Board Oversight of Corporate Citizenship
Our Board of Directors’ Governance, Membership & Sustainability Committee (“Governance Committee”) oversees our policies and programs related to corporate citizenship and public policy issues significant to our business. At least annually, we report to the Committee on our government relations strategies, lobbying activities and political contributions.
INTERACTIONS WITH GOVERNMENTS AND POLITICAL CONTRIBUTIONS
Mondelēz International has a proud history of involvement in the communities where our employees live and work, and where we do business. This includes educating policy-makers and participating in the public discussion of policy issues that affect our business, including our ability to attract and retain a talented workforce.
Like many companies, Mondelēz International regularly works with government officials on matters of concern to our business. It is both necessary and appropriate for us to do so. We do so in a responsible manner with a priority on compliance with local law and consistency with cultural norms. For example, we may convey our opinions on possible changes to laws or regulations, as well as on the implementation of those laws or regulations, where such matters affect our business and our voice can make a difference. Depending on the country, we may support candidates who understand and appreciate the public policies that affect our business. In accordance with applicable laws and regulations, our political contributions and expenditures may be made to political candidates and organizations who support policies that are conducive to our business.
Mondelēz International’s areas of focus in U.S. advocacy can be found here.
APPROVAL PROCEDURES, OVERSIGHT, AND REPORTING
Our Code of Conduct requires our employees to deal honestly with governments. We have effective compliance procedures for, and oversight of, our advocacy and lobbying activities, including political contributions. Internal compliance policies require advance business and legal approval of all lobbying activities and political contributions. Contributions are processed via a multi-level approval process with final approval by the Director of Corporate and Government Affairs.
In addition, the Governance Committee oversees our policies and programs related to corporate citizenship and public policy issues significant to our business. At least once per year, we report to the Committee on our government relations strategies, lobbying activities, and political contributions. And at least annually, we give a similar report to the full Board of Directors.
Where and when required by law, we report our political activities and disclose related expenditures. In particular, we file all information required by U.S. federal, state, and municipal campaign finance and disclosure laws. We also prepare and submit lobbying reports with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives detailing our U.S. federal lobbying activities and expenditures; these reports are available at: https://disclosurespreview.house.gov/ and https://lda.senate.gov/system/public/. U.S. state and municipal government reports are generally available to the public through the internet sites of the jurisdictions where filed. In addition, we list on our website all corporate political contributions that the Company made in support of candidates within six months after the end of each calendar year. Annual political contributions can be downloaded below. The Company generally does not provide contributions from corporate funds to candidates outside the U.S.; any such contributions would require approval from the Company’s Government Affairs and Legal departments.
MONDELĒZ INTERNATIONAL POLITICAL ACTION COMMITTEE
Mondelēz International’s political contributions are focused on candidates who know our business and understand the public policies that affect it, and who support policies important to our company and our industry.
The Company has an affiliated political action committee in the U.S., Mondelēz International Political Action Committee (“PAC”). Senior managers from various business units and functions comprise the PAC’s Board of Directors. The Company pays the PAC’s expenses, and voluntary contributions from eligible employees fund the PAC’s political contributions. The PAC may contribute to U.S. federal political parties, committees, and candidates. The PAC’s Board considers these criteria (among others) in determining which candidates to support:
- Positions on public policy issues important to Mondelēz International
- The presence of Mondelēz International employees or facilities in a candidate’s district or state
- Key committee membership or leadership position
The PAC reports its contributions to the U.S. Federal Election Commission. Details about those contributions are publicly available at www.fec.gov. Within six months after the end of each calendar year, we list all PAC contributions and corporate political spending. Contributions can be downloaded here.
CORPORATE POLITICAL CONTRIBUTIONS
Where permitted by law in the U.S., we may contribute corporate funds to political committees, state candidates, and state political parties. However, as a practice, we do not make “independent expenditures” (money spent to support a political candidate, but not in coordination with the candidate, the candidate’s authorized committee, or a political party). Mondelēz International generally does not make political contributions to tax-exempt organizations such as 501(c)(4)s for election-related purposes. Any contributions Mondelēz International makes to 527 organizations are reported here. The Company generally does not provide contributions from corporate funds to candidates outside the U.S. Any such contributions would require approval from the Company’s Corporate and Government Affairs and Legal departments. Annual contribution disclosure by candidate and state can be downloaded here.
U.S. TRADE ASSOCIATION MEMBERSHIP
The Company discloses annual dues paid of $50,000 or more to U.S. trade associations of which the Company is a member and that lobby in the U.S. Mondelēz International believes that trade association membership and participation can benefit our business (and thus, our shareholders) and employees in various ways, such as providing updates on issues relevant to the business and forums for sharing ideas and information. Mondelēz International has memberships in many trade associations, and we do not always agree with all of their policy positions. We instruct trade associations that they cannot use our dues to support or oppose candidates and regularly monitor whether association positions are consistent with the Company’s interests. A list of trade association dues paid over $50,000 annually, including the non-deductible portion of dues, can be downloaded here.