Political Engagement and
Contributions Policy

Policy Statement

Sempra Energy and its subsidiaries (Sempra Energy) consider engaging with policymakers to be an important, necessary and appropriate part of doing business. We track hundreds of proposed laws, rules, regulations and policies annually and engage at the federal, state, and local levels of government to ensure that the perspectives of our company, our shareholders, our customers, and our employees are represented before lawmakers and regulators. When warranted, we also take positions for or against proposals and sometimes suggest amendments as part of the public policy process.

We believe that public policy engagement is an important and appropriate role for companies, as long as it is conducted in a legal and transparent manner. In the U.S., there are federal, state and local lobbying registration and disclosure laws with which Sempra Energy and its business units comply, and the company has a robust training and reporting program in place to assure compliance.

Governance

On an annual basis, Sempra Energy’s public policy priorities and political contributions policies, processes and reports are shared with the Corporate Governance Committee of our Board of Directors. While our Board provides oversight, management is responsible for the activities, positions and daily decision-making consistent with this oversight.

Procedurally, corporate political spending plans and decisions are reviewed and approved by senior management. Each contribution is reviewed and authorized by a vice president or higher level officer and political reporting and compliance clearance checks are performed before any payments are issued. Our employee political action committee spending plans and decisions are reviewed and approved by the respective political action committee Board of Directors and also receive political reporting and compliance clearance before checks are issued.

Corporate Political Contributions

Sempra Energy makes corporate political contributions as permitted by law only from corporate shareholder funds. Political contributions are made to candidates, political parties, Political Action Committees, and ballot measures in furtherance of public policies that support the company’s business interests.

Sempra Energy complies with all federal, state and local laws as well as reporting requirements governing corporate political contributions. Federal law, for example, forbids corporations from giving monetary or in-kind contributions to candidates for federal office. State and local laws dictate the conditions under which corporate political contributions may be made and disclosed.

Consistent with our commitment to ethical business conduct, political spending reflects Sempra Energy’s interests and is not based on the personal agenda of any of our individual officers, directors or employees. Furthermore, no contributions are given in anticipation of, in recognition of, or in return for, any official act.

Employee Political Action Committee Contributions

Sempra Energy’s employees take an active role in the political arena through the Sempra Energy state and federal Employees Political Action Committees (collectively, SEEPAC). SEEPAC is a voluntary political action committee independent of any political party. It is designed to provide the employees of Sempra Energy and its affiliates an effective, convenient way to make financial contributions to candidates and participate in the political process.

SEEPAC makes political contributions at the federal, state and local levels, and complies with all reporting requirements governing political action committee contributions. Employees are not allowed to make political contributions from personal funds or through SEEPAC and then seek reimbursement from the company.

Trade Association & Business Memberships

Sempra Energy holds memberships in industry, trade and business associations representing the energy industry and the business community in locations where we have operations. Engaging with other business and industry stakeholders helps us gain perspective and arrive at consensus on broad public policy issues that impact our company, our shareholders, our customers and our employees.

While we may not always agree with the positions taken by an association or its members, corporate memberships enable us to learn the views of others, obtain feedback from them, and ultimately, voice our concerns, perspectives and positions on proposed legislation and regulations in a more educated and balanced way.

Political Engagement and Contributions Policy

2013 Corporate Political Contributions

2013 Federal PAC Contributions

2013 Trade Associations