Policy on Political Contributions and Interactions with Government Officials

The purpose of this Policy is to set clear and uniform parameters for interaction with federal, state/provincial and local/municipal elected representatives and public-service officials.†

A. Political Contributions

  1. Because Domtar operates in multiple jurisdictions with varying and -- at times -- conflicting laws regarding political contributions, Domtar does not make political contributions using corporate funds.†††
  2. The use by employees of Domtar's financial or material resources for political purposes is strictly prohibited.†
  3. Domtar shall not pay its representatives' admission fees to partisan political activities. These activities are generally organized for the purpose of raising funds and may take the form of cocktails, meetings, banquets, meals, sporting events or other similar activities.† Activities organized by, and with all proceeds going to, a recognized and registered charity, are not covered by this Policy.†
  4. Any exception to this Policy must have the prior approval of the President and Chief Executive Officer and the Senior Vice-President, Law and Corporate Affairs.†
  5. An annual report on any political contributions must be submitted to the Board of Directors of Domtar.†
  6. The Senior Vice-President, Law and Corporate Affairs is responsible for implementation of this Policy.†
  7. Nothing in this Policy shall restrict, in any way, personal political contributions made by employees to candidates for public office, political parties, Political Action Committees or any other political activity.†
  8. With the approval of the President and CEO and the Senior Vice President,† Law and Corporate Affairs, certain Domtar employees may be solicited for participation in industry political activities.† An example would be participation in an industry Political Action Committee.†††

B. Interaction with Representatives of Government Agencies†

Interaction with officials and employees of governments to ensure the promotion of Domtar's interests is the responsibility of the Vice-President, Government Relations. All contacts with elected officials and employees of governments, other than in the ordinary course of business, should be coordinated through Domtarís Regional Managers of Communications and Government Relation.

It is Domtarís business practice to maintain cordial and harmonious relations with officials and employees of governments at various levels.† Although Domtar encourages such relations, it is absolutely essential that they comply with legislation and Domtar policies and that they preserve the integrity and the appearance of integrity of Domtar and its representatives on one hand, and that of the officials and employees of governments on the other.†


  1. Both under U.S. and Canadian law, the offer and acceptance by an elected representative or government employee of compensation, advantages, or benefits, for consideration of collaboration, help, influence, acting or failure to act, etc., constitutes a criminal offense subject to fines and/or imprisonment. This statutory offense involves both the giver and the taker, and certain jurisdictions do not set a minimum amount (e.g., ďno cup of coffee rule.Ē)† Gifts shall not be provided by Domtar employees to elected and appointed officials.†
  2. If a bona fide, long-term personal relationship has been maintained by a Domtar employee and a government official, such relationship shall be documented and such documentation provided to Domtarís Vice-President, Government Relations.† In cases such as this, any applicable federal, state, or provincial regulation shall be adhered to.†
  3. If Domtar hosts an elected or appointed government officials for a facility visit, or otherwise as part of an education component, applicable laws and regulations must be followed with regard to meals provided and any samples, goods with Domtar logo, etc. that might be provided.† Advice in this regard should be sought in advance from the Vice-President, Government Relations.†
  4. Prudence and good judgment must be exercised and in case of doubt, the Senior Vice-President, Law and Corporate Affairs, or the Vice-President, Government Relations should be consulted.

Issued June 2012