Political contributions


Political contributions

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, Group Companies may make contributions to political parties and organizations 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 activities, 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

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 assist to improperly secure a decision by the Public Official to the improper advantage of the company or the Group.

When approving political contributions, the boards of Group Companies (or the person(s) authorized by the board of the applicable Group Company to provide such approval) should ensure that they comply with these requirements and document this appropriately.


Strict authorization requirements

All political contributions must be:
  • Lawful
  • authorized in advance by the board of the relevant Group Company (or by person(s) authorized by the board of the relevant Group Company) in compliance with the delegated authorities policies and procedures of the applicable 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 organization 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 organization’. 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
  • minimize 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 minimize 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 a Group Company 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 a Group Company in the US 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.


Political Committees

Where legal, and in compliance with the SoBC, Group Companies 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 any Group Company. Approved Employees who are U.S. citizens or permanent residents may administer, contribute and participate in the activities of a PAC connected to Group Companies.


Who to talk to

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