Lobbying & political activity

Political contributions

United participates in the political process by making political contributions to candidates, political parties and political committees. All political contributions, and the reporting thereof, comply with applicable laws. United and its company-sponsored political action committee make contributions consistent with our public policy objectives. Contribution decisions are based on meeting one or more of the following criteria:

• The candidate’s involvement with and position on issues affecting the airline industry
• The presence of United’s employees, facilities or resources in the candidate’s district or state
• The candidate’s demonstrated leadership or potential for leadership
• The candidate’s committee assignments and seniority within Congress and state or local governments
• The candidate’s alignment with United’s shared purpose and values
• No contribution may be given or offered in anticipation or recognition of, or in exchange for, an official act.

United PAC contributions

United has established the United Airlines, Inc. Political Action Committee (the “UAPAC”) to encourage its employees to participate in the political process. The UAPAC is a voluntary unincorporated organization established pursuant to the Federal Election Campaign Act of 1971, as amended. In accordance with federal law, United’s executives, administrative personnel and stockholders may make voluntary contributions to the UAPAC. Foreign nationals and represented employees may not contribute to the UAPAC. The UAPAC is governed by a board of directors (the “UAPAC Board of Directors”), which consists of senior leaders from across United. The UAPAC Board of Directors also oversees all of United’s corporate political contributions and provides annual reports regarding United’s corporate political contributions to the Public Responsibility Committee of the United Airlines Holdings, Inc. Board of Directors (the “UAL Board”).

As required by U.S. federal law, we file regular reports that disclose our political contributions. These contribution disclosure reports may be viewed at the Federal Election Commission Filing and Reports site by searching for “United Airlines, Inc. Political Action Committee.” We file similar publicly available reports with state and local agencies as required by state and local law.

Corporate political contributions

Federal law prohibits United from contributing corporate funds to candidates for federal office. Accordingly, United does not contribute corporate funds to federal candidates, federal political parties or federal PACs. United does not make direct, independent expenditures urging the defeat or election of any candidate.

United may make contributions to state or local candidate campaigns, parties, political committees and ballot measures, to the extent permitted by applicable law, with the approval of the UAPAC Board of Directors.

We file publicly available reports that disclose our political contributions with state and local agencies as required by state and local law. You can find a list of corporate political contributions below. We update this information semi-annually:

• 2024 Corporate Political Contributions
• 2023 Corporate Political Contributions
• 2022 Corporate Political Contributions
• 2021 Corporate Political Contributions

Corporate trade association memberships and indirect lobbying

As a business that operates in nearly every state and in countries across the world, we are members of a wide range of organizations, from general business associations to others more specific to our industry. As part of our collaborative efforts, United works directly with policymakers as well with coalitions of businesses and NGOs, think tanks and traditional business trade associations that represent a wide variety of United’s policy interests in the general business community and the aviation industry.

In particular, we belong to a number of industry associations, which we believe gives us a platform to share and receive business expertise and technical knowledge for the betterment of our industry. This involvement also allows us to advocate for policies that encourage a thriving and competitive industry and business environment.

A portion of the support provided to these organizations may be used by the organizations for lobbying, though we have no direct control over how those expenditures are directed. Our primary trade associations advocate for a broad range of issues, including operational efficiency improvements, infrastructure investments, health and safety standards, tax policy, climate strategy and workforce development, among others. While our positions may not always fully align with these organizations, we work with them to advance progress where opportunities exist and use our influence with these organizations to advocate for policy changes when needed.

Lobbying expenditures

As required by U.S. federal law, we file quarterly reports that disclose our federal, state and local lobbying expenditures and detail our federal lobbying activities. United files using the Internal Revenue Code (IRC) definition of lobbying (Method C), which includes activity by employees who engage in qualified legislative lobbying at the federal, state or local level, as well as federal executive branch lobbying as defined under the IRC; qualified payment to lobbying consultants; and the portion of our trade association payments that are not tax deductible under § 162(e)(1) of the IRC. In 2023, United Airlines, Inc. reported a total of $9,030,000 in expenses related to lobbying activity. These reports, as well as reports for prior years, may be found on the House and Senate websites, click here to view reports. We file similar publicly available lobbying reports with state and local agencies as required by state and local law, which may have different reporting requirements than federal law. Lobbying firms we hire are required to file similar reports. The trade associations we belong to are also subject to public disclosure obligations regarding their lobbying efforts. Annually, we publish a list of trade associations where over $25,000 of our dues and other payments are attributable to the organization’s non-deductible activity, such as lobbying, as identified by the organization. We also publish a list of social welfare organizations (qualifying for tax exemption under Section 501(c)(4) of the IRC), to which we make payments over $25,000.

In fiscal year 2023, there were four trade associations where an excess of $25,000 of United’s annual dues and other contributions were used for lobbying activities. These trade associations and the amounts attributable to lobbying are outlined below.

1. Airlines for America (A4A): $1.03M
2. Business Roundtable (BRT): $84,000
3. U.S. Chamber of Commerce: $36,750
4. U.S. Travel Association: $26,670

In fiscal year, 2023, there were six social welfare organizations that United made over $25,000 in payments to outlined below. These contributions totaled $4.625m.

1. Bay Area Council
2. Chicago for the People
3. The Coalition to Protect America’s Regional Airports
4. Denver Vibes
5. Equality California
6. New California Coalition

Accountability and oversight

United and its subsidiaries are committed to the highest ethical standards, and we have procedures and policies in place designed to ensure that our policy advocacy, political contributions, lobbying expenditures and related activities, are subject to appropriate oversight. We take diligent steps designed to ensure that we are in compliance with applicable rules, regulations and our Code of Ethics and Business Conduct, which is publicly available on our website at ir.united.com At least annually, the Public Responsibility Committee reviews this policy and recommends any revisions it deems necessary or appropriate to the UAL Board.

Lobbying activity oversight

Our policy advocacy and lobbying activities are determined by senior management with oversight by the UAL Board, which has delegated this oversight responsibility to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization oversees and executes our policy advocacy, lobbying expenditures and related activities. Our Senior Vice President of Government Affairs and Global Public Policy also reports regularly to the UAL Board on our policy advocacy, lobbying expenditures and related activities, periodically reviewing with the Public Responsibility Committee the strategic priorities for United’s lobbying activity.

Political contributions oversight

The UAL Board has delegated oversight responsibility of our political contributions to its Public Responsibility Committee. Our Government Affairs and Global Public Policy organization makes recommendations on political contributions to the UAPAC Board of Directors, who, in turn, reviews and approves all UAPAC and corporate political contributions. Our Senior Vice President of Government Affairs and Global Public Policy provides the Public Responsibility Committee with an annual report on the political contributions of the Company and the UAPAC for the prior year.