Political Contributions and Expenditures

Political Contributions and Expenditures

AMERICAN OUTDOOR BRANDS CORPORATION
POLICY ON CORPORATE POLITICAL CONTRIBUTIONS AND EXPENDITURES

pdf  Fiscal Year 2019 Political Contribution Report



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American Outdoor Brands Corporation (the  “Company”) believes that participation in the political process to promote and  protect the interests of the Company is in the best interests of the Company  and its stockholders. The Company seeks to be an effective participant in the  political process by making prudent political contributions and expenditures  consistent with the Company’s objectives and applicable law.

Legal Compliance and Oversight

The Company is committed to compliance  with all applicable laws and regulations in connection with the Company’s  political contributions and expenditures. The Company’s Board of Directors (the  “Board”) has adopted this Policy on Corporate Political Contributions and  Expenditures (the “Policy”), which is designed to ensure that the Company’s political  contributions and expenditures (a) reflect prevailing corporate governance  practices consistent with the Company’s objectives and values; (b) comply with applicable  laws and regulations of the relevant jurisdictions; and (c) promote and protect  the best interests of the Company and its stockholders and not the personal  agendas of individual directors, officers, or employees of the Company.

The Board, acting through the  Nominations and Corporate Governance Committee, is responsible for overseeing the  Company’s lobbying activities and political contributions, including monitoring  the Company’s policy positions and trade association memberships and mandating  that political spending activity is reported annually to and reviewed by the  Board. The Company’s Chief Compliance Officer and Chief Financial Officer are  responsible for managing and coordinating the Company’s political contributions  and expenditures under the Policy and monitoring the operation and  effectiveness of the Policy.

 On an annual basis, management will  report to the Nominations and Corporate Governance Committee and the Board on  prior-year corporate-wide political contributions and expenditures to ensure  alignment with the Policy and the Company’s objectives and values.

The Board must approve any amendment to the  Policy.

Company Contributions, Expenditures, and Lobbying

Corporate Contributions  and Expenditures

  To the extent legally permitted and  deemed appropriate and authorized by the Company’s Chief Compliance Officer and  Chief Financial Officer, in consultation with senior management of the Company,  the Company may consider corporate contributions consistent with the Policy to  (a) candidates running for public office; (b) political parties and committees;  (c) entities operating under section 527 of the Internal Revenue Code of 1986,  as amended (the “Code”), and other tax-exempt organizations when such  contributions are used for political purposes and are not deductible by the  Company under Section 162(e) of the Code; and (d) support issue or ballot  measure campaigns and committees. As provided below, the  Company will disclose on an annual basis all of the foregoing contributions or  expenditures made by the Company that are not deductible by the Company under  Section 162(e) of the Code.  

Trade Associations

The Company belongs to various trade  associations and trade groups. The Company believes that these organizations  help advance a long-term public policy agenda helpful to the Company’s business  interests and goals because the Company’s  positions on public policy issues are often communicated through these  organizations, which enables the Company to reach government officials more  efficiently and in concert with industry partners. However, the Company’s  positions do not always align with the positions taken by these organizations.

Some trade associations and trade groups  may utilize a portion of membership dues for non-deductible state and federal  lobbying and political expenditures. Under the requirements of Section 162(e)  of the Code, the Company receives information from trade associations and other  tax-exempt trade-industry organizations regarding the amount of funds received  from the Company that are used for lobbying expenses and political expenditures  and are not deductible by the Company for income tax purposes according to IRS  statutes. As provided below, the Company will disclose on an annual basis, to  the extent available to it, the portion of payments to trade associations and  other tax-exempt trade-industry organizations reported to the Company as being  used by such entities for political purposes and that are not deductible by the  Company under Section 162(e).

Lobbying

Federal and state disclosures regarding lobbying activities by the  Company and outside consultants that lobby on its behalf are publicly  available. In accordance with the Lobbying Disclosure Act of 1995, as amended (the  “LDA”), and comparable state laws, the Company and outside consultants that lobby  on its behalf file required disclosure reports with the Clerk of the House and  Secretary of the Senate regarding payments for all federal lobbying activities  and with applicable state agencies regarding payments for state lobbying  activities.  As provided below, the Company will disclose on an annual basis  the amounts paid by the Company, including to outside consultants that  lobby on behalf of the Company, for lobbying activities.

Political Action Committee

The Company sponsors a  political action committee, the Smith & Wesson Holding Corporation Political Action Committee (the “SWHCPAC”). The SWHCPAC is funded exclusively  through voluntary contributions from the eligible restricted class of the  Company, and the SWHCPAC has received, and may continue to receive, voluntary  contributions from stockholders and the families of the foregoing groups. Those  participating in the SWHCPAC are not reimbursed, directly or indirectly, for  political contributions or expenses. All SWHCPAC contributions are fully  disclosed in reports filed with the Federal Election Commission (the “FEC”) and  can be accessed by going to the FEC’s website at www.fec.gov. The Policy does not apply to the actions of  SWHCPAC.

Disclosure

The Company will post the Policy on its corporate  website (http://aob.com). In addition, for each fiscal year beginning with the Company’s 2015 fiscal  year, in the event the Company makes political contributions or expenditures in  the United States that are not deductible by the Company as “ordinary and  necessary” business expenses under Section 162(e) of the Code in excess of  $50,000 in the aggregate during such fiscal year, the Company will prepare and  post on its corporate website an annual report on such political contributions  and expenditures. The Company’s annual disclosure regarding such non-deductible  amounts, if required, will include the following information:

  • contributions to or expenditures in  support of or opposition to political candidates, political parties, or political  committees;
  • dues, contributions, or other payments  made to tax-exempt “social welfare” organizations and “political committees”  operating under sections 501(c)(4) and 527 of the Code, respectively, and to  tax-exempt entities that write model legislation and operate under Section  501(c)(3) of the Code to the extent that such amounts are non-deductible; and
  • the portion of dues or other payments  made to a tax-exempt entity, such as a trade association, that are used for an  expenditure or contribution and that are reported to the Company as not deductible  under Section 162(e) of the Code.

Prior to posting,  the annual report will be presented to the Nominations and Corporate Governance  Committee and the Board.

Effective Date: December 16, 2014

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