Where political contributions are expressly permitted by local law and generally accepted as part of local business practice, they must only be made in strict accordance with the law and this policy (or local equivalent).
Contributing for the right reasons
Where expressly permitted by local law, Group companies may make contributions to political parties and organisations and to the campaigns for candidates for elective office (corporate contributions to candidates for federal office in the United States are strictly prohibited), provided that such payments are not:
- made to achieve any improper business or other advantage, or to improperly influence any decision by a Public Official to the advantage of any Group company
- intended personally to benefit the recipient or his or her family, friends, associates or acquaintances
It is not permissible for a Group company to make a political contribution if the contribution itself is intended to influence a Public Official to act or vote in a particular way or otherwise assisting to secure a decision by the Public Official to the advantage of the company or the Group.
When approving political contributions, the boards of Group companies should ensure that they comply with these requirements and document this appropriately.
Strict authorisation requirements
All political contributions must be:
- expressly permitted by local law, as confirmed by external legal advice
- notified in advance to the relevant Regional Head of LEX or equivalent (subject to any applicable law governing the nationality of persons permitted to be involved in such activity)
- authorised in advance by the board of the relevant Group company
- 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 UK 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.
Before any political contribution is made within the UK, the Group Head of Business Conduct and Compliance must be notified.
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 cooperate to minimise any such impact.
All political contributions must be expressly permitted by local law, as confirmed by external legal advice
Who to talk to
- Your line manager
- Higher management
- Your local LEX Counsel
- Head of Compliance: firstname.lastname@example.org