Political Contributions & Lobbying

Political Contributions & Lobbying Policy

At Level-1 Global Solutions, integrity is not a statement; it is a standard that guides every decision we make. How we engage with government, policymakers, and the public reflects our responsibility as a trusted partner in civic and infrastructure projects. Our commitment is clear: to operate transparently, lawfully, and without political influence, ensuring that our work always serves the public interest.

We believe that ethical engagement in the political process strengthens both our company and the communities we serve. For that reason, Level-1 maintains a strict policy on political contributions and lobbying activities to safeguard independence, avoid conflicts of interest, and uphold the trust placed in us by clients, employees, and government partners.

Level-1 Global Solutions does not make political contributions. The company does not allocate funds to political candidates, committees, parties, or campaigns. Should an exceptional circumstance arise, written approval must be obtained in advance from the Level-1 Executive Committee. The request must specify the reason, amount, and intended recipient. No exceptions will be approved for contributions exceeding $5,000 USD, and all approvals must be documented and retained by the Executive Committee.

This policy does not restrict employees from participating in the democratic process as private citizens. Employees are free to vote, advocate, or contribute to campaigns in their personal capacity, provided such actions are lawful, voluntary, and do not create an appearance of representing the company.

For clarity, political contributions include any direct or indirect transfer of funds, goods, or services intended to influence a political campaign or ballot initiative. Examples include:

• Monetary donations to candidates, political committees, or parties
• Purchasing tickets for political events or fundraisers
• Use of company facilities, assets, or time for political purposes
• Sponsorships or advertisements in political publications
• Payments for goods or services that benefit a campaign

Employees must never seek reimbursement, compensation, or other incentives from Level-1 for political activities.

Political participation must never interfere with workplace operations or relationships. Employees may not use their position, authority, or company resources to pressure others into supporting a candidate, cause, or campaign. Political activities must take place entirely outside company time and without use of company equipment or materials. Because Level-1 frequently partners with government clients, all employees must ensure their personal political activities remain compliant with laws governing public contracts and procurement.

Lobbying is an essential part of civic discourse, but it is also subject to strict regulation. Any communication with government officials on behalf of the company that could be considered lobbying must receive prior written clearance from Level-1’s Vice President of Public Policy and Legal Counsel. This includes meetings, advocacy, or policy discussions that could trigger registration or disclosure requirements under federal, state, or local law.

Engagement with current or former government officials must always respect ethical and legal boundaries. Employees must not place any public official in a position that could violate post-employment restrictions, procurement laws, or conflict-of-interest regulations. Many officials are bound by “cooling-off” periods that prohibit them from representing private companies shortly after leaving public service; these restrictions must be strictly observed.

Every employee shares responsibility for maintaining the integrity of Level-1’s political and public interactions. Violations of this policy, including unauthorized political contributions, lobbying without approval, or misuse of company resources, will result in disciplinary action, up to and including termination.

At Level-1 Global Solutions, ethics are not optional. They are the foundation of our work and the measure of our credibility. By maintaining a clear boundary between business and politics, we preserve the independence, trust, and accountability that define who we are- a company built to serve the public good with integrity and transparency.