Political Engagement and Contributions Policy

Governance and Decision-Making

The Corporate Governance Committee of our Board of Directors reviews on an annual basis Sempra Energy’s public policy priorities and political contributions policies, processes and contributions expenditure budgets, including lobbying expenditures associated with memberships. The board also reviews a report detailing the political contributions from the preceding year. While our Board provides oversight, the most senior External Affairs officer 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. Individuals responsible for government affairs in each of Sempra Energy’s business units work to prepare political contributions budgets for the local jurisdictions and states where the company has operations. Budgets are reviewed and approved by our business units’ boards of directors before being submitted to Sempra Energy for review and approval. Once budgets are finalized, each contribution is reviewed and authorized by a vice president or higher level officer and legal compliance reviews are conducted before contributions are made to ensure they comply with applicable laws. Contributions over $100,000 require approval of the most senior External Affairs officer. Our employee political action committee spending plans and decisions are reviewed and approved by the Political Action Committee’s Board of Directors and also receive political reporting and compliance clearance before checks are issued.

Sempra Energy has a department dedicated to all aspects of compliance with applicable political laws and reporting obligations. This department, with the assistance of legal counsel, informs and educates employees, analyzes legal compliance; monitors and communicates changes in laws, and collects disclosure information in a centralized database which is then used to prepare disclosure reports. The training and outreach program consists of the following:

  • An annual online training course required for all external-facing employees, officers, attorneys and directors;
  • A quarterly newsletter sent to all external-facing employees, officers, attorneys and directors with regulation changes, legal information and links to internal and external resources;
  • A bi-annual in-person and/or webinar training regimen for all new hires and transfers;
  • Periodic in-person and/or webinar training for groups identified as having the potential for interface with public officials; and
  • A company intranet site dedicated to political reporting and compliance, which has information on lobbying, gifts, contributions and political fundraising.

Management oversight for corporate political activity and the Sempra Energy Employees’ Political Action Committee resides with the highest-ranking external affairs executive of the company, Mr. Steven D. Davis., Executive Vice President, External Affairs and Corporate Strategy of Sempra Energy and a member of the board of directors of San Diego Gas & Electric Company and Southern California Gas Company.