Political Engagement and Contribution Policy

Crown Holdings, Inc. believes it is appropriate for the company to participate in the political process under certain circumstances to advance the company’s business interests. Political contributions, where permitted, are a legitimate and potentially important method of political expression. The actions and public policy positions of elected and appointed officials at the state/local, national and international levels have the potential to significantly impact our business, our employees and the communities in which we operate. It is the policy of Crown Holdings, Inc. and its subsidiary companies that Crown and its subsidiaries will participate in the political process, including through financial contributions, but only to the extent that it is permissible under national, state, and local laws, rules and regulations.

Unless otherwise noted, the specific policies and references in this policy to Crown or company “employees” apply to each employee, officer and director of Crown Holdings, Inc. and its subsidiaries. Crown will implement the specific policies in a manner consistent with the applicable laws, rules and regulations in the jurisdictions in which Crown Holdings, Inc. and its subsidiaries conduct business.

Crown supports everyone’s right to be actively involved in the political process in support of the issues, candidates or political parties of their choice. However, we stress the importance of clearly distinguishing between personal involvement and involvement on behalf of the company. Accordingly, our employees are prohibited from using Crown’s name, funds, or resources in their personal support for candidates or political causes or organizations, unless permitted by applicable law and approved in advance by the company’s General Counsel.

A. Crown Political Contributions

Crown is not permitted to contribute directly to political candidates for elective federal office in the United States, but it may create a “political action committee,” funded by voluntary employee contributions, which can make such contributions (subject to monetary limitations) to candidates and other political action committees. Similar prohibitions apply in certain U.S. states and other countries, however some of those U.S. states permit the company to operate state-level political action committees. Crown’s General Counsel must approve any contribution of company resources, including the use of company premises, use of company equipment, or monetary payments, to any political candidates, political parties, or other persons or organizations who seek to use the funds to directly influence the outcome of an election or ballot measure.  In the United States, this includes candidate committees, political party committees, political action committees (other than for the administrative expenses of Crown Cork & Seal Company Inc. PAC or Crown’s state-level political action committees, as permitted by law), ballot measure committees, independent expenditures or 501(c)(4) groups.  No contributions will be approved unless permitted under applicable law.

Additionally, Crown employees may not submit a personal political contribution for expense reimbursement by Crown and Crown funds may not be used to reimburse employee personal political contributions.

B. Participation in Supporting Trade Associations

Where permitted by applicable law, Crown may participate in and financially support trade associations and industry groups representing Crown’s interests. Involvement with these organizations allows insights into important issues for our industry and the business community and the ability to jointly advocate for public policies that support a healthy business environment for Crown. Because these trade associations sometimes represent a broad range of companies and industries, there may be instances where an association’s positions differ from those of Crown. Any contribution to a trade association that is intended to be part of the trade association’s contributions to candidates for political office, to political parties, or to other persons or organizations who seek to use the funds to directly influence the outcome of an election or ballot measure must be reviewed and approved by Crown’s General Counsel and will be disclosed annually in Crown’s voluntary disclosure of political contributions and activities.

C. Annual Report

At least annually, Crown’s General Counsel will provide a report regarding company expenditures made pursuant to this policy to the Chief Executive Officer and the Nominating and Corporate Governance Committee of the Crown Board of Directors. Crown will publish a voluntary disclosure of contributions made pursuant to this policy on Crown’s website.

D. Non-Compliance

Failure to comply with any applicable laws and regulations governing political contributions, lobbying activities, and gifts to government officials subjects the individual and Crown to potential civil and criminal penalties. Failure to comply with this policy can result in discipline, up to and including termination.

Contributions

Contributions made in the last five full calendar years are disclosed below. 

Pennsylvania Contributions

• 2021: $1,000 - Shapiro for Pennsylvania
• 2022: $1,000 - Friends of Frank Farry
• 2023: $0
• 2024: $0
• 2025: $0

Federal Contributions

• 2021: $0
• 2022: $0
• 2023: $1,000 - Casey Keystone Victory Fund
• 2024: $500 - Casey Keystone Victory Fund
• 2025: $0

Created: December 11, 2025

Amended: N/A

Last Reviewed: N/A