Campbell Soup Company seeks to participate actively in discussion of and debate on public policy issues that affect the Company, its employees, and its business operations. The Company also seeks to share its views on the implications of proposals relating to such issues with relevant policy makers at all levels of government. Campbell executives and employees are encouraged to work with the Company's Government Affairs Department in the development of Campbell's positions on public policy matters. The positions that are adopted by the Company, and the reasons for its involvement in these issues should be shared with Campbell's employees. Campbell policies encourage its employees to be engaged in the political process, on a voluntary basis, whether through such avenues as Campbellâ€™s political action committee (Campbell PAC) or of their own volition.
No funds or assets of Campbell Soup Company may be used for political contributions outside of the United States. Within the United States, the Company makes a limited number of political contributions as part of its engagement in public policy matters. The Company does not support Federal political candidates or parties other than through political contributions made by the Campbell Soup Company Political Action Committee ("Campbell PAC"). All political contributions made by the Company must be authorized by the Vice President - Government Affairs, as part of the political programs approved by the Chief Executive Officer or the Senior Vice President and General Counsel.
Where permitted by state law, Company funds may be used to participate in campaigns for the election of state officials and for state and local ballot measures that are likely to affect the Company or the quality of life in communities in which Campbell has business facilities or otherwise does business. In rare instances, the Company will consider contributions to state political organizations, state and local political action committees, and local candidates, subject to the approval of the Senior Vice President and General Counsel. Contributions to state political organizations and candidates are publicly disclosed as prescribed by state law.
On a limited basis, and with the approval of the Senior Vice President and General Counsel, the Company may also make contributions to policy-based, nonpartisan organizations, state nonpartisan organizations, and trade association political committees and coalitions, to further its public policy and business interests. In-kind contributions of equipment or employee time are considered to be political contributions, and must be approved by the Senior Vice President and General Counsel or the Vice President - Government Affairs. Notwithstanding the decision that the U.S. Supreme Court issued in 2009 in Citizens United v. Federal Election Commission, the Company has no intention of engaging in electioneering communications, i.e., expending corporate funds specifically to advocate the election or defeat of political candidates.
Campbell's Government Affairs Department manages all of the Company's political programs and contributions and works with Company employees in support of the Company's constructive involvement in political and public policy activities. The Company does not make financial contributions to "527" organizations that are not principal campaign committees or political parties.
The Vice President - Government Affairs prepares an annual report, for review by the Board of Directors, on all political spending by the Company, including but not limited to:
Campbell PAC was established in 2005 and makes contributions to U.S. congressional candidates who share the Company's views on public policy issues. Campbell PAC is a separate legal entity from the Company.
Consistent with U.S. federal law, Campbell Soup Company does not use corporate funds or assets for federal political contributions. Voluntary personal contributions to Campbell PAC are solicited from selected employees in compliance with U.S. federal election laws. Consistent with federal law, all contributions made by Campbell PAC, and all individual contributions to Campbell PAC totaling $200 or more annually, are itemized in monthly disclosures to the Federal Election Commission (FEC) and available for public review.
Members of the governing board of Campbell PAC are appointed by the President and Chief Executive Officer. The Vice President - Government Affairs, who serves as Treasurer of Campbell PAC, recommends fundraising plans and contributions for approval by the governing board. Upon approval of such recommendations, the Treasurer of Campbell PAC implements these plans by reviewing all specific requests for political contributions. Funds are dispersed only to candidates who are approved for contributions, and only within contribution limits prescribed by the governing board. Campbell PAC contribution checks require the signatures of both the Treasurer and the Chair of the Campbell PAC governing board. In either's absence, for contributions of $1,000 or less, the Assistant Treasurer may sign the contribution check.
1 Section 501(c)(6) of the Internal Revenue Code provides for the exemption of non-profit business leagues, chambers of commerce, etc.
2 Section 501(c)(4) of the Internal Revenue Code provides for the exemption of “social welfare organizations” that include non-profit civic leagues or organizations but operated exclusively for the promotion of social welfare, and may be engaged in substantial lobbying activities.
Trade Association Activity
Campbell Soup Company is a member of several food and manufacturing industry trade associations at the federal, state, and local levels. Most of these organizations engage in lobbying activities, operate their own political action committees, and engage in political education programs.
Campbell supports trade associations through the payment of annual dues based primarily on its net sales of applicable products sold in the United States. In some instances, the Company makes additional payments in the form of contributions and special assessments to support special projects and coalition activities, including lobbying projects at the federal and state levels. In addition, Campbell PAC makes PAC-to-PAC transfers to major industry trade association PACs. Campbell exercises no authority over decisions made by trade associations regarding the direction of their political contributions and related spending.
Attachment I - Members of Campbell PAC Governing Board
Attachment II - Criteria for Contributions by Campbell PAC
Attachment III - FY2016 Campbell Soup Company Corporate Political Contributions and Campbell PAC Contributions
Attachment IV - FY2016 Corporate Trade Association Memberships with Dues over $10,000 and any contributions made to 501(c)4 organizations for political purposes
Members of Campbell PAC Governing Board
Rich Landers, Vice President - Tax & Real Estate (Chairman)
Kelly Johnston, Vice President - Government Affairs (Treasurer)
Steve Armstrong, Senior Food Law Counsel
Mark Cacciatore, Vice President - Manufacturing, Napoleon Operations
Bob Centonze, Senior Vice President - Human Resources (World Headquarters)
Adam Ciongoli, Senior Vice President and General Counsel
Ken Gosnell, Vice President - Finance Strategy & Investor Relations
Anthony Sanzio, Vice President - Global Communications
Mark Schreiber, Vice President - Sales & Distribution
Craig Slavtcheff, Vice President - Global Science & Technology
Dave Stangis, Vice President - Public Affairs & Corporate Responsibility
Tom Weill, Vice President - Strategic Supply Chain Services
Criteria for Contributions by Campbell PAC
Key Legislative and Regulatory Issues
Campbell PAC does not make contributions based on any official actions by a federal candidate or office holder. Decisions made by Campbell PAC with respect to financial contributions to candidates are based on the following guidelines:
FY2016 Campbell Soup Company Corporate Political Contributions
|NJ Organization for a Better State (NEW JOBS)||$ 7,200|
FY2016 Campbell PAC Contributions
|Total FY2016 Employee Contributions||$ 30,238|
|Total FY2016 Contributions to Candidates||$ 28,500|
|Cash on Hand at Year End (as of July 31, 2016)||$ 29,063|
FY2016 Corporate Trade Association or Related Memberships with Dues Exceeding
$10,000 and Portion of Dues Spent on Lobbying Activities
|American Association of Chambers of Commerce in Latin America||$ 1,500|
|American Bakers Association||$ 5,570|
|American Benefits Council||$ 6,600|
|Business Roundtable||$ 74,730|
|California League of Food Processors||$ 5,670|
|Canadian American Business Council||$ 0|
|Chamber of Commerce of Southern New Jersey||$ 2,274|
|Chamber of Commerce of the United States||$ 4,000|
|Food Drug Law Institute||$ 0|
|Food Marketing Institute||$ 3,300|
|Grocery Manufacturers of America||$ 317,309|
|National Association of Manufacturers||$ 10,366|
|No contributions were made to 501(c)4 organizations for political purposes.|
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