Lobbying Activities and Political Contributions
Power Corporation’s foundation of integrity and ethical business conduct is fundamental to our success and our ability to generate long-term sustainable growth. We have built our reputation on upholding high standards of conduct, earning the confidence, respect, and trust of business partners, shareholders, employees and communities where we are present. We are committed to carrying out business worldwide ethically and in accordance with all applicable laws, including with respect to lobbying activities and political contributions.
The Corporation has adopted a Lobbying Policy in order to ensure compliance with Canadian federal and provincial legislation regarding communicating with and lobbying of government officials. The policy establishes a framework for compliance with lobbying legal requirements relating to federal and provincial governments and outlines appropriate employee activity and approval processes.
In addition to our Lobbying Policy, our commitment to properly manage lobbying activities and political contributions is also incorporated in our Code of Business Conduct and Ethics and our Global Anti-Bribery Policy.
The Lobbying Policy applies to all oral or written communications with government officials by any director, officer or employee of Power Corporation and its wholly owned subsidiaries, unless a comparable policy applies in respect of a subsidiary, or persons authorized to act on their behalf concerning a change to an existing or proposed law, regulation, policy, program, permit, privatization, grant, financial contribution or appointment or the awarding of a contract, as further defined in the relevant provincial and federal lobbying legislation.
As per our Lobbying Policy, no director, officer or employee may engage or participate in any lobbying activity on behalf of the Corporation unless formally authorized to do so in advance by the Chief Executive Officer or General Counsel.
Before engaging in a specific lobbying activity, authorized individuals are required to notify in advance the General Counsel of the specific lobbying activity to be undertaken. No external consultant should be hired to communicate with a government official on behalf of Power Corporation without first seeking the approval of the General Counsel. No such outside consultant may be paid a success fee or compensation contingent on success.
Political contributions by Corporation personnel may only be made with personal funds and within the applicable Canadian federal and provincial limits. Employees who wish to make political contributions on their own behalf are expected to comply with the applicable legal requirements in the relevant jurisdiction and are strongly encouraged to verify with the General Counsel that they are fully compliant with applicable laws.
Our Global Anti-Bribery Policy also explicitly prohibits any charitable contributions made in an attempt to influence any decision or obtain an advantage. The Corporation is prohibited from making corporate charitable contributions to a charity owned or controlled by a public official in any jurisdiction.
Additionally, any director, officer or employee who engages in an approved lobbying activity must seek approval before engaging in political activity for any government official who the Corporation is lobbying or may seek to influence in the future. This includes organizing fundraisers or playing any campaign role.
No gift or hospitality shall be provided to any government official who the Corporation is lobbying or may seek to lobby in future, other than minor expressions of courtesy or protocol. Invitations of government officials to sporting events, meals, conferences or speaker series are strictly prohibited if the Corporation is lobbying or may seek to lobby such government official in future. Also, any gifts or hospitality to government officials must comply with our Code of Business Conduct and Ethics and Global Anti-Bribery Policy.
All our directors, officers, and employees receive a copy of our Code of Business Conduct and Ethics, our Global Anti-Bribery Policy, and our Lobbying Policy and are informed about their importance. They must also certify their compliance to our Code of Business Conduct and Ethics at least annually. Employees and officers additionally receive training annually on the Code of Business Conduct and Ethics and related policies, including lobbying activities and political contributions.
In addition, our group companies are responsible for implementing their own policies and procedures with regards to lobbying activities and political contributions. As part of our active ownership approach, we are committed to fostering compliance with lobbying and political contributions legislation by our subsidiaries.
Under our lobbying policy, directors, officers and employees who have been authorized to engage in lobbying activities on behalf of the Corporation must report monthly all of their lobbying activities for the applicable time period to the General Counsel. Reporting must include the time spent preparing for, travelling to, and engaging in lobbying, each separately tracked. Certain officers and certain employees must also confirm yearly that they have not engaged in any lobbying activities on behalf of the Corporation.
Where applicable, the General Counsel is responsible for managing federal and provincial lobbying registrations for the Corporation, including filing the required semi-annual and monthly communication reports if applicable.
Responsibility and Review
The General Counsel is responsible for implementing the policies and procedures related to lobbying activities and political contributions. He also reviews compliance with internal reporting requirements relating to such activities. He is responsible for conducting an annual review of the lobbying policy and its effectiveness and will revise and update it as necessary.