Political Disclosures

Public sector decisions significantly affect AAR’s business, direction and growth. For this reason, AAR participates in the political process through regular and constructive engagement with government officials and policy-makers, by making political contributions, and by encouraging the civic involvement of its employees. AAR complies with all applicable laws and regulations related to its participation in the political process. 

AAR’s Government Affairs Department is responsible for managing and coordinating the Company’s political participation. The Board of Directors of AAR Corp. is responsible for overseeing the Company’s lobbying activities and political contributions and for reviewing Annual Contributions and Lobbying Reports. The Company's participation in the political process is governed by our Political Participation, Lobbying, and Contributions Policy.

Corporate Political Contributions and Expenditures

Independent Expenditures
AAR has not sponsored advertisements that would qualify as “independent expenditures” or “electioneering communications” under U.S. federal campaign finance laws, and has no plans to do so. 

Political Contributions Outside of the United States
AAR does not and will not contribute, loan, or make available any money, assets, property or other thing of value to any non-U.S. candidate, political party, or political committee. 

Contributions to Political Candidates
Consistent with U.S. federal law, AAR does not contribute corporate funds to federal candidates, national political party committees, or other federal political committees. AAR may contribute corporate funds to U.S. state or local candidates or committees only where permissible and within the limits designated by state and local laws and regulations, including limitations in so-called “pay-to-play” rules that may be applicable in jurisdictions where AAR holds or may in the future bid for a government contract. 

State and Local Contributions
From time to time, AAR may make corporate political contributions in certain states where permitted by law. In 2018, AAR did not make corporate political contributions to state political candidates or political committees. 

527 Political Contributions 
In 2018, AAR did not contribute to any Section 527 organizations or to organizations that support or oppose local state or local ballot initiatives or referendums, and has no plans to do so in the future. In the event that the Company would choose to use Company funds to make contributions to these organizations, it will disclose such contributions. 

Political Action Committee
In the United States, AAR sponsors the AAR Corp. PAC, a federal political action committee, formed pursuant to the Federal Election Campaign Act, as amended, and the regulations promulgated by the Federal Election Commission. The AAR PAC enables eligible Company employees to voluntarily pool their financial resources to support federal political candidates and organizations. The PAC is funded exclusively by eligible employees' voluntary contributions; employee contributions are never coerced and all solicitees are informed that neither their contribution nor their refusal to contribute will affect their employment status. Employees may not be directly or indirectly reimbursed for PAC contributions. 

PAC contributions and expenditures are publicly disclosed on government-agency websites, including the Federal Election Commissions website (www.fec.gov). Additionally, information regarding contributions to the AAR Corp. PAC can be found at The Center for Responsive Politics website.

Trade Associations 
AAR participates in various trade associations. These associations provide a variety of benefits to the Company including access to information and data on industry trends and emerging issues, and educational opportunities for our employees. Some of these associations utilize a portion of membership dues for non-deductible lobbying regarding issues of common concern to members. In 2018, AAR did not pay any dues to any trade associations where (1) dues for a single year exceeded $50,000; and (2) a portion of those dues were not deductible under Section 162(e)(1) of the Internal Revenue Code, as reported by the organization.  

Lobbying Expenditures 
AAR lawfully engages in the legislative process through lobbyists to communicate its views on legislative and regulatory matters affecting the Company’s business. All federal lobbying activities are regulated by the Lobbying Disclosure Act (LDA). Under the LDA, AAR’s lobbyists file quarterly disclosure reports with the Clerk of the House and the Secretary of the Senate regarding payments for all federal lobbying activities.  The most recent reports along with historical reports can be found at The Center for Responsive Politics website.