Public policy engagement, political activities and contributions guidelines

Last updated

March 27, 2026

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Why it matters

To PepsiCo:

PepsiCo's business is impacted by public policy at the local, state, national, regional and global levels. We participate in public policy dialogue and share our expertise, insights and ideas to contribute to relevant policy issues with the objective of promoting a business environment that supports PepsiCo's ability to achieve sustainable growth in the years ahead.

To the World:

The success of the societies in which we operate depends on various actors being responsibly engaged in the political process. PepsiCo's policy engagement and political activities — including political giving and issue advocacy — must always comply with all applicable laws, our Global Code of Conduct and our policies and must conform to the approaches described in these materials.

Approach

Our public policy engagement is guided by PepsiCo’s governance structures outlining our approach to public policy engagement, designed to ensure transparent, responsible oversight of engagement and activities that advance the company’s long‑term business interests.

Governance & oversight

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

Political contributions (candidates): governance, criteria and accountability

PepsiCo’s Political Contributions Policy outlines our criteria for contributing to candidates. PepsiCo seeks to support candidates who have responsible pro-business records and positions. In this way, we aim to improve the business climate and enable our success as a company committed to integrity, innovation and value.

Contribution factors

The following criteria are used to evaluate all potential contributions:

  • The candidate's or entity's commitment to improving the business climate.
  • The candidate's commitment to the long-term public policy objectives 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 important to PepsiCo is considered, or the candidate's demonstrated or potential leadership within the U.S. Congress or a State Legislature.
  • The candidate’s overall character, integrity, personal conduct and record of public service.

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 political contributions and expenditures as described below.

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 Government Affairs Senior Vice President; 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 to make political contributions of their own time and money to the candidates or parties of their choosing. Such private activities do 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 as long as those affiliations and activities are both lawful and fully compliant with PepsiCo’s Code of Conduct.

Political contributions (political action committees (PACs) and corporate funds): governance, criteria and 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. Certain management, supervisory and other eligible employees who are U.S. citizens or lawful permanent residents of the U.S. may voluntarily contribute to CCF. Except for administrative expenses, CCF is completely funded with voluntary contributions from eligible PepsiCo employees. The CCF may solicit contributions from eligible employees; however, coercion of any employee to contribute to the CCF or to make any political contribution of any kind is prohibited by law.

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

All CCF and corporate political contributions are approved by a Corporate Affairs committee chaired by a Government Affairs & Corporate Citizenship Vice President and are included in PepsiCo’s annual disclosures.

Recipients of Political Contributions from PepsiCo

PepsiCo and our employee PAC, the CCF, make political and other contributions where permitted by law to:

  • Candidates (federal, state and local)
  • National, state, and local political parties, and other political groups
  • Political Action Committees (PACs) (e.g., trade association and leadership PACs)
  • Ballot measures or campaigns
  • Tax-exempt organizations (e.g., 501(c)(4) and 527)

All of PepsiCo’s political contributions described in the above bullets are disclosed on this webpage. Additionally, all of PepsiCo’s political contributions are distributed in a non-partisan manner consistent with the contribution factors discussed above. Moreover, all such contributions must be made and reported in accordance with applicable federal, state and local campaign finance laws.

Political Contributions Corporate Accountability

PepsiCo has developed processes designed to ensure corporate accountability in all political contributions, both corporate and those from the CCF:

  • PepsiCo employees must obtain approval from a Corporate Affairs committee chaired by a Government Affairs & Corporate Citizenship Vice President before making political contributions of corporate or CCF funds.
  • All contributions must be reviewed by expert outside counsel to ensure legal compliance.
  • All contributions must promote 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 indirectly (e.g., through compensation increases for personal political contributions or expenses).
  • Details on all PepsiCo's political contributions (including CCF and corporate political contributions) are posted here on an annual basis.
  • Both corporate and CCF political contributions (and related policies) are overseen and reviewed by PepsiCo’s Board of Directors through the Sustainability and Public Policy Committee.

Contribution disclosures

We disclose political contributions made both directly and through our PAC annually. PepsiCo’s five most recent political contribution disclosures are located below:

Risk management

PepsiCo’s public policy engagement can help support policies that promote a stable operating environment and advance long‑term resilience. This work strengthens our ability to anticipate regulatory shifts, support productive supply chains and protect the continuity of our operations.

Lobbying practices related to climate change

Climate change is one of the most important issues of our time and requires immediate, coordinated action by a range of actors.

Industry action must be supported by government 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 U.S. Climate Action Partnership, signing the American Business Act on Climate Pledge, supporting the Paris Climate Agreement and becoming a founding member of the U.S. Climate Leadership Council, among other actions. PepsiCo also regularly reviews the climate change positions taken by our trade associations.

Strategy

Public policy engagement and issue prioritization

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 aim is to promote a business environment that supports PepsiCo's ability to achieve sustainable growth in the years ahead. In 2025, our key issues included agriculture, selective taxation, ingredients, trade, commodities, food security, recycling, environmental sustainability and artificial intelligence.

The adoption of the United Nations Sustainable Development Goals, the Paris Agreement on Climate Change and the Global Biodiversity Framework, have guided the development and implementation of programs, laws and policies focused on sustainability that affect how we conduct business. We participate in public policy dialogue, share our expertise on key issues that support our business strategy and, where we can, contribute ideas that help our business, our consumers and society thrive in a sustainable fashion.

As companies continue to be called upon to develop creative, innovative solutions and products to better serve society’s needs, PepsiCo participates in discussions with various stakeholders on food policy and sustainability topics. For example, PepsiCo is a member of organizations such as the European Food Information Council, a non-profit organization focused on making food and health science more accessible and easier to understand among the public. Our participation in scientific discussions includes topics such as food safety, food allergies, product assessment, packaging materials and nutritional quality. PepsiCo implements transparency practices when sponsoring scientific research, such as linking to PepsiCo-funded research on our website and disclosing PepsiCo’s role when promoting findings of sponsored research. For additional information on our research practices, please see Responsible research.

Lobbying: guidelines, reporting and expenses

PepsiCo monitors and abides by the changing laws and regulations governing lobbying activities, including rules regarding regional, national and sub-national lobbying registration and reporting obligations. In Europe, PepsiCo is registered in the E.U. Transparency Registry, where the company discloses fields of interest, contributions to policy discussions and costs associated with lobbying activities in the E.U.

In the U.S., PepsiCo associates who engage in and support lobbying efforts at the 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.

The federal Lobbying Disclosure Act requires PepsiCo to file quarterly activity reports. In 2025, PepsiCo spent approximately $4 million on federal lobbying-related activities in the U.S. PepsiCo and each of its individual federal lobbyist employees are also required to file semi-annual contribution reports, which reflect a wide range of other contributions relating to federal officials.

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

A list of PepsiCo’s 2025 U.S. external registered lobbyists can be found here.

Strategic collaborations

PepsiCo collaborates with external groups, including industry and trade associations, non-profit organizations and non-governmental organizations to help us achieve our public policy ambitions. We work 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.

Memberships and trade associations

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

  • American Beverage Association
  • Business for Social Responsibility (BSR)
  • 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 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, PepsiCo's trade associations are required to obtain specific consent from the company to use its dues or similar payments for the funding of exceptional political expenditures. 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.

We disclose our contributions to trade associations and policy groups of which PepsiCo is a member in our annual Trade Associations and Policy Groups disclosure.

Charitable contributions

The majority of our international monetary charitable contributions in 2025 were made through the PepsiCo Foundation, the company’s philanthropic arm. The PepsiCo Foundation primarily works with U.S. non-profit organizations to contribute to various international organizations for disaster relief and work in the areas of food and nutrition security, access to safe water and economic opportunity. As a 501(c)(3) private foundation, the PepsiCo Foundation is prohibited from engaging in most lobbying and political activities, including directly or indirectly participating or intervening in political campaigns on behalf of or in opposition to any political candidate. Neither PepsiCo nor the PepsiCo Foundation makes charitable contributions for purposes of political influence.

All of the PepsiCo Foundation’s contributions are publicly disclosed on its U.S. tax returns in compliance with federal disclosure requirements. In addition, information regarding PepsiCo Foundation’s contributions for the most recent fiscal year, including those made to foreign organizations, can be found on the Foundation’s website.  

What's next?

We expect to continue participating in public policy dialogue and sharing our expertise, insights and ideas with an aim to promote a business environment that supports PepsiCo's ability to achieve sustainable growth in the years ahead.

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