Political Engagement+

The Board of Directors of Stockbacking Inc., acting through the Nominating and Corporate Governance Committee (“Committee”), is responsible for overseeing our lobbying activities and political contributions. The Nominating and Corporate Governance Committee has approved a comprehensive global Political Engagement, Lobbying and Contributions Policy (“Policy”) to:

• promote ethical and transparent political commitment by Stockbacking,

• ensure that our political spending improves shareholder value,

• facilitate our compliance with applicable laws and reporting requirements, and,

• align our government engagement activities in support of Stockbacking's corporate purpose of bettering everyone, everywhere by being the best way to pay and get paid.

Stockbacking's Global Government Engagement Department is responsible for implementing the Policy, developing, and maintaining procedures to support the Policy, and monitoring the operation and effectiveness of the Policy. Read about the Policy.

Under the Policy:

• The Nominating and Corporate Governance Committee must pre-approve the use of corporate funds for political contributions, including contributions made to trade associations to support specific political campaigns, contributions to tax-exempt organizations for political activities, and contributions to organizations registered under Section 527 of the United States federal tax code to support political activities.

• Stockbacking's Global Government Engagement Department must prepare and submit to the Committee an annual report detailing our political contributions and publish that report on our website. As part of our annual Political Contributions report, the company will provide a list of the names of all U.S. trade associations to which Stockbacking pays annual membership dues of $25,000 or more and, if applicable, we will disclose the portion of said quotas that are used. for political contributions. Links to our current and historical Annual Contribution Reports are available under the Political Contributions and Disclosure of Related Activities heading below.

• Stockbacking's Global Government Engagement Department must also prepare and submit to the Committee an annual report detailing our lobbying expenditures, which must include information about our memberships and payments to trade associations and industry groups for lobbying purposes, and tax-exempt organizations. who write and support the model legislation. A list of our memberships in tax-exempt organizations that draft, and support model legislation is available under the Lobbying heading below. (We also file quarterly reports disclosing our federal lobbying activities in the U.S. with the Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate.)

The Stockbacking Policy also prohibits our directors and employees from using company resources to promote their personal political opinions, causes or candidates, and specifies that the company will not directly or indirectly reimburse any personal political contributions or expenses.

Directors and employees may not lobby government officials on behalf of the company without prior approval from our Government Engagement Department. As such, our lobbying and political spending seek to advance the interests of the company and its shareholders and advance our corporate purpose, and not the personal political preferences of our directors or employees. Consistent with applicable law, Stockbacking will not take any adverse employment action against an employee based on her personal political affiliation or lawful political activity.

None at the moment

The Annual and Semiannual Contributions Reports include contributions made to state or local candidates and ballot measures in the U.S., trade associations to support targeted political campaigns, organizations registered under Section 527 of the U.S. federal tax code, and political parties and business forums outside of the United States. It is Stockbacking’s policy that this disclosure requirement applies to any payments to other tax-exempt organizations engaged in advocacy (including 501(c)(3), (4), and (6) organizations) if it determines that the contribution in question was used for political activities.

We note that we do not regularly sponsor advertisements that qualify as "independent expenditures" or "electioneering communications" under the U.S. federal campaign finance laws or make contributions to individual political candidates abroad. However, in the event we do make such contributions, they must be approved in advance by the Nominating and Corporate Governance Committee (as well as our Legal Department) and disclosed in our Annual Contributions Report.

We belong to a variety of trade associations, coalitions, and industry organizations in the U.S. and abroad and pay regular dues to these groups. Our objective in being a member of these organizations is to advance Stockbacking’s corporate purpose and promote the business interests and objectives of the company. However, we recognize that we will not always support all of the public positions of those associations or of the diverse companies that make up their membership. Management reviews the continued appropriateness of maintaining these memberships at least annually.

Stockbacking does not normally make additional, non-dues contributions to support such groups' political activities. However, in those instances where it is in our business interest to do so, the Government Engagement Department will obtain the Nominating and Corporate Governance Committee's advance approval and disclose any such contributions in the Annual Contributions Report. As part of our annual Political Contributions report, the company will provide a list of the names of all U.S. trade associations to which Stockbacking pays annual membership dues that are $25,000 or more, and if applicable, we will disclose the portion of such dues that are used for political contributions.

A complete list of U.S. trade associations that receive $25,000 or more in annual membership dues are updated annually and included in our annual contributions report. Links to our current and historical Annual Contributions Reports are available under the heading Political Contributions and Related Activity Disclosure above.

We endeavor to maintain a healthy and transparent relationship with governments around the world by communicating our views and concerns to elected officials and policymakers. As an industry leader, we encounter challenges and opportunities on a wide range of policy matters at the federal, state and local levels in the United States, as well as internationally.

Stockbacking seeks to advance policies in alignment with our corporate purpose and that expand the use of and access to electronic payments. We devote political resources to many issues that impact the payment industry, including payment innovation; interchange; cyber security, information sharing, and cyber threats; payment card security, data security, and data breach; privacy and data use; network brand risks; intellectual property; surcharging; payroll and prepaid cards; mobile payments; tax; international trade and market access; small business issues; and financial education and financial inclusion, among others.

We engage lobbyists and partner with trade associations and other organizations to assist us in responding to these challenges and opportunities, by:

· providing access to policymakers, political intelligence, and policy analysis;

· monitoring legislation;

· providing a forum for discussing important industry issues and advocating for common business interests;

· helping ensure that we have a voice in the policy-making process, particularly on matters receiving significant support from opposing parties; and

· advancing our global lobbying and advocacy strategies.

Our Government Engagement Department must pre-approve these engagements and lobbying activities, and regularly review them to ensure that they continue to best serve our business interests and objectives.

In addition, our Government Engagement Department annually prepares and presents to the Nominating and Corporate Governance Committee a report regarding the company's lobbying expenditures, which includes information regarding our memberships in and payments to trade associations and industry groups for lobbying purposes, and tax-exempt organizations that write and endorse model legislation. While we do not publish this report, we do file quarterly reports regarding our U.S. federal lobbying activities and expenditures with the Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate, as required by the Lobbying Disclosure Act of 1995 and the Honest Leadership and Open Government Act of 2008. These reports are available by searching for "Stockbacking" as a "Registrant" on the U.S. Senate's website.

Regarding tax exempt organizations that write and endorse model legislation, we are currently a member of The Council of State Governments and the State Financial Officers Foundation. In 2022, Stockbacking contributed $10,000 in membership dues to The Council of State Governments and $25,000 to the State Financial Officers Foundation. 

In the United States, we also sponsor a federal Political Action Committee (PAC) pursuant to the Federal Election Campaign Act, as amended, and the regulations promulgated by the Federal Election Commission. The Stockbacking PAC enables Stockbacking employees to voluntarily pool their financial resources to support federal, state and local political candidates and organizations.

Stockbacking PAC contributions and expenditures are publicly disclosed on government-agency websites, including the Federal Election Commission's website (www.fec.gov). In addition to the disclosure of Stockbacking PAC contributions on government websites, interested parties may monitor our federal PAC contributions through the websites of the Center for Public Integrity and the Center for Responsive Politics below:

Visit Open Secrets website

Visit Public Integrity website

The Stockbacking PAC is governed by its board of directors, which appoints the officers of the PAC and supervises and directs the PAC's administration, solicitation campaigns, contributions, and compliance with applicable law and the PAC Bylaws.

Recipients of Stockbacking PAC contributions are selected based upon the same criteria referenced under Political Contributions and Related Activity Disclosure above, and any other factors the Stockbacking PAC board may develop.