U.S. Political Contributions and Advocacy
As a leading global agricultural processor and food-ingredient provider, Archer Daniels Midland Company connects the harvest to the home, making products for food, animal feed, industrial and energy uses.
Our ability to fulfill this vital purpose is enhanced when government policies impacting our operations promote growth — growth that facilitates job creation; encourages ongoing investment in our business, our employees and the communities where we live and work; and returns value to our stockholders.
ADM's Board of Directors believes that participation in the political process is an important element of our business, one undertaken for the benefit of all company stakeholders. We therefore support candidates for political office and organizations that share our pro-growth vision, our aspirations for the future of global agriculture, and our commitment to the people who depend on it for their lives and livelihoods. In particular, we support candidates and organizations that share our views regarding: continued investment in America’s infrastructure, particularly our inland waterways; reducing barriers to trade; the value of biofuels to the transportation fuel mix; and support for ports and highways. Decisions to support particular candidates and/or organizations are determined by the company’s best interests, not the personal political preferences of ADM executives.
Policies and Guidelines
In addition to individual candidates for public office and candidate committees, ADM supports a small number of 527 groups, including the Democratic Governors Associations, the Republican Governors Association and Ag America (Republican Agriculture Commissioners). We do not support independent political expenditures or 501(c)4 organizations.
ADM’s 2019 corporate contributions through March 31 totaled $18,250, with recipients ranging from individual state candidate campaigns to state political parties and select state and national political associations.
ADMPAC's contributions to federal candidates, state candidates, and various federal and state campaign committees through March 31, 2019 total $42,500. These PAC contribution figures and supporting data have been filed with the Federal Election Commission. Past years' totals follow.
Reporting and Disclosure
ADM management reports on our company’s political contributions, compliance and strategy to the Board of Directors on a quarterly basis. The Board’s Nominations and Corporate Governance Committee, composed solely of outside directors, reviews these reports at each of its meetings to ensure we are in compliance with our political contributions policy. We submit quarterly reports to Congress detailing our federal lobbying, as required by the Lobbying Disclosure Act. In addition, ADM's federal PAC is required to submit to the Federal Election Commission regular, detailed reports of all distributions and contributions. These reports are available to the public online. ADM’s political activities and contributions are also subject to state-level regulations. States that allow corporate contributions to candidates or political parties require that the identity of the donors and the dollar amounts of political contributions be disclosed. This information is widely available on individual states’ websites.
ADM has memberships in several industry, trade and business associations representing agriculture and the business community.
This allows us to work with many organizations on a variety of topics and advocate on behalf of our shareholders, our business, our customers, our employees and our communities.
While we may not always agree with all of the positions taken by an association or its members, corporate memberships enable us to learn the views of others, obtain feedback, and ultimately, voice our concerns, perspectives and positions on proposed legislation and regulations in a more educated and thoughtful manner.
One manner in which ADM supports political advocacy is through memberships in trade associations, which in turn engage in political advocacy. The amount of dues associated with this political advocacy is duly reported in ADM’s Quarterly LD2 filings. In 2017, the top associations in which ADM maintained membership that engaged in lobbying (based on dues attributed to lobbying) were:
American Peanut Shellers Association
Corn Refiners Association
National Association of Manufacturers
National Biodiesel Board
National Oilseed Processors Association
On occasion, ADM supports efforts to influence the outcome of ballot initiatives at the state and local level. In 2017, ADM did not engage in this type of advocacy.
Political Expenditures and Contributions
As a registered entity that employs lobbyist, ADM files six reports each year with the Clerk of the House and the Secretary of the Senate. ADM’s LD-2 reports disclose expenses related to lobbying activities. ADM’s LD-203 discloses contributions made to Members of Congress.
Political Activity by ADM Employees
Some ADM employees choose to support the well-being of their communities by participating in the political activities of their choice. However, they may only participate in such activities on their own time and at their own expense. They may never use ADM property or resources for personal political activities. In addition, they are prohibited from engaging in any political activities on ADM’s behalf, unless authorized to do so. Employees may not attempt to coerce coworkers, especially those who report to them, to support their personal political causes or candidates.
Policy on Political Expenditures from Company Funds
ADM engages in a centralized, deliberative process when making decisions about the company's political participation to ensure that all applicable laws are followed, and all appropriate disclosures are made.
The company’s vice president of Government Relations and vice president of State Government Relations authorize expenditures of less than $1,000. Contributions of greater than $1,000 typically require the approval of the board of directors of ADMPAC, a political action committee funded by our employees’ voluntary contributions. The ADMPAC board of directors is chaired by the vice president of state government relations and composed of employees who represent various areas of the company.
From ADM’s Code of Conduct :
ADM will only engage in the political process when allowed by law. Our company will only contribute to political candidates or campaigns with the prior written approval of our CEO or the Government Relations department. “Contribute” is a broad term and may include money, property, services and so forth.
Lobbying activities are highly regulated. We therefore may not make any contacts with government officials in an attempt to influence legislation, regulation, policy or other governmental actions on ADM’s behalf. The only exception to this rule is when you have specific permission from our CEO or the Government Relations department. Additionally, lobbying activity may require certain reporting requirements.