Political Engagement

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Overview

Political Engagement

At The Estée Lauder Companies we are committed to the highest standards of professional and personal conduct.

Consistent with the commitment to be a responsible citizen in every community we serve, we conduct our relations with governments in places where we do business in accordance with applicable laws, rules and regulations.

Lobbying and Public Policy Positions

The Estée Lauder Companies’ business is affected by legislation and regulations everywhere we operate, market or sell our products. We communicate regularly with governments to give our views on proposed regulation and work to educate them on the high standards to which we hold ourselves accountable.

From time to time, we may take a position on matters of public policy that could affect our business, employees or the communities we serve. As a matter of Company policy, our business units, members of management or employees may not take positions on matters of public policy or engage in lobbying activities in the Company's name or on the Company's behalf without the approval of the Executive Vice President and General Counsel or the Senior Vice President, Global Government Relations. Our political policy, public policy and legislative priorities are reviewed periodically with senior management. In addition, periodically, we provide a report to the Board's Nominating and Board Affairs Committee concerning government relations activities and policies, political contributions and expenditures and other related topics.

Political Campaign Contributions and Expenditures

The Estée Lauder Companies does not have a political action committee ("PAC").

Consistent with U.S. federal law, The Estée Lauder Companies does not make political contributions to candidates for federal office.

By policy, The Estée Lauder Companies may make a modest number of political contributions to state and local political candidates and parties in the United States, with the approval of the Executive Vice President and General Counsel. In 2013, such contributions totaled less than $34,000; in 2014, they were less than $15,000; and in 2015, they were less than $20,000. Contributions are made without regard for the private political preferences of our executives.

Further, as a matter of policy, The Estée Lauder Companies does not use corporate funds to support 527 organizations, 501(c)(4)s, ballot measures or "Super PACs." In addition, we do not make independent political expenditures to influence federal elections and do not allow Company facilities to be used for purposes of campaigning or fundraising.

Trade and Industry Associations

The Estée Lauder Companies works with industry associations and other trade organizations on public policy matters in some of our key markets when we believe that such participation is in the best interests of the Company. Because these associations and organizations have numerous members with different areas of focus, they may address a very broad range of public policy and other matters; as a result, there may be occasions where The Estée Lauder Companies’ views on particular issues differ from the views of certain associations or organizations in which we participate.

Approximately $195,000 of The Estée Lauder Companies’ dues paid in 2015 to the U.S. cosmetics trade association, the Personal Care Products Council (“PCPC”), were identified by PCPC as funds spent on lobbying and political activities. Related expenses identified by other U.S. associations in which we are a member are believed to be de minimis and in no instance more than $25,000.

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The Estée Lauder Companies' Political Engagement

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