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Public Policy Engagement, Political Activities and Contributions Guidelines


Public Policy Engagement, Political Activities & Contributions Guidelines Why It Matter

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Governance & Oversight

PepsiCo’s Board of Directors recognizes that the use of Company resources in the political process is an important issue for shareholders. PepsiCo’s Board of Directors oversees the Company’s public policy processes and activities with the assistance of its Sustainability, Diversity and Public Policy Committee. This includes the periodic review of policies and practices regarding political contributions, as well as the review of PepsiCo’s political contributions and expenditures of both corporate and political action committee funds.

Public Policy Engagement and Issue Prioritization

PepsiCo’s business is affected by public policy at the local, state, national, regional and global levels. Our Public Policy and Government Affairs team works with senior management to set annual and long-term public policy priorities. We have a strong Global Code of Conduct and abide by local laws and regulations that govern interaction with public officials. Through public policy engagement, our goal is to promote a business environment that supports PepsiCo's ability to achieve sustainable growth in the years ahead.

Since 2015, we have witnessed the convergence of an international policy agenda with the adoption of the United Nations Sustainable Development Goals as well as the Paris Agreement on Climate Change. Governments, civil society and key business leaders have come together in pursuit of ambitious, long-term solutions to the world’s most significant environmental and social challenges. Companies continue to be called upon to develop creative, innovative solutions and products to better serve society’s needs. These historic agreements reflect future policy direction which will affect how we conduct business.

We therefore participate in public policy dialogues and share our expertise on key issues that support our business strategy and where we or others have identified that we can contribute ideas to solve policy issues. We aim to make constructive contributions that will lead to policies that help our business, our consumers and society thrive in a sustainable fashion. In 2020, our key issues included discriminatory taxation, trade, commodities, restrictions in the marketplace, food security, health & nutrition, and environmental regulation.

Lobbying: Guidelines, Reporting and Expenses

PepsiCo monitors and abides by the changing laws and regulations governing lobbying activities, including the rules regarding national and sub-national lobbying registration and reporting obligations. In the U.S., PepsiCo associates who engage in and support lobbying efforts at the U.S. federal and state levels undergo annual ethics training by expert outside counsel. PepsiCo discloses all lobbying activities at the federal, state, and local level, as required by law.

Political Contributions (PAC and corporate funds) – Governance, Criteria, Accountability

Political contributions by PepsiCo’s political action committee – the PepsiCo, Inc. Concerned Citizens Fund (CCF) – provide an important opportunity for PepsiCo and its employees to participate in the democratic process. The CCF receives voluntary employee contributions from eligible individuals to make political campaign contributions to U.S. federal and state candidates, political parties and other political committees. Management, supervisory and other eligible employees who are United States citizens or lawful permanent residents of the United States (i.e. green card holders) may voluntarily contribute to the CCF. Except for administrative expenses, the CCF is completely funded with voluntary contributions from eligible PepsiCo employees. Coercion of any employee to contribute to the CCF or to make any political contribution of any kind is unacceptable.

PepsiCo also makes political contributions with corporate funds in some jurisdictions, such as cities and states in the United States, where permitted by law.

All CCF and corporate contributions are approved by a Corporate Affairs committee led by the Corporate Senior Vice President, Public Policy & Government Affairs. All such political contributions are distributed in a non-partisan manner to U.S. candidates, political parties, other political committees and ballot measure committees. Moreover, all such contributions must be made and reported in accordance with applicable federal, state and local campaign finance laws.

PepsiCo has developed processes designed to further promote corporate accountability:

  • PepsiCo employees must obtain approval from the Corporate Senior Vice President, Public Policy & Government Affairs before making political contributions of corporate funds.
  • All contributions must be reviewed by expert outside counsel to ensure legal compliance.
  • All contributions must further reflect PepsiCo’s business or strategic interest and not those of its individual officers or directors.
  • No contribution will be given to influence, to reward or in exchange for an official act or for any other improper purpose.
  • Employees will not be reimbursed directly or through compensation increases for personal political contributions or expenses.
  • Details on all PepsiCo's political contributions are posted on its website on an annual basis.
CONTRIBUTION FACTORS

PepsiCo seeks to support candidates who have responsible pro-business records and positions. In this way, PepsiCo seeks to improve the business climate, our quality of life and the society in which we live, enabling us to succeed as a company committed to integrity, innovation and value.

The following criteria will be used in connection with all contributions:

  • The candidate's or entity's commitment to improving the business climate.
  • The candidate's commitment to the long-term public policy goals of PepsiCo.
  • The location of PepsiCo facilities or employees within the candidate's district or state.
  • The candidate's position on key committees where legislation of importance to PepsiCo is considered or the candidate's demonstrated leadership - or potential for leadership - within the U.S. Congress or a State Legislature.
  • The candidate’s overall character, integrity, personal conduct, record of public service, and commitment to supporting diversity, equity, and inclusion.

Since 2010, corporations generally have been permitted to engage in independent candidate advocacy directly and through other organizations. As a company that does business with the federal government, PepsiCo is not permitted to sponsor or contribute to such independent expenditures with regard to federal elections. When PepsiCo contributes to independent expenditure committees in state and local elections, those contributions are reported as required by law and disclosed annually by PepsiCo along with other corporate and CCF contributions and expenditures.

PepsiCo generally does not make contributions to candidates outside of the United States. Any exception to this policy would require a written recommendation by PepsiCo’s regional government affairs representative and approval by:

  • The Corporate Senior Vice President, Public Policy & Government Affairs, and
  • The corporate and regional law departments to ensure strict legal compliance.

Any such contribution would be posted on the PepsiCo website with other political contributions.

Finally, PepsiCo employees have the right to be engaged in the political process in their individual private capacity as they see fit, and make political contributions of their own time and money to the candidates or parties of their choice. Such private activities must not in any way suggest PepsiCo's involvement or support. In addition, an employee’s personal political affiliation or political activities shall not be the basis of adverse employment action so long as those affiliations and activities are both lawful and fully compliant with PepsiCo’s Code of Conduct.

PepsiCo’s Political Contributions Policy can be found here.

Trade Associations

PepsiCo is a member of numerous industry and trade groups and partners with various nonprofit organizations and non-governmental organizations, including:

  • American Beverage Association
  • Business for Social Responsibility (BSR)
  • Ceres
  • Consumer Brands Association
  • Consumer Goods Forum
  • FoodDrinkEurope
  • Food Industry Asia
  • International Council of Beverage Associations
  • International Food & Beverage Alliance
  • Mexican Council of Consumer Goods Products (ConMexico)
  • SNAC International
  • UN Global Compact
  • U.S. Council for International Business
  • World Business Council for Sustainable Development
  • World Economic Forum

PepsiCo works with these groups because they represent the food and beverage industry and the business community on issues that are critical to PepsiCo’s business and its stakeholders. Importantly, such organizations help develop consensus among varied interests.

PepsiCo does not always share or agree with all of the views of each of our peers or associations. PepsiCo representatives on the boards and committees of such groups ensure that PepsiCo’s position about policy or related activities is voiced. As such, there may be times when PepsiCo chooses not to fund certain initiatives sponsored by such organizations.

PepsiCo annually reviews the benefits and challenges from membership in our major trade associations. In addition, our trade associations are required to obtain specific consent from PepsiCo to use PepsiCo’s dues or similar payments for the funding of exceptional political expenditures beyond regular dues and business matters. PepsiCo specifically directs in writing each of its primary trade associations to use PepsiCo dues for general operating expenses and other routine activities, which includes lobbying executive and legislative bodies, and not to apply PepsiCo dues to any political event or election related activity without a specific approval from PepsiCo.

PepsiCo currently does not belong to any organizations which have as a primary focus the creation and promotion of model legislation.

Lobbying Practices Related to the Issue of Climate Change

Climate change is one of the most important issues of our time and requires immediate, coordinated action. Building on our track record of action on climate change, PepsiCo has a goal to reduce absolute greenhouse gas emissions across our value chain by more than 40 percent by 2030 and to achieve net-zero emissions by 2040, one decade earlier than called for in the Paris Agreement. This goal has been independently recognized by leading NGOs as a science-based target.

Industry action must be supported by climate policy that creates clear price signals and incentives to accelerate clean technology and needed innovation. PepsiCo does not question the science behind climate change, and we have a record of supporting climate policy through membership in the US Climate Action Partnership, signing the American Business Act on Climate Pledge, supporting the Paris Climate Agreement, and becoming a founding member of the US Climate Leadership Council, among other actions.

We believe that our goals and advocacy are consistent with the Paris Climate Agreement, and we ask our trade associations to adopt a similar stance as and when they engage on the issue. PepsiCo regularly reviews the climate change positions taken by our trade associations, and we have publicly reported information on trade association positions as part of our annual CDP Climate Change Report.

PepsiCo is a member of many trade associations and other business and civil society associations, and we do not always agree with all of the positions these associations may take on specific policy matters. PepsiCo is a member of the U.S. Chamber of Commerce, but we do not serve on the organization’s Board and we do not share its views on climate policy.

Disclosure


Lobbying

The Lobbying Disclosure Act requires PepsiCo to file quarterly activity reports. The company’s reports can be found here. In 2020, PepsiCo spent approximately $3,690,000 on federal lobbying-related activities in the United States. PepsiCo and each of its individual federal lobbyist employees are also required to file semiannual contribution reports, which reflect a wide range of other payments relating to federal officials. These reports are available at this link.

In addition, under the Lobbying Disclosure Act, many PepsiCo consultants that support the company’s lobbying efforts must file reports regarding their activities on behalf of the company.  

A list of PepsiCo 2020 Registered Lobbyists can be found here.

Contributions

PepsiCo’s political contributions in the United States between 2019-2020 are reported below:

Trade Associations

We disclose our contributions to U.S. trade associations and policy groups of which PepsiCo is a member and which lobby in the U.S. at the state and federal level. The document may be downloaded here.

Ethics and Integrity

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