PepsiCo Inc

PepsiCo's Board of Directors recognizes that the use of company resources in the political process is an important issue for shareholders and other stakeholders. It oversees the company's public policy processes and activities with the assistance of its Sustainability and Public Policy Committee. This includes the periodic review of policies and practices regarding political contributions, as well as the review of PepsiCo's expenditures of both corporate and political action committee funds. [...] PepsiCo monitors and abides by the changing laws and regulations governing lobbying activities, including rules regarding regional, national and sub-national lobbying registration and reporting obligations. In Europe, PepsiCo is registered in the E.U. Transparency Registry, where the company discloses fields of interest, contributions to policy discussions and costs associated with lobbying activities in the E.U. In the U.S., PepsiCo associates who engage in and support lobbying efforts at the federal and state levels undergo annual ethics training by expert outside counsel. PepsiCo discloses all lobbying activities at the federal, state and local level, as required by law. [...] PepsiCo annually reviews the benefits and challenges from membership in our major trade associations. In addition, our trade associations are required to obtain specific consent from PepsiCo to use PepsiCo's dues or similar payments for the funding of exceptional political expenditures beyond regular dues and business matters. PepsiCo specifically directs in writing each of its primary trade associations to use PepsiCo dues for general operating expenses and other routine activities, which includes lobbying executive and legislative bodies, and not to apply PepsiCo dues to any political event or election-related activity without a specific approval from PepsiCo. [...] PepsiCo regularly reviews the climate change positions taken by our trade associations, and we have publicly reported information on trade association positions as part of our annual CDP Climate Change Submission.

PepsiCo's Global Sustainability Office, led by the company's Chief Sustainability Officer, is charged with coordinating and informing the company's sustainability agenda across our value chain. Serving as the central connection point, the Sustainability Office works closely with leaders from across the business to drive continued progress against our climate change agenda and embed sustainability into our long-term strategic planning. The Board plays an essential role in determining our strategic priorities and considers sustainability issues (e.g., climate change) as an integral part of its business oversight. To this end, the Board established a Sustainability and Public Policy Committee to assist in providing more focused oversight of key sustainability, inclusion and public policy matters. One of the primary responsibilities of the Committee is to review PepsiCo's key sustainability programs and related goals and monitor the Company's progress toward achieving those goals, including progress against climate ambitions.

The Board established a Sustainability, Diversity and Public Policy Committee in 2017. The Committee assists the Board in providing more focused oversight over PepsiCo's policies and programs and related risks that concern key sustainability, diversity, equity and inclusion and public policy matters. [...] As specified in its Charter, the Sustainability, Diversity and Public Policy Committee oversees this policy and is responsible for reviewing the Company's key public policy trends, issues and regulatory matters, its engagement in the public policy process and the Company's political activities and expenditures. In addition, our Board receives information regarding the Company's public policy initiatives and developments as necessary.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]PepsiCo's Corporate Affairs department has specific teams and individuals who are assigned responsibilities for developing corporate policy and regulatory positions as well as engaging with external stakeholders on regulatory policy that aligns with our climate strategy. They manage relationships with policymakers, trade associations and non-government actors, coordinating activities such as advocating for consistent climate change positions that may influence regulatory policy globally and at the market level. Corporate Affairs works closely with the business units, Sustainability Office, and other functions to ensure that our external engagements are aligned with our overall strategy on climate action and advocacy.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]PepsiCo's Corporate Affairs department has specific teams and individuals who are assigned responsibilities for developing corporate policy and regulatory positions as well as engaging with external stakeholders on regulatory policy that aligns with our climate strategy. They manage relationships with policymakers, trade associations and non-government actors, coordinating activities such as advocating for consistent climate change positions that may influence regulatory policy globally and at the market level. Corporate Affairs works closely with the business units, Sustainability Office, and other functions to ensure that our external engagements are aligned with our overall strategy on climate action and advocacy.