Approach

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. 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 expenditures of both corporate and political action committee funds.

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 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. 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 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 2022, our key issues included discriminatory taxation, trade, commodities, restrictions in the marketplace, food security, health and nutrition and environmental sustainability.

As companies continue to be called upon to develop creative, innovative solutions and products to better serve society’s needs, PepsiCo is committed to engaging with stakeholders on public health 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 the science behind food and health more accessible and easier to understand among the public. Our scientific engagement is focused on sharing our expertise on key issues such as food safety, food allergies, health benefits assessment of food products, microplastics, packaging materials, sensory science and consumer behavior. PepsiCo adheres to robust principles on transparency in sponsoring any scientific research, including making available links to PepsiCo-funded research on our website and disclosing any role of PepsiCo in research when promoting findings of sponsored research. For more 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 Lobbying Disclosure Act requires PepsiCo to file quarterly activity reports. In 2022, PepsiCo spent $4,090,000 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 payments relating to federal officials.

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’s 2022 registered lobbyists can be found here.

Political contributions (PAC 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. Management, supervisory and other eligible employees who are U.S. citizens or lawful permanent residents of the U.S. (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 U.S., where permitted by law.

All CCF and corporate contributions are approved by an executive Corporate Affairs committee led by the Corporate Senior Vice President, Public Policy and 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 and 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 (including CCF and corporate 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.

Contribution disclosures

PepsiCo’s political contributions in the United States between 2020-2022 are reported below:

• PepsiCo 2022 Concerned Citizens Fund Contributions
• PepsiCo 2022 Corporate Political Contributions
• PepsiCo 2021 Concerned Citizens Fund Contributions
• PepsiCo 2021 Corporate Political Contributions
• PepsiCo 2020 Concerned Citizens Fund Contributions
• PepsiCo 2020 Corporate Political Contributions

Charitable contributions

PepsiCo does not make charitable contributions for purposes of political influence, and all charitable contributions made by the PepsiCo Foundation are publicly disclosed in its tax returns.

Most of our international cash charitable contributions in 2022 were made through the PepsiCo Foundation, the company’s philanthropic arm. The PepsiCo Foundation primarily works with U.S. non-profit organizations such as Charities Aid Foundation America to contribute to various international partners for disaster relief and work in the areas of access to food security, 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, and does not make charitable contributions for purposes of political influence.

More information regarding the PepsiCo Foundation’s work and disbursements, including its extensive work to bring food and other vital resources to the communities most affected by COVID-19, can be found on our Foundation’s website.

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
• World Resources Institute

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. For example, while PepsiCo is a member of the U.S. Chamber of Commerce, we do not serve on the organization’s Board and we do not share its views on climate policy.

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.

We disclose our contributions to trade associations and policy groups of which PepsiCo is a member. Starting in 2022, the document reflects our global memberships and may be downloaded here.

Lobbying practices related to 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 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.

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 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 Submission.