Political Contributions and Lobbying Expenditures
Raytheon participates in the U.S. political process to ensure that the Company’s interests as a leading member of the aerospace and defense industry, and as a significant employer and taxpayer, are appropriately represented. The Company maintains detailed policies and oversight procedures to ensure that political contributions and lobbying expenditures are made in a legal, ethical, and transparent manner. In all such activities, Raytheon complies with all relevant laws and regulations and adheres to the highest standards of ethical conduct consistent with its Code of Conduct.
Political Contributions and Activities
Raytheon has established a Domestic Political Contributions and Activities Policy (Political Contributions Policy) to assure that any contributions made with Company funds and political action committee activities comply with all relevant federal, state and/or local laws, as well as Raytheon’s governance processes and procedures. Among other things, this policy establishes the Raytheon Political Action Committee (RAYPAC) operating in accordance with Federal Election Commission (FEC) standards as the only federal PAC empowered to solicit employees for political contributions. It also prohibits Company employees from volunteering their services to a candidate or political committee during work hours and sets forth a specific approval process required in connection with any political contribution from Company funds.
Raytheon Political Action Committee
The Company offers eligible employees an opportunity to make voluntary political contributions to RAYPAC which, in turn, supports candidates for federal office and some state offices, and organizations operated in accordance with Internal Revenue Code (IRC) Section 527. RAYPAC is governed by a Steering Committee comprised of senior management from each of the Company’s business units as well as representatives from its government relations and legal functions selected in accordance with the RAYPAC by-laws. The Steering Committee is led by an Executive Committee, the membership of which currently includes the following Company officers: the Vice President, Internal Audit; the Vice President, Government Relations; the Vice President, Legal, International and Washington Operations; the Company’s PAC Manager; and a representative from Corporate Finance.
RAYPAC is registered with the FEC, and its activities are reported per the FEC’s required filing schedule. RAYPAC contribution information is available at www.fec.gov.
In addition to RAYPAC, Raytheon also sponsors two state political action committees (PACs). These PACs operate under, and comply with, the statutes and regulations in effect in the state in which they operate. These state PACs are governed by the same individuals who, at any given point in time, are responsible for RAYPAC governance. Contribution information can be found at the following state agency websites: Arizona Secretary of State and the California Secretary of State. Arizona and California State PAC contribution information for 2015 are set forth in the following report: 2015 Arizona and California State PAC Disbursements.
Direct Corporate Political Contributions
As reflected in the table below, in 2015, no contributions were made from Company funds to any individual candidate or Section 527 organization. Further, the Company has no plans to make direct political contributions from Company funds in the future. In the event that the Company makes any direct political contributions from Company funds in the future, it would disclose such contributions.
On a limited basis in the past, the Company has made direct corporate political contributions to state and local candidates, and to organizations operated pursuant to IRC Section 527, in accordance with the Political Contributions Policy. Pursuant to the Political Contributions Policy, no contributions were made from Company funds to any candidate, political committee or political party without the approval of Raytheon’s Political Expenditure Review Committee (PERC) which most recently included the following Company officers: the Vice President, Internal Audit; the Vice President, Government Relations; the Vice President, Legal, International and Washington Operations; the Company’s PAC Manager; and a representative from Corporate Finance.
2015 Corporate Contributions Summary
|Section 527 Contributions||$ 0|
|State & Local Contributions||$ 0|
|Total 2015 Corporate Contributions||$ 0|
Expenditures to the Public in Support of Political Campaigns and Ballot Measures
Raytheon does not spend Company funds on communications to the general public in support of political campaigns or ballot initiatives. In the event that the Company makes any expenditures from Company funds in support of political campaigns or ballot initiatives in the future, it would disclose such expenditures.
The Company has several policies in place related to its lobbying activities (Lobbying-Related Policies) to assure:
- Compliance with federal laws relating to lobbying, including complete and accurate reporting of lobbying activities under the Lobbying Disclosure Act (LDA);
- Compliance with state and local laws relating to lobbying, including complete and accurate reporting of lobbying activities where required; and
- Approval from the Vice President, Government Relations, or his designee prior to engaging in any contact or communication with elected officials, or their staff, on behalf of the Company.
Raytheon responsibly and lawfully engages in the legislative process to communicate its views on legislative and regulatory matters affecting the Company’s business and its various constituencies. In full compliance with the LDA and the Lobbying-Related Policies, the Company’s lobbying activities and expenses, as defined by Section 162 (e) of the Internal Revenue Code, are disclosed to the U.S. Congress on a quarterly basis. In addition, the Company files semi-annual reports detailing certain Federal Election Commission Act (FECA) contributions, honorary contributions, presidential library contributions, and payments for event costs. These reports are publicly accessible at the U. S. House of Representatives Office of the Clerk website. Raytheon’s quarterly federal lobbying reports for 2015 are set forth below.
The Company also files periodic reports with state and local agencies reflecting lobbying activities as required by relevant state and local laws. For the jurisdictions that provide online availability, the Company’s filed reports, as of January 31, 2016, can be found at the following linked websites:
Raytheon has in place sound procedures to assure the accuracy, timeliness, and oversight of its federal and state filings.
In the ordinary course of business, Raytheon participates in certain trade associations. Membership in trade associations can provide a number of benefits including: facilitating the Company’s ability to stay abreast of technical issues and emerging industry standards; providing educational opportunities for employees; reporting on trends; and engaging in public advocacy and education on behalf of the membership. Some trade associations utilize a portion of membership dues for non-deductible lobbying regarding issues of common concern to members. Under Section 6033(e)(1) of the Internal Revenue Code, trade associations are required to inform contributors of the portion of annual dues, if any, attributable to lobbying expenses. A listing of the trade associations to which Raytheon paid 2015 dues of $50,000 or more in 2015 and the portion of such dues, if any, not deductible under Section 162(e)(1) of the Internal Revenue Code, as reported by the organization, are set forth in the 2015 Trade Association Summary. There was also no other separate payment at this level made to a trade association in 2015 with the purpose that such payment be used for lobbying.
The Public Affairs Committee of the Board of Directors, which is composed entirely of independent directors, periodically receives reports on political and lobbying activities in accordance with its Charter.