PUBLIC POLICY & POLITICAL ENGAGEMENT

The Coca‑Cola Company, together with our bottling partners, is a system of more than 700,000 employees that delivers refreshment every day in 200+ countries and territories.  We are constantly transforming our portfolio to meet consumer preferences, while doing more in water replenishment, recycled packaging, sustainable sourcing, and carbon emissions reduction.  We consider it our responsibility to make our voice heard on policy issues that impact our business, employees, consumers, and shareowners.

Key Advocacy Areas

The Coca‑Cola Company’s public policy agenda is built around our mission to refresh the world and make a difference. In the U.S. and Canada, our policy priorities include sustainability, consumer preference, and community impact. Our advocacy often involves collaboration and thought leadership in the public and private sectors. When significant to our business interests, we may also advocate through lobbying and coalitions. The company’s public policy agenda in the U.S. and Canada is established by the North America Operating Unit and managed by the Vice President, Public Policy, Federal Government Relations & Political Engagement, and Senior Vice President & Chief of Public Affairs, Communications and Sustainability. The Corporate Governance and Sustainability Committee of the Board of Directors provides oversight and annual reviews.

Lobbying

Coca‑Cola engages in direct advocacy at U.S. federal and state levels of government to share information and perspective on our public policy priorities. The company discloses our lobbying activity and expenditures as required by law and adheres to the highest ethical standards.  Coca‑Cola files federal lobbying reports quarterly with the Office of the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate and makes these reports available on our company website.  We file state lobbying activities with the appropriate governing agencies.   LOBBYING DISCLOSURE REPORTS

Political Engagement Outside the United States

Coca‑Cola engages in direct advocacy outside the U.S. to share information and perspective on our public policy priorities. As true in the U.S., the company follows all national laws regarding political engagement and discloses our political giving as required by law in the countries where we operate. Disclosure of political contributions are made according to each country’s legal framework and through the relevant national and regional regulatory authorities. Links to the relevant national and regional regulatory disclosure repositories are listed below.

• European Transparency Register
• Australian Electoral Commission
• Australian Labor Party

Trade & Other Tax-Exempt Organizations

Coca‑Cola's business operations reach many markets. Our membership with trade groups and related organizations gives us the opportunity to exchange ideas among a broad range of perspectives on our key policy issues. While we may not agree with every position of each organization, the company believes diverse perspectives help contribute to balanced policy outcomes. The company voluntarily discloses our trade and social welfare group affiliations on a semi-annual basis.

• Trade groups organized under Section 501(c)(6) of the Internal Revenue Code to which we contribute $25,000 or more in membership dues, along with amounts attributed to lobbying as identified by those organizations as non-deductible expenditures under § 162(e)(1).  TRADE GROUP MEMBERSHIPS

• Social welfare groups organized under Section 501(c)(4) of the Internal Revenue Code to which we contribute, along with amounts attributed to lobbying as identified by those organizations as non-deductible expenditures under § 162(e)(1).  The company does not make contributions to 501(c)(4) organizations for electoral purposes.  SOCIAL WELFARE GROUP CONTRIBUTIONS
   

Corporate Political Contributions

Consistent with U.S. federal law, Coca‑Cola does not use corporate funds to contribute to federal candidates, political parties, or political committees, or otherwise employ its resources, including in-kind, even when permitted by law. The company has a long-standing policy against use of corporate funds for independent expenditures or Super PACS, including toward electioneering communications.  As of January 1, 2021, the company has not used corporate funds to directly support state or local political candidates, even if permitted by law. 

The company, however, contributes funds on a limited basis to political groups organized under Section 527 of the Internal Revenue Code.  In some instances, the company may also contribute corporate funds for the purpose of supporting or opposing state and local ballot initiatives with material impact on our business operations, if permitted by law.  The Vice President of Public Policy & Government Relations, along with Legal, approves corporate political contributions, while ballot initiatives require additional approval by the Senior Vice President & Chief of Public Affairs, Communications and Sustainability and the President of the North America Operating Unit.  When the company contributes to political groups, the information is voluntarily disclosed on our company website.  POLITICAL CONTRIBUTIONS
 

The Coca‑Cola Political Action Committee

The Coca‑Cola Company Nonpartisan Committee for Good Government, our employee-funded Political Action Committee (Coca‑Cola PAC), makes political contributions in a bipartisan manner to U.S. candidates based on alignment with established criteria and our company values. The Coca‑Cola PAC Board of Directors evaluates political contributions quarterly and our eligibility criteria on an annual basis.
 

Coca‑Cola PAC Criteria

Coca‑Cola PAC Match Program  

The Coca‑Cola PAC Match Program provides support to charities that focus on community wellbeing, economic empowerment and environmental sustainability. Coca‑Cola PAC members can designate charitable organizations to receive contributions in a dollar amount equal to their year-end PAC total. Gifts to matched organizations are funded by the general corporate treasury.  Neither The Coca‑Cola Company nor the PAC contributor receives a tax deduction for these donations.  RECIPIENTS

Employee Political & Civic Engagement

We encourage a culture of civic and community engagement. And we do so by not including the personal political views of company directors, leaders and employees in the political decisions the company or Coca‑Cola PAC makes. Company initiatives that encourage civic participation must fully respect an employee’s choice on whether, or not, to engage. Employees may not be reimbursed, directly or indirectly, by the company for personal political contributions and expenses.

Oversight & Compliance

The Corporate Governance and Sustainability Committee of the Board of Directors annually reviews our public policy agenda and advocacy program. These reviews ensure that our activities align with our business interests and serve the needs of our shareowners and broader stakeholder community.  The Vice President of Public Policy & Government Relations is responsible for management of Coca‑Cola's public policy agenda and political engagement, in consultation with the Senior Vice President & Chief of Public Affairs, Communications and Sustainability, and the Legal Department.  Coca‑Cola's political participation is conducted in an open and nonpartisan manner and in strict compliance with the Code of Business Conduct, the U.S. Political Engagement Policy, and applicable laws and regulations.