Title of each class of securities to which transaction applies:

Aggregate number of securities to which transaction applies:

Per unit price or other underlying value of transaction computed pursuant to Exchange Act Rule 0-11 (set forth the amount on which the filing fee is calculated and state how it was determined):

Proposed maximum aggregate value of transaction:

Amount Previously Paid:

Form, Schedule or Registration Statement No.:

Filing Party:

Date Filed:

As a result of our shareholder outreach and engagement process, shareholders have expressed to us the importance of ensuring that there is formalized Board oversight of the Company’s engagement in lobbying activities and political contributions. As discussed in our proxy statement, prior to finalizing and publishing our annual Political Activity and Lobbying Report, our Board reviews the annual report. Additionally, our Board currently receives a quarterly presentation by our Senior Vice President of Client Relations and other members of management regarding the Company’s lobbying activities and political contributions in order to ensure proper oversight of the Company’s lobbying activities, political contributions and our Political Contributions Policy. In addition to receiving these presentations, the Board discusses at these quarterly meetings the scope of lobbying activities and political contributions and the assessment of the potential risks and rewards of participating in lobbying activities and political contributions.

In response to the shareholder feedback we have received and in order to further maintain and foster the highest level of ethics and compliance with respect to our lobbying activities and political contributions, we will be enhancing our Political Contributions Policy, giving specific responsibility to the Board’s Nominating and Corporate Governance Committee, composed entirely of independent directors, to review annually the Political Contributions Policy and to review annually the Company’s lobbying activities and political contributions, including: payments by GEO for direct or indirect lobbying or for grassroots lobbying communications (we note that GEO does not currently engage in grassroots lobbying), GEO’s membership in and payments to any tax-exempt organization that writes and endorses model legislation, and political contributions by GEO and the non-partisan political action committee that GEO sponsors (the “GEO PAC”). Additionally, we will furnish a copy of our Political Contributions Policy, as may be updated from time to time, on our website.

Prior to receiving the shareholder proposal, we had already published our Political Activity and Lobbying Report for 2018 and we are committed to continuing to publish an annual Political Activity and Lobbying Report. Our annual report explains the approval process for lobbying expenditures and political contributions. Our annual report discloses the total annual dollar amount paid to consultant government relations professionals for direct lobbying and discloses any trade and membership associations to which we pay dues, fees or contributions of more than $25,000 annually. Our annual report also discloses the total annual dollar amounts paid in political contributions divided by source of funds (i.e., GEO Corporate and GEO PAC) and by recipient category (i.e., federal candidates, parties and committees; and state/local candidates, parties and committees).

Additional or more frequent disclosure of our government relations activities would reveal to competitors and opponents valuable information regarding the Company’s operations, development and business strategy. This could prevent or greatly hinder the Company’s development, operating goals and strategy and, consequently, be detrimental to shareholders.

We welcome the opportunity to have meaningful engagement with all of our stakeholders and shareholders regarding our existing Political Contributions Policy and our Political Activity and Lobbying Report.