²ÝÝ®ÊÓƵ engages responsibly in the political process in the communities where our employees live and work. Public policy decisions affect our businesses, ²ÝÝ®ÊÓƵ believes that active participation in the political process and public policy debates are in the best interests of the Company and its shareholders. Our goal is to ensure public officials representing our people, products and plants understand the issues that impact our business. We adhere to the local laws and regulations governing interactions with government officials, and participate in the political process through issue advocacy and political contributions. The Company has put in place effective compliance procedures for, and oversight of, lobbying activities, corporate contributions and ²ÝÝ®ÊÓƵ PAC political expenditures. The ²ÝÝ®ÊÓƵ Code of Conduct requires all employees to maintain honest relationships with government officials.
The ²ÝÝ®ÊÓƵ PAC, the company’s political action committee, is funded by voluntary contributions from eligible employees and shareholders. Comprised of senior employees from across the company, the ²ÝÝ®ÊÓƵ PAC Board approves contributions to federal, state and local candidates, political parties and other federal PACs. The private political preferences of our company officers, executives and Board members are not taken into consideration when making political contributions from corporate funds or from the ²ÝÝ®ÊÓƵ Political Action Committee. Where permitted by law, ²ÝÝ®ÊÓƵ also makes corporate contributions to political committees, state candidates and state political parties. Support for candidates and corporate contributions are determined by a number of key considerations, which include but are not limited to the following:
²ÝÝ®ÊÓƵ and the ²ÝÝ®ÊÓƵ PAC do not support Presidential campaigns, judicial candidates, super PACs or make contributions to independent expenditure committees, which is defined as money spent to support a political candidate, but not at the suggestion or request of the candidate, the candidate’s authorized committee or a political party.
The Company has put in place effective compliance procedures for, and oversight of, lobbying activities, corporate contributions and ²ÝÝ®ÊÓƵ PAC political expenditures. The ²ÝÝ®ÊÓƵ Code of Conduct requires all employees to maintain honest relationships with government officials. In addition, all employees must receive approval in advance from the Global Head of Government Affairs before making any political contributions from corporate funds.
At a minimum, The ²ÝÝ®ÊÓƵ Board of Directors receives an annual update on political and lobbying activities and discusses with management their strategies and recommendations.
²ÝÝ®ÊÓƵ files all information as required by federal and state campaign finance and disclosure laws. The ²ÝÝ®ÊÓƵ PAC reports its contributions to the Federal Election Commission (FEC), the details of which are publicly available on the FEC internet site.
In addition, all ²ÝÝ®ÊÓƵ PAC and Company political contributions since 2012 are listed below. This includes contributions to ballot initiatives and 501c4 organizations where funds may be utilized for political purposes. This information is updated semi-annually on our website.
²ÝÝ®ÊÓƵ prepares and submits reports with the Secretary of the U.S Senate and the Clerk of the U.S. House of Representatives quarterly, which detail lobbying activities and expenditures. These reports are available at: . The Company also files lobbying reports with many U.S. state and municipal governments as required by law. These reports are publicly available through the websites of the jurisdictions where they are filed.
²ÝÝ®ÊÓƵ believes that trade association membership and participation provides a number of benefits to our business and employees including the ability to remain engaged on relevant issues, and as a forum for sharing ideas and information.
²ÝÝ®ÊÓƵ instructs trade associations in writing that our dues must only be used for general operating expenses, which includes lobbying on issues of importance to our business. ²ÝÝ®ÊÓƵ dues may not be used to provide support or oppose of political candidates. Find language sent to trade associations here.
Below please find links to all ²ÝÝ®ÊÓƵ PAC and political contributions as well as a list of the trade associations to which ²ÝÝ®ÊÓƵ paid dues of $50,000 or more, along with a breakdown of the amount of those dues that were used for lobbying activities. Please note this list covers the previous four years, and therefore includes membership for the legacy Kraft Foods Group, Kraft Foods Global and H. J. Heinz Company organizations.
Trade Association Dues and Political PAC Contributions: