Approval Process
Every proposed political contribution undergoes an internal review process to evaluate whether it is legally permissible and in the best interests of the company making the contribution and our shareholders. In many cases, we may not agree with every position taken by a candidate whom we support.
Each corporate political contribution made by the Altria Group and its companies receives advance written approval from: (1) the relevant State Government Affairs Regional Director; (2) the Vice President for State Government Affairs; (3) the Senior Vice President for External Affairs; and (4) an Assistant General Counsel in the Altria Client Services (ALCS) Law Department. Additionally, contributions over $5,000 cannot be made without the written approval of Altria’s General Counsel or her designee.
The Board of Directors for AltriaPAC and Ste. Michelle Wine Estates PAC approve each PAC contribution as required by their by-laws and procedures. The Directors are employees of the Altria family of companies.
Altria utilizes several guiding principles when selecting which candidates or committees receive PAC or corporate political contributions. When making these decisions, Altria considers whether: any Altria employees or facilities are located within the state or district; Altria and its family of companies conduct business in the state or district; the candidate serves on a legislative committee with jurisdiction over issues of interest to Altria; 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. As such, PAC or corporate political contributions are made without regard to the private political preferences of any employee.
Board Oversight
Altria recognizes that the use of company resources in the political process is an important issue for shareholders. Accordingly, our companies provide periodic updates on political and public policy issues to the Nominating, Corporate Governance and Social Responsibility Committee. The Committee also receives updates regarding corporate and PAC political contributions as well as contributions to trade associations and other tax-exempt organizations.
Policies for Employees
Federal, state, and local laws impose significant restrictions on the political activities of corporations and their PACs. For compliance with these complex laws, each Altria company adopts comprehensive policies and procedures that provide direction to employees who engage in the political process. Among many important requirements, the 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.
Contributions to Third Parties
While each Altria company prefers to make political expenditures directly rather than through third-party groups, Altria and its companies, like all major corporations, are members of various 501(c) organizations that may engage in political activities. Altria and its companies may not necessarily agree with every position taken by each organization to which we contribute, but we determine that the intended use of a contribution is consistent with Altria’s Mission and Values before making a contribution to any such group. We also request that the recipient tell us what portion of our dues or similar payment is used for political activities, making it non-deductible under Section 162(e)(1)(B) of the Internal Revenue Code. To the extent it is reported to us, we disclose the non-deductible portion of our contributions on an annual basis, where such portion exceeds $50,000 in a calendar year.
For 2012, no 501(c) organization reported that the Section 162(e)(1)(B) non-deductible portion of dues paid by Altria exceeded $50,000.