The Sherwin-Williams Company (“Sherwin-Williams” or the “Company”) uses public policy engagement to advocate for positions that are impactful to Sherwin-Williams and advance the interests of our Company, including directly and indirectly through our membership in trade associations and organizations.

Sherwin-Williams maintains policies and procedures governing our lobbying activities and political engagement that are designed to promote compliance with applicable laws and regulations, including the Sherwin-Williams Political Engagement Policy and our Code of Conduct. The Sherwin-Williams Political Engagement Policy and the Code of Conduct provide that no employee or director may engage in any activity on behalf of Sherwin-Williams with the intention of influencing legislation or rulemaking, or engage lobbyists or others to do so, without the approval of Sherwin-Williams’ Government Affairs Department. 

Sherwin-Williams’ political engagement activities are overseen by senior executive management and the Board of Directors (the “Board”). The Board oversees Sherwin-Williams’ public policy engagement and advocacy activities and receives regular updates from management. In addition, the Chief Legal Officer must approve in advance any political contribution made with Company funds or resources and the Government Affairs Department must approve, in writing, any activity on behalf of Sherwin-Williams with the intent to influence legislation or rulemaking or the engagement of lobbyists or others to do so.

Political Contributions

Our Code of Conduct prohibits employees from engaging in conduct that would create the misimpression that any personal political activities are being done for or on behalf of the Company including, without limitation, by using Sherwin-Williams’ email system or letterhead.

Political Action Committee (PAC)

Although permissible by law, Sherwin-Williams does not currently have a political action committee.

Direct Lobbying

Sherwin-Williams engages with government and regulatory officials in the countries and regions in which we operate on key issues and emerging risks and opportunities. Depending on the jurisdiction, this engagement includes advocating on labor, transportation, energy, environmental, tax, and trade issues. Our public policy advocacy efforts follow applicable laws in each jurisdiction, and we report on those efforts and their expenses as required by law. For example*:

• In the United States, the Company discloses its U.S. federal lobbying activity and expenditures as required by law. Each quarter Sherwin-Williams files Form LD-2 to report its federal lobbying activities to the Office of the Clerk of the House of Representatives and the Secretary of the Senate.  Semi-annually, Sherwin-Williams files Form LD-203 to disclose certain political and honorary contributions as required by law.
• U.S. state and local lobbying activity and disclosure reports are filed in each jurisdiction where we engage in lobbying activity as required by law. These disclosures are publicly available in all jurisdictions with public access portals. In 2024, we were required to file reports in the following states:
  • New Jersey
  • Ohio
  • Pennsylvania
  • South Carolina
  • Vermont
• The Company reports its lobbying efforts in foreign jurisdictions as required by applicable law. In 2024, we were required to file reports in the following jurisdictions:
  • European Union
  • Germany

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We maintain procedures to subject prospective outside lobbying firms to a due diligence process in advance of their retention in order to comply with the law and uphold Sherwin-Williams’ high ethical standards.

Grassroots Lobbying

Grassroots lobbying refers to making disbursements for efforts to shape public opinion regarding legislation or urging the general public to contact public officials regarding legislation. As a general matter, Sherwin-Williams does not engage in grassroots lobbying.

Sherwin-Williams belongs to several trade associations. These associations play an important role in our industry and provide the Company with opportunities to engage in the legislative and regulatory process and influence matters that impact the industry, as well as matters that are critical to our customers, our employees, and the communities in which we operate.

We actively participate in various trade associations and industry-based organizations to understand and manage risks associated with changing government policies and legal landscapes. Listed below are the trade associations/industry-based organizations to which the Company contributed in excess of $25,000 for 2024.

Sherwin-Williams participates in trade associations where membership provides value to our business. Each association is different, however Sherwin-Williams values:

• Opportunities to understand a range of views on issues affecting our industry
• Engagement opportunities for employees or customers across the industry
• Sharing best practice and technical insights
• Providing input to the development of industry standards
• Sharing the Company’s position and perspectives
• Opportunities to improve the operating environment

While the groups in which we participate are necessarily focused on issues and positions important to Sherwin-Williams, the Company does not control the advocacy agenda of any trade association in which it participates.  Moreover, the lobbying activities of the groups of which we are members may not necessarily represent our positions at all times, given the variety of business issues in which many trade associations and other groups are engaged. While we do not always agree with the positions taken by these groups, we generally believe that our membership allows us to more effectively advance Sherwin-Williams’ business positions and interests. The Company periodically evaluates our trade association memberships and policy alignment and when we disagree with such groups on a position, we employ a range of approaches to make our concerns heard. We believe that our participation in these groups contributes balance and greater perspective.

Where significant differences in policy positions arise, we may provide greater clarity on our own positions and work to share our position in the association. If differences remain significant, Sherwin-Williams will assess the value of the Company’s continued participation in the association.