POLITICAL CONTRIBUTIONS POLICY STATEMENT

Wachovia Corporation Political Contributions Policy

As a large financial institution, Wachovia is subject to significant regulation at the federal, state and local levels of government, which can have a profound impact on the way we operate our business, support our employees and serve our customers and communities. The Government Relations group, which is part of Wachovia's Legal Division, works closely with all divisions of Wachovia to manage the legislative and political activities of Wachovia in a manner consistent with good corporate governance practices and in compliance with all legal requirements.

Wachovia Corporation is prohibited by law from making contributions or expenditures in connection with any federal and most state elections, and because of its national charter, Wachovia Bank, N.A. is prohibited from making any political contributions. Even when permitted by applicable law, Wachovia’s policy is that it does not use corporate funds to make contributions to political candidates, political parties or committees, or political entities organized under Section 527 of the Internal Revenue Code. 

Wachovia’s political activities consist primarily of Wachovia’s sponsorship of the Wachovia Employees Good Government Funds, which are employee-funded, voluntary, non-profit, non-partisan political action committees (PACs).  Our PACs solicit and accept voluntary contributions from eligible employees and make political contributions to federal, state and local candidates and candidate committees that promote responsible government and support effective financial legislation important to Wachovia and its stockholders.  Any employee who is a member of a PAC may request a PAC contribution for a candidate for office.  Funding decisions regarding political contributions by the PACs are subject to the oversight of the board of trustees for each PAC, which include employees who represent various lines of Wachovia’s business and the geographical locations where we conduct business, and are based upon advancing the best interests of Wachovia and its stockholders and the recommendations made voluntarily by contributing Wachovia employees.     

Wachovia believes that our PACs are a transparent means by which our employees can provide contributions to candidates for public office who promote responsible government and support constructive financial services legislation.  All PAC receipts and contributions are required to be reported to the various federal and state elections commissions, where that information is available for public disclosure.  Wachovia’s PACs are subject to internal oversight processes, policies and procedures, including annual internal audits that are reviewed by Wachovia’s Audit Committee.

Additional information about Wachovia’s policies regarding political activities and dealings with government officials, including compliance with Municipal Securities Rulemaking Board Rule G-37, is set forth in Wachovia’s Code of Conduct and Ethics, which is available on our web site at www.wachovia.com/file/CorpGovCodeofConductEthics.pdf .

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