2021 Owens Corning Sustainability Report | Expanding Our Social Handprint | Human Rights & Ethics | 283 review of travel and expenses (T&E) to assess policy compliance, sensitive transactions, and potential misuse or abuse. In 2021, our anti-corruption efforts resulted in the following outcomes: • 100% of the members of our board of directors received communication on our anti- corruption policies, procedures and compliance efforts. • 100% of our employees received communication on our anti-corruption policies and procedures, and 100% of staff employees, which is approximately 28% (5,695) of all employees, completed training. • 100% of our new suppliers received our Supplier Code of Conduct, which includes anti- corruption expectations. • 100% of Owens Corning’s business was assessed for corruption risks, per an annual assessment cycle. Significant risks identified and assessed include customers, independent third parties (including facilitation payments), direct and indirect interactions with government officials (including gifts and entertainment), anti- money laundering, politically exposed persons, and bribery. • Owens Corning received no fines, penalties, or settlements in relation to corruption in 2021. Furthermore, no employees were disciplined or dismissed due to noncompliance with anti-corruption policies in 2021. There were no confirmed incidents of corruption, termination of contracts with business partners, or public legal cases against Owens Corning or its employees related to corruption. ■ Anti-Competitive Behavior In general, Owens Corning discourages employee contact with competitors. Employees who do have contact with a competitor must report that contact to the law department, even if business is not discussed. • Before a scheduled meeting or call with a competitor, the law department must review the purpose of the meeting, the written agenda, a list of participants, and any documents or information that will be shared. • After any contact with a competitor, scheduled or unscheduled, employees must file a report with the law department. Owens Corning has established controls related to potential contact with competitors. These controls may be reviewed as part of a periodic audit process. The company has created a mobile- friendly web app to make reporting these interactions easy. After extensive review, we have found no record of any fair competition breaches in our company’s history. We have also had no legal actions for anti-competitive behavior or monopoly practices. ■ Corporate Political Advocacy Owens Corning incurs lobbying expenses directly through an internal registered lobbyist and three lobbying consultants, as well as indirectly through trade associations who lobby on their members companies’ behalf. In 2021, direct and indirect lobbying expenses for the company totaled $564,390. Lobbying-related expenses are a subset of the company’s overall advocacy- related expenditures, which also includes membership fees for industry associations. In 2021, the company’s overall advocacy-related expense was $3,200,004. In 2021, the five largest lobbying- related expenses totaled to $483,108, and were with the following organizations: • WilmerHale. • Flywheel Government Solutions. • Mehlman Castagnetti. • Business Roundtable. • North American Insulation Manufacturers Association (NAIMA). In 2021, our three largest trade association or lobbyist expenditures were for NAIMA, the Asphalt Roofing Manufacturers Association (ARMA), and the European Insulation Manufacturers Association (EURIMA). The company spent $1,895,373 with these three groups, which includes membership fees and contributions to trade associations. Owens Corning’s political advocacy objectives are to support initiatives which align with the company’s core principles, including advocating for energy efficiency measures and contemporary building code development and adoption. We also work in conjunction with the National Association of Manufacturers and the Business Roundtable to advocate for affordable housing and other social justice concerns. In 2021, Energy Efficiency accounted for around $280,000 worth of related expense, and Building Codes accounted for around $140,000, with some overlap of spending between these areas. Owens Corning does not permit the use of corporate funds to support any political candidate, political organization, or campaign.
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