Our Political Activity Philosophy
I. Overview of Political Activity Philosophy
McCormick & Company, Incorporated (including subsidiaries globally, “McCormick” or the “Company”) has a legacy of involvement in the communities in which the Company operates and its employees live and work. Community involvement includes supporting public policies that affect the Company’s business, brands, and 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 related to these activities. Any such individual activities must not in any way suggest the Company’s support.
* The Company will not reimburse anyone for a political contribution.
II. Political Activity by the Company
It is the Company’s policy to be a good corporate citizen. Wherever the Company does business, employees and directors are required to comply with all applicable laws, rules, and regulations.
The Company will maintain a Government Affairs Council. Membership on this Committee is determined from time to time by the Company’s President and is annually reviewed by the Nominating/Corporate Governance Committee of the Board of Directors.
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.
* The Company 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, or its stockholders, employees, and other stakeholders (clauses (i) and (ii) are designated as “Political Initiatives” in this Policy).
* All contributions by the Company to Political Initiatives must be authorized, in advance, by the Government Affairs Council and, if authorized, are made without regard for the personal political preferences of the Company’s directors, officers, or executives.
McCormick belongs to industry organizations and trade associations and may work with such organizations and associations as well as communications companies and other parties and coalitions, with the purpose of educating elected officials and government policy makers regarding issues of interest to the Company and its industries.
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 must also comply with such Policy and Procedure.
- McCormick will not provide contributions to candidates or political parties outside the United States.
- All contributions to 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 Council.
III. Considerations; Oversight
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 country, district, or state.
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.
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.
IV. Activities with Specific Types of Organizations
A. Political Action Committees.
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 will not maintain or sponsor any PAC at the federal or state level.
B. 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 to such association 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 federal and state campaign finance and disclosure laws of the United States and other countries, as applicable. The Company will disclose on its corporate website a copy of this Policy, a confirmation that all contributions are made and approved in accordance with this policy, and a rolling five-year archive of contributions in the following areas:
- corporate political contributions and payments to any individual candidate for office, if any;
- contributions and payments to any “Section 527 organizations” such as governors committees and super PACs, if any;
- payments in connection with any state ballot initiative;
- trade associations in the United States to which McCormick has paid annual dues of $25,000 or more, and which had non-deductible lobbying expenditures.