, sets an annual budget and has a stringent process for the justification, approval and reporting of any corporate political contributions made in the U.S., where such contributions are permissible by law.

    Oversight of Political Activity and Spending Practices

    WestRock’s political activity and spending practices are overseen and approved by the Advisory Board and subject to comprehensive regulation by federal and state governments, including detailed disclosure requirements. The Advisory Board annually reviews all political contributions to ensure alignment with company policy goals and values. The company’s political spending includes donations to candidates for elected office, as well as payments to trade associations. The company conducts regular trainings, compliance system reviews, and internal audits to ensure all PAC and corporate political contributions are made in accordance with the law and company policies. WestRock believes that transparency and accountability with respect to political expenditures and lobbying are important.

    Company political contributions reflect our interests as a company and not those of any individual director, officer or employee’s personal political preferences. They are made in accordance with our political contributions policy only as permitted under federal, state and local laws to help elect candidates who demonstrate integrity and character, support the forest and paper products industry and understand the contribution of our industry to the national economy and the communities in which we serve. No political spending is given in anticipation of, in recognition of or in return for any official act.

    The company does not make “independent expenditures” nor does it contribute to so-called “Super PACs”, 527 groups, 501(c)4s, or for any election ballot measure.

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