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Political contributions

 
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Political contributions must only be made in strict accordance with the law and this policy (or local equivalent)

Contributing for the right reasons

Where legal, RAI companies may make contributions to political parties and organisations, to the campaigns for candidates for elective office (corporate contributions to candidates for federal office in the United States are strictly prohibited), to other entities that may legally participate in political-related activity, or to support political issues, provided that such payments are not:
  • made to achieve any improper business or other improper advantage, or to improperly influence any decision by a Public Official to the improper advantage of any Group company
  • intended personally to benefit the recipient or his or her family, friends, associates or acquaintances

(See Conflicts of Interest Policy for definition of “Public Officials”)

It is not permissible for a Group company to make a political contribution if the contribution itself is intended to improperly influence a Public Official to act or vote in a particular way or otherwise assisting to improperly secure a decision by the Public Official to the improper advantage of the company or the Group.

When approving political contributions, the board of the applicable RAI company (or the person(s) authorized by the board of the applicable RAI company to provide such approval) should consider whether they comply with these requirements.

Strict authorisation requirements

All political contributions must be:
  • lawful
  • authorised in advance by the board of the relevant RAI company (or by person(s) authorized by the board of the relevant RAI company) in compliance with the approval policies and procedures of RAI and its subsidiaries
  • fully recorded in the company‘s books
  • if required, placed on public record

Strict procedures must be followed when there is a proposal to make a contribution to any organisation within the European Union or the United States engaged in political activity (especially if originating from a Group company located outside the jurisdiction). This is due to laws having extraterritorial effect and a very broad definition of ‘political organisation’. The foreign contribution ban in the US is particularly strict and must be adhered to carefully.

Group companies within the EU must seek prior written approval from the Group Director of Legal & External Affairs which, if given, may be subject to specific conditions.

Political committees

Where legal, and in compliance with the SoBC, RAI and its subsidiaries may support political issue committees connected with the Group and conduct activities as permitted by the laws and regulations (including reporting requirements) governing such political committees.  

In the US, federal law and certain state laws permit corporate funds to be used in the formation and administration of Political Action Committees, or PACs, which can receive voluntary political contributions from eligible employees and their families.  All such voluntary contributions received must be accounted for in separate, segregated funds, strictly apart from those of RAI and its subsidiaries.  Employees may administer, contribute and participate in the activities of a PAC connected to RAI and its subsidiaries.

Personal political activity

As individuals, we have a right to participate in the political process. As employees, if we undertake any personal political activities we must:
  • do so in our own time, using our own resources
  • minimise the possibility of our own views and actions being misconstrued as those of any Group company
  • take care that our activities do not conflict with our duties and responsibilities to the Group

If we plan to seek or accept public office, we should notify our line manager in advance, discuss with them whether our official duties may affect our work, and co-operate to minimise any such impact.

Personal political contributions to candidates or other political organizations in the US may only be made by US citizens or permanent residents (green card holders) in accordance with law and using their own funds.  It is not permissible to seek reimbursement from RAI and its subsidiaries for any personal political contributions.  Foreign nationals are prohibited from directing, dictating, controlling or directly or indirectly participating in the decision-making process of any US election-related activities on behalf of RAI and its subsidiaries or any related political committee.  Such activities include the making or directing of contributions, donations, expenditures or disbursements in connection with any federal or non-federal elections in the US or decisions concerning the administration or management of any political committee.

Who to talk to

Your line manager
Higher management
Your local LEX Counsel
Head of Compliance:
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