U.S. Political Engagement Policy
04/07/2022
The Coca‑Cola Company (“the Company”, “TCCC”) engages on public policy issues as actions at every level of government can affect how we innovate, source, produce, package, distribute, market, and continuously meet consumer expectations. In the United States, political engagement elevates our voice about the policies that could affect our employees, customers, and consumers, and the Company’s ability to deliver on strategic business priorities.
Application
This policy applies to all U.S. employees of TCCC and Company-owned bottling operations.
Purpose
TCCC’s participation in the political process is conducted in accordance with the principles of the Code of Business Conduct and in strict compliance with applicable laws and regulations. Acting with integrity, transparency, and nonpartisanship is embedded in TCCC’s political engagement. Our political participation, contributions and disclosures are routinely reviewed against leading industry standards.
Corporate Political Contributions
Federal Contributions: Consistent with U.S. federal law, TCCC does not use corporate funds to contribute to federal candidates, political parties, or political committees, or otherwise employ its resources, including in-kind, even when permitted by law. TCCC also does not take a position for partisan political purposes, that is, specifically for the purpose of advancing the interest of a federal political party or federal candidate to public office.
State and Local Contributions: As of January 1, 2021, TCCC has not used corporate funds to directly support state or local political candidates, even if permitted by law, and within limitations of so-called “pay-to-play” rules in jurisdictions where the Company holds and/or may apply for a government contract.
Contributions to Political & Social Welfare Organizations: TCCC contributes corporate funds to political and social welfare organizations, on a limited basis, in alignment with our business priorities and company values. This includes for the purpose of supporting or opposing state and local ballot initiatives with material impact on TCCC. Each year, the Company discloses contributions to IRC § 527 political organizations on the Company website. For contributions to IRC § 501(c)(4) social welfare organizations, the Company discloses the portion attributable to lobbying expenses on the Company website.
Lobbying, Trade Associations & Membership Groups
Public Policy & Federal Government Relations (“PPGR”) sets TCCC’s public policy agenda, which aligns the Company’s engagement and advocacy efforts to business priorities. Advocacy ranges from direct lobbying by Company staff and consultants to indirect lobbying through trade associations and business groups. Through each of these paths, TCCC focuses discussions with policymakers on key business priorities including environmental sustainability, consumer preference, tax and trade, and workforce diversity and inclusion.
Lobbying: In the U.S., communications with federal, state and local government officials or employees may be reported as lobbying activity. Information about the Company’s lobbying activities filed under the U.S. Lobbying Disclosure Act, 2 U.S.C. § 1601 et seq. are publicly disclosed on the Company website.
Trade Associations & Membership Groups: TCCC is a member or supporter of trade associations, chambers and other IRC § 501(c)(6) organizations that represent a broad spectrum of views on industry and policy issues. TCCC may not agree with every position of each organization, its leadership, or its supporters, but the Company believes that participation among diverse perspectives helps contribute to balanced policy outcomes. Each year, the Company discloses its 501(c)(6) memberships with annual dues at $25,000 or more, along with the portion attributable to lobbying expenses on the Company website.
Employee-Funded Political Action Committee
The Coca‑Cola Company Nonpartisan Committee for Good Government (“Coca‑Cola PAC”) is a federal political action committee registered with the Federal Election Commission fully funded by eligible employee voluntary contributions. The Coca‑Cola PAC enables eligible Company employees to voluntarily pool their financial resources to support federal political candidates and organizations. Neither an employee contribution nor refusal to contribute are ever a condition of employment. PAC expenditures are disclosed publicly on the Company and relevant government websites, including the Federal Election Commission.
Contributions Criteria: PPGR and the Coca‑Cola PAC Board of Directors evaluate a candidate’s eligibility for receiving a political contribution based on alignment with the following criteria and Company values, including: 1. champions issues related to Coca‑Cola business interests; 2. represents districts or states with significant system presence; 3. holds a leadership position or committees key to Coca‑Cola’s business priorities; 4. supports workforce equality and inclusion; and 5. demonstrates a strong record for environmental sustainability.
Neither TCCC nor the Coca‑Cola PAC contributes funds for independent expenditures, including toward electioneering communications or Super PACs.
Personal Political Activity
The personal political views of TCCC directors, leaders and employees have no influence on the political activities of the Company or the Coca‑Cola PAC. Company initiatives that encourage civic participation must fully respect the prerogative of employees to determine if and how to use their personal time and without regard to political preferences. Employees may not be reimbursed, directly or indirectly, by the Company for PAC or any other personal political contributions and expenses.
Review & Approval
The Vice President, Public Policy, Federal Government Relations & Political Engagement oversees U.S. political engagement, political contributions, and lobbying, in consultation with the Senior Vice President & Chief of Public Affairs, Communications and Sustainability, and Legal, to ensure activities are conducted in strict compliance with Code of Business Conduct, applicable laws and regulations, and voluntary initiatives. The ESG and Public Policy Committee of the Board of Directors reviews at least annually TCCC’s public policy agenda, political contributions and lobbying activities.
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