to political causes using their personal funds, IPG’s Code of Conduct and Anti-Corruption Policy provide that IPG and its agencies may not contribute any company funds, facilities or services to any candidate for public office, any political party or official thereof, any political action committee, or any political initiative, referendum or other form of political campaign without prior approval from IPG’s General Counsel and Chief Risk Officer (other than political marketing and communication services or lobbying activities, which are conducted by an IPG company whose regular business activities consist of such services or activities).