DEFINING SUCCESS // Corporate Governance and Ethics

Public Policy Engagement

Campbell participates actively in the discussion of local, state, national, and international public policy issues relevant to our business strategies and operations, from food safety and advertising to healthcare and international trade. We also contribute to public dialogue on policy issues through our memberships in food industry trade associations, such as the Grocery Manufacturers of America, the Food Marketing Institute, the American Bakers Association, the Confederation of Food and Drink Industries of the EU, the Food and Consumer Products Association of Canada, the Australian Food and Grocery Council, and the International Life Science Institute. We express our views candidly and are committed to transparency in our interactions with government agencies and officials. Campbell's lobbying disclosure reports are filed with the appropriate state and federal authorities under the U.S. Lobby Disclosure Act and are available for review at United States Senate Public Disclosure site.

In 2009, Campbell adopted a formal set of Political Accountability Guidelines and related disclosures, which are available on the company's public website. In the U.S., the company does not endorse any individual political party or candidate, but we do encourage voluntary political activity by our employees. Our employees can contribute funds to political candidates and organizations engaged in policy issues that are important to our company, such as food manufacturing standards and worker safety, through Campbell's Political Action Committee (PAC), a segregated fund that is affiliated with the company. Contributions made by the Campbell PAC are publicly reported in accordance with federal law. To view Campbell PAC's disclosures of contributions and expenditures to the Federal Election Commission (FEC), visit FEC Disclosure Data site.

Also in 2009, Campbell established its Public Policy Council, an 11-member committee of senior executives that evaluates and advises the company on the array of public policy issues that affect Campbell and the food industry. By providing thoughtful analysis and leadership, the Public Policy Council helps Campbell's Government Affairs group provide information and valuable insights to both to our trade associations and directly to regulatory agencies and elected officials.