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Engaging with Policymakers

Creating Better Days through civic engagement

Civic Engagement at Kellanova

We believe that responsible civic engagement is vital to creating better days and a place at the table for everyone. And we are committed to transparency in our work with external stakeholders and our participation in the political process.

Oversight & Compliance

We have a long-standing policy on corporate political activities, set forth below and in our Global Code of Ethics. We have controls in place to direct, monitor, and disclose political activities in compliance with applicable laws.

  • Leadership: Our Vice President, Global Government Relations, in collaboration with the Senior Vice President, Chief Global Corporate Affairs Officer, manages involvement in the political process, with the General Counsel, Board of Directors, and independent experts providing oversight.
  • Government Relations: We undergo trainings on political and lobbying compliance and adhere to all rules and regulations governing these activities.
  • All Employees: Our Global Code of Ethics makes clear that employees have the right to support candidates, political parties, and organizations on their own time and in their personal capacity. However, employees cannot engage in these activities during working hours or use company resources for personal political activity. Kellanova does not reimburse employees for personal political contributions or other expenses. Employees also receive annual training on the code that addresses anti-corruption, anti-competitive behavior, data protection, and human rights. Read more about how we operate ethically and address social and enviornmental priorities here.

Engagement in Advocacy

Responsible Lobbying

Kellanova’s public policy agenda is anchored in our company’s vision toward a good and just world, where people are not just fed but fulfilled. Integrity and transparency are integral to this mission and our government relations activities.

  • In the U.S., we employ registered lobbyists at the federal and state level. Our federal lobbying expenses and lobbying issues are publicly disclosed on a quarterly basis as required by the Lobbying Disclosure Act. These reports can be found here. We also disclose state lobbying activities where required by law. These reports are made publicly available by the relevant state lobbying regulators and can be found here.
  • Outside of the U.S., disclosures are made according to each region or country’s legal framework. We are registered on the European Union Transparency Register, which is updated annually.

To learn more, our Global Wellbeing Positions, Metrics and Reporting provides detailed information covering a variety of topics. 

Involvement in Trade Associations
Kellanova regularly engages in multi-stakeholder partnerships to advocate together where a common position can be found. We respect the opportunity for all groups to participate in the policy process.

Kellanova is a member of, or otherwise contributes to, several associations engaging in lobbying and political activities worldwide. Globally, we publish a list of groups to which our dues/payments exceed $50,000 USD/year, and specific to U.S. federal lobbying, we indicate the portions attributed to non-deductible lobbying activities as reported to us by these organizations.

Following is a list of these organizations across the regions where we operate:

  • Global
    • Consumer Goods Forum*
    • International Food & Beverage Alliance
  • Europe
    • FoodDrinkEurope*
    • CEEREAL*
    • European Snacks Association*
  • Latin America
    • CONMEXICO*
    • ABIA* (Brazil Food & Beverage Association)
  • Asia, Middle East, & Africa
    • Food Industry Asia
  • North America
    • U.S.
      • Consumer Brands Association*
      • Association of Food and Dairy Retailers, Wholesalers, and Manufacturers
      • National Association of Manufacturers
      • The Food Industry Association (FMI)*
    • Canada
      • Food, Health & Consumer Products of Canada*
      • I.E. Canada (Canadian Association of Internal and External Importers)

*Denotes where Kellanova leaders serve on boards

Kellanova continuously reviews the positions of its trade associations and industry policy groups to which it belongs to assess the extent to which they align with the company’s own policy positions. We may not always agree with every position of our associations. When we do not agree, we communicate our position transparently and may engage independently. In the event of significant misalignment, we have a process in place to assess continued membership.

Kellanova also ensures that the individuals engaging with trade associations understand and adhere to company ethics and compliance policies.

Engagement in the Political Process

Corporate Political Contributions
Where permitted by law, Kellanova may contribute to candidates, political parties, political committees, and ballot initiatives. Any political contribution with corporate funds requires approval by the Vice President, Global Government Relations; Chief Global Corporate Affairs Officer; and the General Counsel. We’ve chosen not to engage in certain legally permissible political activities. For example, we do not make direct independent expenditures (IEs). We also do not contribute to IE committees (“super PACs”) or to other groups, e.g. 501(c)(4) and 527 organizations, for the purposes of making IEs.

Political contributions reflect the interests of Kellanova and not those of its officers, executives, or directors. We post details here of corporate political contributions in all countries they are made, although to date, all contributions have been U.S.-specific. We update this information semi-annually:

Our Board of Directors’ Social Responsibility and Public Policy Committee is composed entirely of outside directors, and has oversight responsibility of all government relations activities, political expenditures made with corporate funds, involvement in trade associations, and the company’s corporate civic engagement policy.

Employee Political Action Committee (PAC)

Originally established in 1976 under Kellogg Company, the Kellanova PAC is funded by personal, voluntary contributions from eligible employees and Board members, and is governed by an executive Steering Committee. The PAC is non-partisan and contributes to candidates across the political spectrum who support policies that enable the growth and prosperity of our company and our communities and advance our Better Days™ Promise social and environmental purpose strategy. 

  • Criteria used in determining financial support include:
    • Views on, and involvement in, business issues that are key to the company’s success;
    • Representation of a Kellanova facility, office or large employee base;
    • Ethical integrity of the candidate;
    • Leadership position and/or membership on key committees with jurisdiction over the company’s priority issues; and,
    • Strength of a candidate and financial need/impact of a contribution.
       
  • Reporting: The Federal Election Commission (FEC) regulates all PAC activity and requires that we report all campaign contributions and receipts exceeding $200/year. Our reports are publicly available on the FEC website. You may also find a list of our PAC contributions here.
     
  • Charity Match: We also sponsor a PAC charity match program, which provides support to our long-standing partners Action for Healthy Kids, Feeding America, Food Research & Action Center, Future Farmers of America, The Nature Conservancy, No Kid Hungry, and United Way. Kellanova PAC members can designate the organization to receive donations in a dollar amount that is 50% of their year-end PAC contribution total. These donations are funded by Kellanova’s general treasury. Neither the company nor PAC contributors receive a tax deduction for these donations.