About American Express

American Express Company Political Activity

American Express Company believes that active engagement in the public policy arena is an important part of responsible corporate citizenship and is vital to the democratic process.

American Express is committed to engaging in a dialogue with policymakers on a wide range of public policy issues important to the Company. Our business is subject to legislative and regulatory requirements at the federal and state levels and changes to such rules can have a significant impact on our shareholders, customers, employees and communities. Our U.S. federal and state government affairs offices represent the Company on important policy issues before Congress, the Administration, regulators, and state governments across the United States.

In addition to the Company’s advocacy efforts, American Express participates in the political process through the American Express Company Political Action Committee (AXP PAC) and through corporate political contributions in those jurisdictions where it is permissible to do so.

The Company maintains comprehensive compliance procedures to ensure that its activities are conducted in accordance with all relevant laws governing political contributions and lobbying activities.

The Company regularly files reports with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives detailing its lobbying activities. Copies of these filings are available at www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm.

American Express Company Political Contributions
Federal election law allows corporations to establish political committees, which may make contributions to federal candidates, state candidates (as permitted by law) and other committees. Established more than 25 years ago, the AXP PAC is supported solely by voluntary contributions from American Express employees. AXP PAC is regulated by the Federal Election Commission (FEC). AXP PAC files regular reports with the FEC and the relevant State election commissions on its receipts and disbursements. Reports filed with the FEC are available to the public at www.fec.gov.

American Express makes political contributions as permitted under federal, state and local laws to help elect candidates whose views and positions are good for the Company, our industry, and ultimately the free-market economy. Political contributions are made by the AXP PAC or by corporate funds, where permitted. AXP PAC contributions as well as corporate political contributions are made based on a variety of factors including:

The candidate's views on issues of importance to American Express;
The candidate's position on a committee with jurisdiction over policy issues important to American Express;
The candidate's representation of a state or district where American Express has an employee presence; and,
The candidate’s elected leadership position.

AXP PAC does not contribute to presidential campaigns.

Decisions regarding individual political action committee contributions are made by Company management responsible for government affairs, under the oversight of the board of directors of the Company’s political action committee. Corporate political contributions are determined by Company management responsible for the Company's government affairs.

The Company reports regularly to the American Express Company Board of Directors’ Public Responsibility Committee (PRC) regarding its engagement in the public policy arena and its fundraising activities and political contributions.

Beginning for payments made in calendar 2008, American Express will request information regarding political contributions from trade associations, entities organized under section 501(c) 4 of the Code, and other tax exempt organizations that engage in non-deductible lobbying and political expenditures under Code section 162(e). For any such organization that receives in excess of $50,000 during the calendar year from the Company, American Express will request that the organization identify the portion of American Express' payments used in connection with participation or intervention in a political campaign on behalf of (or in opposition to) any ballot initiative or candidate for public office, as defined under Subsection 162(e)(1)(B) of the Code. American Express will include in its political contributions report on its website any responses American Express receives to such requests.