This Policy sets out the standards to be followed by anyone engaged in Lobbying or other political engagement on behalf of the Company, including those from outside the Company.
Our Policy covers the following requirements:
- BAE Systems shall only engage in Lobbying activities in the countries in which it operates in order to communicate with, and inform, legislators and government decision makers on matters relating to our business;
- All Lobbying activity is recorded and reviewed; and
- Anyone engaged in Lobbying activities on behalf of BAE Systems shall conduct themselves in a way that conforms with the BAE Systems’ standards of responsible business conduct.
Our employees are required to be open and transparent in dealings with legislators and government decision makers and declare the interest they are representing.
It remains the Policy of the Company not to make any political donations or incur political expenditure within the normal understanding of those terms. The Company has no intention of altering this Policy. However, the definitions of ‘political donation’ and ‘political expenditure’ within the UK Companies Act 2006 are very wide and potentially capture activities that would not be ordinarily considered to be such but form part of the Company’s usual business engagement with key stakeholders and allows the Company to participate in public debate and opinion-forming on matters which affect its business. Consequently, to avoid inadvertent infringement of the UK Companies Act 2006, authority is sought from shareholders at the Company’s annual AGM to make political donations and incur political expenditure up to a specified limit.
The BAE Systems Political Action Committee (PAC) in the US enables eligible BAE Systems Inc. employees to voluntarily contribute to the BAE Systems PAC, and is required to operate in full compliance with US federal laws and regulations.
Publication date: 20 May 2025
Governance and Disclosure