Registration - In-house Corporation

Newmont / Bernard Wessels, Managing Director North America

Registration Information

In-house Corporation name: Newmont
Responsible Officer Name: Bernard Wessels, Managing Director North America
Responsible Officer Change History
Initial registration start date: 2021-12-15
Registration status: Active
Registration Number: 953207-370657

Associated Communications

Total Number of Communication Reports: 43

Monthly communication reports in the last 6 months: 7

Version 7 of 8 (2023-11-06 to 2023-12-14)

Registration versions:

Version 7 of 8 (2023-11-06 to 2023-12-14)

Lobbying Information

Subject Matters

Aboriginal Affairs
Climate
Economic Development
Employment and Training
Energy
Environment
Fisheries
Industry
Infrastructure
International Trade
Labour
Mining
Natural Resources
Taxation and Finance
Transportation

Subject Matter Details

Grant, Contribution or Other Financial Benefit

Federal funding programs aimed at supporting training, innovation and decarbonization within the mining sector.

Policies or Program

Discussions with government officials on policies with respect to mining industry operations, innovation, corporate social responsibility, environmental permitting, sustainability and climate change, and to provide updates on Newmont's Canadian operations and projects.

Communication Techniques

Written communication
Oral communication

Government Institutions

Canadian Northern Economic Development Agency (CanNor)
Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC)
Environment and Climate Change Canada (ECCC)
Finance Canada (FIN)
Fisheries and Oceans Canada (DFO)
House of Commons
Impact Assessment Agency of Canada (IAAC)
Indigenous Services Canada (ISC)
Infrastructure Canada (INFC)
Innovation, Science and Economic Development Canada (ISED)
Intergovernmental Affairs Secretariat (IGA)
Natural Resources Canada (NRCan)
Prime Minister's Office (PMO)
Privy Council Office (PCO)
Transport Canada (TC)

Government institutions added through a monthly communication report

Invest in Canada Hub
Senate of Canada
Treasury Board Of Canada Secretariat (TBS)

In-house Corporation Details

Description of activities

Newmont is the world’s leading gold company and a producer of copper, silver, zinc and lead. In Canada we operate in Ontario and Quebec at the Musselwhite, Porcupine and Eleonore mines and also have exploration / development projects in the Yukon and BC.

Responsible officer name and position during the period of this registration

Bernard Wessels, Managing Director North America

Government funding

No government funding was received during the last completed financial year.

In-house Corporation Contact Information

Address:
3260 - 666 Burrard St
Vancouver, BC V6C 2X8
Canada

Telephone number: 604-696-3000

Parent Company Information

Newmont is not a subsidiary of any other parent companies.

Subsidiary Beneficiary Information

Goldcorp Inc
- 3260-666 Burrard Street
  Vancouver, BC V6C 2X8
  Canada
Goldcorp Kaminak Ltd
- 3260-666 Burrard Street
  Vancouver, BC V6C 2X8
  Canada
Newmont Corporation
- 6900 E Layton Avenue
  Suite 700
  Denver, CO 80237
  United States of America

Lobbyists Details

Senior Officers whose lobbying activities represent less than 20% of their Duties

No lobbyists added

Senior Officers and Employees whose lobbying activities represent 20% or more of their Duties

Keivan Hirji, Senior Sustainability & External Relations Specialist | Public offices held
John Mullally, Senior Director, Sustainability & External Relations | No public offices held
Christian Roldan, Study Manager, Coffee Mine Project | No public offices held
Gerry Stinson, Sustainability & External Relations Manager, Porcupine Mines | No public offices held
Stephanie Thibeault, Director Environmental Performance North America | No public offices held

Newmont/

The following names have been used on or after July 2, 2008

The following names have been used on or after July 2, 2008
Name	From	To
Newmont/	2021-12-15	current

Newmont

Responsible Officer History
Responsible Officer Name	From (YYYY-MM-DD)	To (YYYY-MM-DD)
Bernard Wessels	2022-10-17	Current
Mark Rodgers	2021-12-15	2022-10-17

Bernard Wessels, Managing Director North America (Corporation)

Learn more...

Registrants are required to submit a monthly communication report for each oral and arranged communication with a designated public office holder. The name of the most senior paid officer (i.e. the registrant) will appear on all in-house monthly communication reports, whether or not he/she participated in the communication.

Note: Monthly Communication Reports are due on the 15^th day of each month for communications that took place in the previous month.

Results below are sorted by posted date, beginning with the most recent.

Results 1-43 of 43

Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- George Chahal, Member of Parliament and Chair of the Standing Committee on Natural Resources | House of Commons
Subject Matter of the communication: Mining
Communication date: 2024-03-04
Posted date: 2024-04-15
Communication number: 370657-599103 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Melanie Campbell, Director | Stategic Policy | Natural Resources Canada (NRCan)
- Marc Serré, Parliamentary Secretary | Natural Resources Canada (NRCan)
Subject Matter of the communication: Mining
Communication date: 2024-03-04
Posted date: 2024-04-15
Communication number: 370657-599102 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Ray Kassam, Chief Strategy Officer | Invest in Canada Hub
- Bobby Kelly, Chief of Staff | Invest in Canada Hub
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-15
Communication number: 370657-588076 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Randi Anderson, Director of Policy | Minister's Office | Natural Resources Canada (NRCan)
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-14
Communication number: 370657-588075 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Alexander Muir, Chief of Staff to Deputy Minister | Natural Resources Canada (NRCan)
- Jeffrey Labonté, Associate Deputy Minister | Natural Resources Canada (NRCan)
- Michael Vandergrift, Deputy Minister | Natural Resources Canada (NRCan)
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-15
Communication number: 370657-588074 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Dennis Glen Patterson, Senator | Senate of Canada
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-15
Communication number: 370657-588073 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Tina Green, Assistant Secretary | Treasury Board Of Canada Secretariat (TBS)
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-15
Communication number: 370657-588071 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Michael Brewster, Director, Parliamentary Affairs | Environment and Climate Change Canada (ECCC)
Subject Matter of the communication: Environment, Fisheries
Communication date: 2023-09-11
Posted date: 2023-09-14
Communication number: 370657-576555 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Kevin Brosseau, Associate Deputy Minister | Fisheries and Oceans Canada (DFO)
Subject Matter of the communication: Environment, Fisheries
Communication date: 2023-08-31
Posted date: 2023-09-14
Communication number: 370657-576551 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Joshua Swift, Policy Advisor | Environment and Climate Change Canada (ECCC)
Subject Matter of the communication: Environment, Fisheries
Communication date: 2023-08-29
Posted date: 2023-09-14
Communication number: 370657-576553 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Claire Seaborn, Chief of Staff | Minister's Office | Natural Resources Canada (NRCan)
Subject Matter of the communication: Economic Development, Mining, Natural Resources
Communication date: 2023-05-12
Posted date: 2023-05-15
Communication number: 370657-566290 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Andrew Cooper, Regional Advisor | Minister's Office | Fisheries and Oceans Canada (DFO)
Subject Matter of the communication: Environment, Fisheries, Mining, Aboriginal Affairs
Communication date: 2023-04-21
Posted date: 2023-05-15
Communication number: 370657-566289 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Joshua Swift, Special Assistant - Ontario Desk | Environment and Climate Change Canada (ECCC)
Subject Matter of the communication: Mining, Natural Resources, Aboriginal Affairs
Communication date: 2023-04-20
Posted date: 2023-05-15
Communication number: 370657-566287 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Andrew Cooper, Regional Advisor | Minister's Office | Fisheries and Oceans Canada (DFO)
Subject Matter of the communication: Environment, Fisheries, Aboriginal Affairs
Communication date: 2023-02-10
Posted date: 2023-03-15
Communication number: 370657-556572 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Andrew Cooper, Regional Advisor | Minister's Office | Fisheries and Oceans Canada (DFO)
Subject Matter of the communication: Fisheries, Mining, Natural Resources
Communication date: 2023-02-09
Posted date: 2023-03-15
Communication number: 370657-560187 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- andrew cooper, Special Assistant | Fisheries and Oceans Canada (DFO)
Subject Matter of the communication: Economic Development, Environment, Mining
Communication date: 2022-11-30
Posted date: 2022-12-07
Communication number: 370657-549176 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Rebecca Parkinson, Senior Advisor, Prairies & North | Intergovernmental Affairs Secretariat (IGA)
- Joshua Lindner, Policy Advisor, BC | Intergovernmental Affairs Secretariat (IGA)
Subject Matter of the communication: Economic Development, Environment, Mining
Communication date: 2022-11-30
Posted date: 2022-12-07
Communication number: 370657-549174 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- John Hannaford, Deputy Minister | Natural Resources Canada (NRCan)
Subject Matter of the communication: Economic Development, Infrastructure, Mining, Aboriginal Affairs
Communication date: 2022-11-29
Posted date: 2023-08-21
Communication number: 370657-575202 (amended from 370657-552189) View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Ben Chin, Senior Advisor | Prime Minister's Office (PMO)
Subject Matter of the communication: Economic Development, Mining, Aboriginal Affairs
Communication date: 2022-11-29
Posted date: 2022-12-15
Communication number: 370657-552191 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Cecile Siewe, Director | Environment and Climate Change Canada (ECCC)
- John Moffet, Assistant Deputy Minister | Environmental Protection Branch | Environment and Climate Change Canada (ECCC)
Subject Matter of the communication: Economic Development, Environment, Infrastructure, Mining, Aboriginal Affairs
Communication date: 2022-11-29
Posted date: 2022-12-15
Communication number: 370657-552185 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Ed Fast, Member of Parliament | House of Commons
Subject Matter of the communication: Economic Development, Infrastructure, Mining, Natural Resources, Aboriginal Affairs, Employment and Training
Communication date: 2022-11-29
Posted date: 2022-12-15
Communication number: 370657-552181 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Cassandra Millar, Special Assistant | Minister's Office | Finance Canada (FIN)
- Tyler Norman, Regional Advisor | Minister's Office | Finance Canada (FIN)
- Leslie Church, Chief of Staff | Minister's Office | Finance Canada (FIN)
Subject Matter of the communication: Economic Development, Infrastructure, Mining, Natural Resources, Aboriginal Affairs
Communication date: 2022-11-28
Posted date: 2022-12-15
Communication number: 370657-552174 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- John Aldag, Member of Parliament | House of Commons
Subject Matter of the communication: Economic Development, Mining, Natural Resources, Employment and Training
Communication date: 2022-11-28
Posted date: 2022-12-15
Communication number: 370657-552171 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Kevin Deagle, Senior Policy Advisor | Minister's Office | Innovation, Science and Economic Development Canada (ISED)
Subject Matter of the communication: Economic Development, Environment, Mining
Communication date: 2022-11-17
Posted date: 2022-12-07
Communication number: 370657-549173 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Joshua Swift, Special Assistant | Office of the Minister | Environment and Climate Change Canada (ECCC)
Subject Matter of the communication: Economic Development, Environment, Mining
Communication date: 2022-11-17
Posted date: 2022-12-07
Communication number: 370657-549172 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Blake Oliver, Senior Policy Advisor | Office of the Deputy Prime Minister and Minister of Finance of Canada | Finance Canada (FIN)
Subject Matter of the communication: Economic Development, Environment, Mining
Communication date: 2022-11-17
Posted date: 2022-12-07
Communication number: 370657-549171 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Margaret Buist, Vice President | Canadian Northern Economic Development Agency (CanNor)
- Richard Vermette, Director General | Canadian Northern Economic Development Agency (CanNor)
- Sierra Van der Meer, Vice President | Canadian Northern Economic Development Agency (CanNor)
Subject Matter of the communication: Economic Development, Aboriginal Affairs, Employment and Training
Communication date: 2022-11-15
Posted date: 2022-12-15
Communication number: 370657-552167 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Connor Moen, Policy and Parliamentary Affairs Advisor | Indigenous Services Canada (ISC)
- Ellen Kuschnik, Director of Parliamentary Affairs | Minister's Office | Indigenous Services Canada (ISC)
- Cody Trystuha, Northern Ontario Advisor | Minister's Office | Indigenous Services Canada (ISC)
Subject Matter of the communication: Economic Development, Mining, Aboriginal Affairs
Communication date: 2022-11-15
Posted date: 2022-12-15
Communication number: 370657-552124 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Jennifer Walsh, Sr Environmental Policy Analyst | Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC)
- Mireille Lajoie, Director | Petroleum and Mineral Resources Managment Directorate | Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC)
- Rebecca Chouinard, Senior Special Advisor | Natural Resources and Environment Branch | Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC)
- Kim Pawley, Manager | Environmental Assessment | Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC)
- Anita Walker, Director | Climate Change and Clean Energy Secretariat | Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC)
Subject Matter of the communication: Economic Development, Aboriginal Affairs, Employment and Training
Communication date: 2022-11-15
Posted date: 2022-12-15
Communication number: 370657-551775 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Tyler Foley, Legislative Assistant | Office of Dr. Marcus Powlowski, MP | House of Commons
- Marcus Powlowski, Member of Parliament | House of Commons
Subject Matter of the communication: Economic Development, Industry, Employment and Training
Communication date: 2022-11-15
Posted date: 2022-12-15
Communication number: 370657-551758 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- François-Philippe Champagne, Minister of Innovation, Sciences and Economic Development | Minister's Office | Innovation, Science and Economic Development Canada (ISED)
Subject Matter of the communication: Economic Development, Mining
Communication date: 2022-11-10
Posted date: 2022-12-15
Communication number: 370657-551825 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Joshua Swift, Special Assistant | Office of the Minister | Environment and Climate Change Canada (ECCC)
- Eamonn McGuinty, Senior Policy Advisor | Office of the Minister of Environment and Climate Change | Environment and Climate Change Canada (ECCC)
- Charlie Angus, MP | House of Commons
- Raphaël Beauchamp, Senior Policy Advisor | Office of the Minister | Natural Resources Canada (NRCan)
Subject Matter of the communication: Economic Development, Energy, Environment, Mining
Communication date: 2022-10-14
Posted date: 2022-11-09
Communication number: 370657-545689 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Joshua Swift, Special Assistant | Environment and Climate Change Canada (ECCC)
Subject Matter of the communication: Environment, Mining, Natural Resources
Communication date: 2022-07-20
Posted date: 2022-08-15
Communication number: 370657-540221 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Tony Maas, Senior Policy Advisor | Prime Minister's Office (PMO)
Subject Matter of the communication: Environment, Mining, Natural Resources
Communication date: 2022-07-06
Posted date: 2022-08-15
Communication number: 370657-540220 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Margaret Buist, VP | Canadian Northern Economic Development Agency (CanNor)
Subject Matter of the communication: Mining, Natural Resources, Aboriginal Affairs
Communication date: 2022-06-17
Posted date: 2022-07-08
Communication number: 370657-536960 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Jeff Labonté, Assistant Deputy Minister | Major Projects Management Office | Natural Resources Canada (NRCan)
Subject Matter of the communication: Mining, Natural Resources
Communication date: 2022-06-17
Posted date: 2022-07-08
Communication number: 370657-536957 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Carol Hughes, Member of Parliament | House of Commons
Subject Matter of the communication: Mining
Communication date: 2022-06-16
Posted date: 2022-07-08
Communication number: 370657-536956 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Joshua Swift, Special Assistant | Environment and Climate Change Canada (ECCC)
Subject Matter of the communication: Climate, Environment, Mining
Communication date: 2022-06-16
Posted date: 2022-07-08
Communication number: 370657-536955 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Julie Dabrusin, Member of Parliament | House of Commons
Subject Matter of the communication: Climate, Mining, Aboriginal Affairs
Communication date: 2022-06-16
Posted date: 2022-07-08
Communication number: 370657-536954 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Patty Hadju, Minister of Indigenous Services Canada | Indigenous Services Canada (ISC)
Subject Matter of the communication: Mining, Aboriginal Affairs
Communication date: 2022-06-13
Posted date: 2022-07-08
Communication number: 370657-536952 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Charlie Angus, MP | House of Commons
Subject Matter of the communication: Mining
Communication date: 2022-06-13
Posted date: 2022-07-08
Communication number: 370657-536951 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Eric Melillo, MP | House of Commons
Subject Matter of the communication: Mining, Aboriginal Affairs, Employment and Training
Communication date: 2022-06-13
Posted date: 2022-07-08
Communication number: 370657-536948 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Brendan Hanley, Member of Parliament | Yukon | House of Commons
Subject Matter of the communication: Economic Development, Mining, Aboriginal Affairs
Communication date: 2022-01-05
Posted date: 2022-02-11
Communication number: 370657-521910 View associated registration

Bernard Wessels, Managing Director North America (Corporation)

Learn more...

Results below are sorted by posted date, beginning with the most recent.

Results 1-43 of 43

Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- George Chahal, Member of Parliament and Chair of the Standing Committee on Natural Resources | House of Commons
Subject Matter of the communication: Mining
Communication date: 2024-03-04
Posted date: 2024-04-15
Communication number: 370657-599103 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Melanie Campbell, Director | Stategic Policy | Natural Resources Canada (NRCan)
- Marc Serré, Parliamentary Secretary | Natural Resources Canada (NRCan)
Subject Matter of the communication: Mining
Communication date: 2024-03-04
Posted date: 2024-04-15
Communication number: 370657-599102 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Ray Kassam, Chief Strategy Officer | Invest in Canada Hub
- Bobby Kelly, Chief of Staff | Invest in Canada Hub
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-15
Communication number: 370657-588076 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Randi Anderson, Director of Policy | Minister's Office | Natural Resources Canada (NRCan)
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-14
Communication number: 370657-588075 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Alexander Muir, Chief of Staff to Deputy Minister | Natural Resources Canada (NRCan)
- Jeffrey Labonté, Associate Deputy Minister | Natural Resources Canada (NRCan)
- Michael Vandergrift, Deputy Minister | Natural Resources Canada (NRCan)
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-15
Communication number: 370657-588074 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Dennis Glen Patterson, Senator | Senate of Canada
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-15
Communication number: 370657-588073 View associated registration
Newmont
In-house Corporation

Designated Public Office Holders who participated in the communication:
- Tina Green, Assistant Secretary | Treasury Board Of Canada Secretariat (TBS)
Subject Matter of the communication: Economic Development, Mining
Communication date: 2023-11-21
Posted date: 2023-12-15
Communication number: 370657-588071 View associated registration

List of Public Offices Held
Position	Period Held	Last Date Designated Public Office Held
Senior Policy Advisor Fisheries & Oceans Canada, Pacific Region	January 2020 to December 2021	Not a designated office

Date Modified:: 2024-04-04

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Registration - In-house Corporation

Newmont / Bernard Wessels, Managing Director North America

Registration Information

Associated Communications

Version 7 of 8 (2023-11-06 to 2023-12-14)

Version 7 of 8 (2023-11-06 to 2023-12-14)

Subject Matters

Subject Matter Details

Grant, Contribution or Other Financial Benefit

Policies or Program

Communication Techniques

Government Institutions

Government institutions added through a monthly communication report

Description of activities

Responsible officer name and position during the period of this registration

Government funding

In-house Corporation Contact Information

Parent Company Information

Subsidiary Beneficiary Information

Senior Officers whose lobbying activities represent less than 20% of their Duties

Senior Officers and Employees whose lobbying activities represent 20% or more of their Duties