Our Political Activity Philosophy
McCormick has a legacy of involvement in the communities in which our employees live and work. Community involvement includes supporting public policies that affect our business, our brands, and our employees. It also includes educating policy makers and participating in the public dialogue on policy issues where appropriate.
The company encourages employees to be active participants in the communities in which they live and work. While this Policy does not address individual contributions by employees to political parties, or volunteer activities, employees must comply with all applicable laws in this regard. Of course, those individual efforts must not in any way suggest McCormick’s support.
*THE COMPANY WILL NOT REIMBURSE ANYONE FOR A POLITICAL CONTRIBUTION.
Political Activity by the Company
It is the company’s policy to be a good “corporate citizen.” Wherever we do business, employees and directors of the company are required to comply with all applicable laws, rules and regulations.
United States federal law does not permit corporations to contribute funds directly to candidates for federal office (the President, Vice-President, or candidates for the United States House and Senate). State laws vary and may or may not allow corporate contributions to candidates for state and local office.
MCCORMICK WILL NOT CONTRIBUTE TO CANDIDATES FOR PUBLIC OFFICE OR TO POLITICAL CAMPAIGNS.
Company funds may be used (i) to support state and local ballot measures that are likely to affect the company or the quality of life in the communities in which McCormick employees live and work or where the company otherwise does business; and (ii) to support or advocate issues, legislation or referenda of importance to the company, our stockholders, employees, and other stakeholders (clauses (i) and (ii) are designated as “Political Initiatives” in this Policy).
McCormick belongs to industry organizations and trade associations, and may work with communications companies and other organizations and coalitions, with the purpose of educating elected officials and government policy makers regarding issues of interest to the company and our industry.
*ALL CONTRIBUTIONS BY THE COMPANY TO POLITICAL INITIATIVES MUST BE AUTHORIZED, IN ADVANCE, BY THE GOVERNMENT AFFAIRS COMMITTEE AND, IF AUTHORIZED, ARE MADE WITHOUT REGARD FOR THE PERSONAL POLITICAL PREFERENCES OF THE COMPANY’S DIRECTORS, OFFICERS OR EXECUTIVES.
Membership on this committee is determined by the company’s Management Committee and is annually reviewed by the Nominating/Corporate Governance Committee of the Board of Directors.
Employees are reminded that the company maintains a Corporate Policy and Procedure on the Foreign Corrupt Practices Act & International Anti-Corruption Compliance which is applicable to all United States and international operating units. Any proposed use of company funds in support of any political initiative outside the United States would additionally need to comply with this policy and procedure. Note that:
*MCCORMICK WILL NOT PROVIDE CONTRIBUTIONS TO CANDIDATES OR POLITICAL PARTIES OUTSIDE THE UNITED STATES.
*ALL CONTRIBUTIONS OR SUPPORT OF POLITICAL INITIATIVES OUTSIDE THE UNITED STATES REQUIRES THE ADVANCE APPROVAL OF THE RESPONSIBLE MEMBER OF THE COMPANY’S MANAGEMENT COMMITTEE, IN ADDITION TO THE GOVERNMENT AFFAIRS COMMITTEE.
In making contributions, McCormick considers various criteria, such as positions on public policy issues and/or the presence of McCormick employees and facilities in a particular district or state.
Note that the company has a separate Charitable Donations Committee that reviews all company contributions to Internal Revenue Code section 501(c)(3) organizations (i.e., not-for-profit organizations that are operated exclusively for charitable, educational, scientific, and other permitted purposes). An example of a 501(c)(3) organization is the United Way of Central Maryland.
At least annually, the Nominating/Corporate Governance Committee of the Board of Directors receives a report on the company’s political contributions, and discusses with management their strategies and recommendations. The Nominating/Corporate Governance Committee is also responsible for periodically reviewing this policy.
Types of Organizations
Political Action Committees or PACs are organized for the purpose of raising and spending money in connection with political campaigns in the United States.
*MCCORMICK DOES NOT MAINTAIN OR SPONSOR A PAC AT THE FEDERAL OR STATE LEVEL.
Trade Associations. McCormick believes that trade association membership and participation benefits our business and employees in various ways, such as providing updates on issues relevant to the company. McCormick is a member of a number of food and manufacturing industry trade associations at the federal, state, and local levels. Many of these organizations engage in lobbying activities, operate their own political action committees, and engage in political education programs. McCormick supports trade associations through the payment of annual dues. In some instances, the company may make additional payments in the form of contributions and special assessments to support special projects and coalition activities, including advocacy efforts at the federal and state levels.
McCormick will file all information statements required by United States federal and state campaign finance and disclosure laws.
The link below lists for the previous fiscal year:
(i) aggregate corporate political contributions and payments to any individual candidate for office in excess of $500;
(ii) payments of $25,000 or more in connection with any state ballot initiative;
(iii) trade associations in the United States to which McCormick has paid dues in of $25,000 or more, and which had non-deductible lobbying expenditures in excess of $10,000.
We will maintain a rolling four-year archive of such contributions, beginning with the 2013 fiscal year.