IM����

Political Contributions

IM���� does not have a Political Action Committee and, accordingly, does not make direct contributions to political candidates, parties or committees at the federal level. Generally, our political contributions are relatively small. Our direct political contributions to Internal Revenue Code 527 organizations and/or political associations in respect of state and local matters for the last three years included the following:

	Political Campaign Support	Infrastructure Funding	Regulatory Reform	Total
2023	$58,000	$25,000	$8,900	$91,900
2022	$16,500	$88,750	—	$105,250
2021	$28,000	$28,500	$11,000	$67,500

If a proposed contribution, dues payment or donation to a 501(c)(4) community benefit organization, 501(c)(6) trade association, or 501(c)(3) charitable organization will be used for a lobbying or political purpose or has been requested by a government official or their family, it must be approved using the same process to which other political contributions are subject pursuant to our .

IM���� makes contributions to state and local candidates, political parties and committees in jurisdictions where applicable by law. A list of such political contributions may be found .

From time to time, IM���� makes contributions to certain 501(c)(4) tax-exempt organizations that we believe further the goals of IM���� and the communities in which we operate. Annual contributions to the following 501(c)(4) tax-exempt organizations are provided .

From time to time, IM���� has donated in support of ballot measures. Annual contributions to the following initiatives in order to influence the outcome of a ballot measure are provided .

From time to time IM���� has donated to certain 501(c)(6) tax-exempt organizations other than 501(c)(6) trade associations which are discussed below. Annual contributions to 501(c)(6) organizations are provided .

IM���� has not made contributions to any 527 groups and/or political associations in the last three years. IM���� does not make contributions to Super PACs using corporate funds.

Independent Expenditures

While permitted by law, IM���� has elected not to make independent expenditures or contribute to independent expenditure committees or to other organizations (e.g., 501(c)(4) and 527 organizations) for the purpose of making independent expenditures.

Trade Associations

We are a member of various national and state trade associations, in addition to the U.S. Chamber of Commerce, that make political contributions. We believe all the groups of which we are a member share and otherwise further our goals, as well as providing both a useful forum for discussing issues of general industry significance and an effective platform for advocating positions on issues of importance to each association's members, including IM����. We periodically review lobbying registrations submitted by these associations as part of our continuing membership and do not believe any have taken any position as part of their lobbying efforts that are inconsistent with our stated strategy or in conflict with the interest of our shareholders, though from time to time such associations may take positions on issues that are not fully representative of ours. Overall, we believe that IM����’s membership in such associations is in the long-term interests of the Company and its shareholders.

Our total indirect lobbying payments made in 2023 were $232,484. Below is a list of names of U.S. trade associations of which the Company was a member in 2023 and whose annual membership dues are $25,000 or more. Also disclosed below are the amount of dues reported by trade associations as political contributions in 2023.

Trade Association1	Membership Dues	Amount of Membership Dues Reported as Political Contributions2
Portland Cement Association	$764,353	—
National Ready Mixed Concrete Association	$412,116	Less than $25,000
National Stone Sand & Gravel Association	$369,131	Less than $75,000
American Road and Transportation Builders	$292,500	—
Cement Council of Texas	$265,129	—
Texas Aggregates and Concrete Association	$196,313	—
United States Chamber of Commerce	$150,000	Less than $75,000
National Asphalt Pavement Association	$87,574	Less than $25,000
California Nevada Cement Association	$74,671	Less than $25,000
Colorado Stone Sand and Gravel Association	$67,505	Less than $25,000
North Carolina Aggregates Association	$64,416	Less than $25,000
Iowa Limestone Producers Association	$50,703	Less than $25,000
Georgia Construction Aggregates Association	$49,839	Less than $25,000
National Lime Association	$44,496	—
Maryland Transportation Builders and Materials	$40,287	Less than $25,000
North Carolina Chamber	$39,710	Less than $25,000
Colorado Contractors Association	$35,438	—
South Carolina Aggregates Association	$27,170	—

¹All trade associations are in the United States. Includes associations and coalitions where contributions / dues are greater than $25,000.
²Amounts are based on percentage of dues reported by the trade association as being used for “Lobbying expenditures” per the definition at Section 162(e)(1) of the Internal Revenue Code.

Lobbying on Infrastructure and Climate Change

Given our businesses’ relatively low greenhouse gas (GHG) emissions profile, IM���� does not conduct, at the federal or state level, any direct lobbying on climate change matters. We periodically review positions taken by the trade associations of which we are a member and are not aware of any recent lobbying efforts that are inconsistent with the Paris Agreement.

• The Portland Cement Association (PCA), the only cement industry association in which we are a member, recently adopted and published its own “Roadmap to Carbon Neutrality” for the cement and concrete industry, looking across the value chain from clinker production to carbon capture and sequestration (CCS). Among other things, the Roadmap calls for greater market acceptance of alternative fuels usage and low-carbon cement blends, as well as increased research and investment in CCS technologies.
• The U.S. Chamber of Commerce, which represents U.S. businesses across all sectors, has published “Our Approach to Climate Change”, which includes its support for U.S. participation in the Paris Agreement and acknowledges that our climate is changing, that humans are contributing to these changes and that “inaction is not an option.” The Chamber has pledged to support its members in developing, financing and implementing the technology and other solutions needed in mitigating GHG emissions, increasing fuel efficiency and use of renewable fuels and investing in commercially-viable technological solutions for lower-carbon infrastructure and CCS.

We also are closely monitoring relevant industry developments in key areas relating to climate change. For example, as recognized by a number of international organizations (including the International Energy Agency) as well as various industry associations, the cement sector’s ability to contribute to limiting GHG levels in a manner consistent with the goals of the Paris Agreement depends on successful future development and implementation of CCS technologies on a commercial scale, which does not yet exist. Similarly, acceptance of lower clinker content cements in the United States by federal and state Departments of Transportation and ASTM International may also be critical in allowing the cement sector to achieve carbon neutrality across the value chain by 2050.

Oversight on Political Activities and Trade Associations

From a governance standpoint, our Finance Committee, which is comprised exclusively of independent directors, oversees the Company’s political and lobbying expenditures and activities, develops and oversees IM����’s policy on political expenditures and reviews IM����’s political expenditures, payments to trade associations and any such expenditures and payments that may be used for political purposes. This includes setting an annual cap of $250,000 on total Company spending, as well as capping any individual Company contribution at $25,000 annually, and ensuring that such spending is consistent with IM����’s business interests, strategy and goals. All political expenditures are reviewed by our Chief Financial Officer after consultation with our General Counsel’s office, and final authorization is required from the Chief Executive Officer or an authorized delegate. This arrangement ensures not only that such activities comply with applicable law, but also that all activities further the long-term interest of IM���� and our shareholders. In addition, our lobbying and political expenditures and our payment to trade associations and other tax-exempt organizations that may be used for political purposes are reviewed annually by management with the Finance Committee, which reports its review to the full Board of Directors. The Finance Committee’s charter is available on . The Finance Committee makes recommendations to the Board of Directors with respect to any changes in IM����’s policy on political expenditures.

All of IM����‘s employees, contractors and agents acting in the Company’s name are governed by our , which is a robust set of procedures that applies to political and advocacy activities of IM����, our subsidiaries and our affiliates, including political contributions to trade associations, political parties, campaigns and individual candidates, lobbying activities or gifts to public officials or public employees. This policy provides that all political and advocacy activities, including contributions, by IM���� must comply with federal, state and local requirements associated with participating in the policy-making and political process, as well as our Code of Ethical Business Conduct.

Our Code applies to all employees and directors of IM����. The Code explicitly acknowledges the “right of its employees to support any candidate or political party” with their own time and money but states that no IM���� assets, funds or employee work time may be contributed to any political party, campaign or candidate without “the prior approval of the company’s Political Contribution Committee or Legal Department”, who review the requests for compliance with applicable law and have final authority over our corporate political spending.

Although it is the Company’s policy to encourage our employees to participate in trade associations, both at the national and state levels, to monitor industry policies and trends, build skills and to participate in civic activities, the Code makes clear that, despite IM����’s membership in any trade association, the Company’s position on issues may from time to time differ from that trade association.

Any employee who wishes to request that IM���� contribute to state or local candidates, candidate committees, political action campaigns, ballot questions, 501(c)(3) donation, political organizations or other political committees is required to submit a completed form to our Political Contributions Committee (PCC), which consists of senior management. The PCC then provides an annual report on such contributions to our Finance Committee.

Public Policy

We engage with legislatures and regulators to educate them on issues that impact IM���� and our industry. These are consistent with our strategy and our core values. The top issues for us in recent years have been infrastructure investment as well as health and safety.

Aggregates are the second most utilized product in the world and are the foundation to create buildings, roads, airports, bridges, schools and communities. They are indispensable in developing the infrastructure needed to access clean water, deliver reliable energy, and advance environmental stewardship. We advocate for increased investment in our nation’s roads, buildings and the environment through efficient material sourcing and transportation, along with sustainable construction supply chains and effective project delivery, and for provisions that streamline permitting and approval of large infrastructure projects.

The health and safety of our employees is a core value for us and an area in which we spend extraordinary management resources to achieve our goal of zero incidents. We believe open conversations with our regulators, including the Mine Safety and Health Administration (MSHA) and Occupational Safety and Health Administration (OSHA), to improve the applicable rules and regulatory inspections promote a safer and healthier workplace.