Compliance & Oversight

 
 
​Our participation in political and public policy processes is subject to an extensive framework of laws, regulations, public disclosure, company policies and internal oversight.
We maintain a robust political activity compliance and integrity program that comprehensively addresses our companies’ political and public policy activities. This program is based upon our Code of Conduct​, which outlines key risk areas and the principles​ that should guide employees’ actions. 
Our political activity compliance and integrity program incorporates best practices and includes detailed policies and procedures to comply with the laws related to these public policy activities. Additionally, we systematically review both our political activity compliance program and our companies’ political activities, which has resulted in Altria Group being recognized as a leader for its commitment to political transparency and accountability.
​Policies & Procedures Guiding Our Involvement In the Public Policy Process 
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There are many laws and regulations that govern a company’s public policy engagements, including laws that govern direct lobbying, grassroots advocacy and other interactions with government officials. Altria and its companies are committed to complying with such laws and have established specific policies and procedures regarding them. Our policies and procedures govern interactions with government officials, including both direct and grassroots lobbying activities, and are designed to enable Altria and its companies to participate in the public policy process in ways that both enhance shareholder value and are consistent with Altria’s Mission & Values. 
Among many important requirements, the policies prohibit employees from: 
  • engaging in the direct lobbying of government officials without approval from both the Altria Client Services (ALCS) Law department and the ALCS External Affairs department; and 
  • engaging in grassroots activities without approval from both the ALCS Law department and the ALCS External Affairs department.
Policies & Procedures Guiding Our Involvement In the Political Process 
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Federal, state, and local laws impose significant restrictions on the political activities of corporations and their PACs. Altria’s companies have comprehensive policies and procedures to provide direction to employees who engage in the political process.  
These policies prohibit employees from: 
  • providing political contributions in anticipation of, in recognition of, or in return for an official act;
  • seeking or receiving direct or indirect reimbursements for personal political contributions or expenses;
  • pressuring or coercing fellow employees to make personal political contributions; and 
  • rewarding another employee or making employment decisions based in whole or in part on that employee’s personal political contributions.
​Approval Process for Political Contributions 
Every proposed political contribution must be legally permissible and in the best interests of the company making the contribution and our shareholders.
Altria uses several guiding principles when selecting which candidates or committees receive PAC or corporate political contributions, including whether: 
  • Altria and its companies have employees or facilities located within the state or district; 
  • Altria and its companies conduct business in the state or district;
  • the candidate serves on a legislative committee with jurisdiction over issues of interest to Altria’s companies;
  • the recipient understands the legislative and regulatory issues related to Altria’s businesses; and 
  • the candidate is a member of congressional or state legislative leadership. 
PAC or corporate political contributions are made without regard to the private political preferences of any employee.
Each corporate political contribution made by Altria Group and its companies requires written advance approval from: 
  • ​the relevant State Government Affairs Regional Director; 
  • the Vice President for State Government Affairs; 
  • the Senior Vice President for External Affairs; and 
  • an Assistant General Counsel in the Altria Client Services (ALCS) Law Department.
Contributions over $25,000 require the written approval of Altria’s General Counsel or his or her designee.​
The AltriaPAC and Ste. Michelle Wine Estates PAC Board of Directors approve each PAC contribution. The Directors are employees of the Altria family of companies.
Altria conducts regular trainings, compliance system reviews, and internal audits to ensure all PAC and corporate political contributions are made in accordance with the law and company policies.
Board Oversight 
 
The use of company resources for political and public policy activities can be an important issue for shareholders. Consistent with our principles of good governance and high standards for ethical conduct, the Altria Board of Directors’ Nominating, Corporate Governance and Social Responsibility Committee oversees our participation in the political and public policy processes and the political activity compliance program. Our companies provide periodic updates on political and public policy issues and engagements to the committee. Our companies also update the committee regarding contributions to organizations involved in the public policy arena, including trade associations and other tax-exempt organizations.
Altria shares extensive information about its participation in these areas on our website so shareholders and others can learn more about our political and public policy activities.
Leadership
 
Altria is recognized as a leader in political activities disclosure by many entities, including the Center for Political Accountability-Zicklin Index of Corporate Political Accountability and Disclosure (CPA-Zicklin Index), and the Baruch College Index of Corporate Political Disclosure (Baruch Index).
In 2016, the CPA-Zicklin Index ranked Altria 5th among the S&P 500 in terms of the voluntary disclosure of its political spending and designated the company as a "trendsetter" in this area.  This index is intended to provide a comprehensive portrait of accountability and disclosure practices of the largest U.S. public companies.
The Baruch Index, which measures a company's transparency concerning its corporate political activity, has also praised Altria’s efforts. The Baruch Index described Altria in 2011 as being a “leader” in publicly disclosing the “corporate policies, procedures and structures” related to its political activities. The Baruch Index focuses on:
  • the ease with which someone can find the relevant materials on the corporate website;
  • what policies, procedures and corporate governance structures are in place and disclosed; and 
  • what the corporation says about who and what it gives to, and how those donations are made.
We also are active members of the Conference Board’s Committee on Corporate Political Spending, a committee of corporations dedicated to accountability, education and engagement on issues of political activity. Through our work with the Committee on Corporate Political Spending and through other constructive engagements, we hope to provide leadership on these issues within the broader corporate community. Learn more about the Committee on Corporate Political Spending.