Global Lobbying and Political Support Policy
Trusted to Deliver Excellence
Introduction
Rolls-Royce is committed to ensuring that any Lobbying Activity or Political Support in which it
participates is done in full compliance with all laws and regulations, in accordance with our zerotolerance approach to bribery and corruption as set out in section 4 of the Rolls-Royce Global Code of
Conduct (the “Code”), and the standards set out in section 5.3 of the Code relating to Lobbying
Activity and Political Support.
The principles underpinning this this Global Lobbying and Political Support Policy (“Policy”) are:

Rolls-Royce engages with governments, their agencies and representatives in order to
communicate with them on matters relating to Rolls-Royce business;

Individuals or entities engaged in Lobbying Activities on behalf of Rolls-Royce (including third
parties) must:

be authorised to do so by Rolls-Royce Government Relations;

be registered in the relevant country where applicable; and

conduct themselves in a way that conforms with all applicable laws, the Company’s
standards within the Code and with honesty, integrity and transparency in all
dealings with governments, their agencies and representatives.

Rolls-Royce does not make corporate contributions or donations to political parties or to any
organisations, think-tanks, academic institutions or charities closely associated to a political
party or cause;

Rolls-Royce does not have any preference for one political party over another; and

Rolls-Royce employees may take part in party politics or make personal political donations
outside the business and in their own time.
This Policy is mandatory and applies to all employees and representatives of Rolls-Royce and its
wholly owned subsidiaries (“Rolls-Royce” or “Company” or “employees”). A Rolls-Royce employee
who is a director on a Board of a joint venture should encourage the joint venture to adopt this Policy
as a model or use a similar policy which meets similar standards.
This Policy and the other Anti-Bribery and Corruption Policies (“ABC Policies”) set a minimum
standard that must be followed. Where local laws, regulations or rules impose a higher standard, that
higher standard must be followed. Breaches of the ABC Policies are not acceptable and may result in
disciplinary action up to and including dismissal..
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Common Terms
Rolls-Royce Government Relations: one of
Lobbying Activity: engagement with
the following:
governments, their agencies and

United Kingdom – UK Government
representatives in order to communicate with
Relations
them on matters relating to Rolls-Royce

European Union – EU Affairs
business.

North America (US and Canada) –
Government Business

Rest of the world – contact your Regional
Director/Country Director in the first
Political Support: activity which requires
Rolls-Royce, or its representatives, to come
into contact with the political community or
deal with political matters.
instance or if you have no Regional
Director or Country Director contact the
Political Donation: a payment or transfer of
Director of Rolls-Royce International
value made to a political party, or organisation,
Contact details are available on the
think-tank, academic institution or charity
Government Relations page of the
affiliated with a political party, or any
Rolls-Royce intranet.
representatives of such parties, or individuals
standing for public office.
1. Global Lobbying and Political Support
Policy
1.1 Policy
1.1.1
All Lobbying Activity and Political
1.1.3
Rolls-Royce and its employees must
Support will be consistent with Rolls-Royce
not make any Political Donations on behalf of
principles and standards as defined in the
Rolls-Royce.
Code.
1.1.4
1.1.2
All employees who are contemplating
Rolls-Royce will act in an entirely open
manner within the laws and regulations
Lobbying Activity or Political Support must
applying to Lobbying Activity, Political Support
seek advice from the relevant Rolls-Royce
or Political Donations in all the countries in
Government Relations to ensure compliance
which the Company operates.
with local laws and regulations.
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1.1.5
Certain Rolls-Royce employees in the
1.2.5
All employees must report as soon as
United States have the right under United
possible if you know or suspect a breach of
States law to organise Political Action
any ABC Policy by you or by another person,
Committees to advance in a collective fashion
including those acting on behalf of Rolls-Royce
to support their political and policy interests.
who are not Rolls-Royce employees (for
These committees are funded by voluntary
example, logistics providers). Reports should
donations via payroll deduction and are
be made to a member of the ABC Compliance
administered by a committee of employees
team, the Legal Function or the Ethics Line.
who act on their behalf, independently of the
company. Rolls-Royce will comply with all
laws and regulations governing Political Action
1.3 Report on Lobbying
Activity
Committees organised by its employees in the
United States.
1.3.1
The Director of Rolls-Royce
International will submit an annual report to the
1.2 Lobbying
Rolls-Royce Safety and Ethics Committee on
the following:
1.2.1
Any third party conducting Lobbying
a.
Activity on behalf of Rolls-Royce must be
approved under the Rolls-Royce Global
Registers;
b.
Advisers Policy.
All employees, and anyone acting on
Political Support activity together with
Lobbying Activities, will act at all times with
the payments made to those Advisers
honesty and integrity and will ensure that
as provided by the ABC Compliance
information they provide in their Lobbying
team;
d.
fairly represented.
1.2.3
The information which will be included in
the Rolls-Royce Annual Report and on
the Sustainability section of the Rolls-
All employees, and anyone acting on
Royce website in relation to Lobbying
behalf of Rolls-Royce, will be open and
Activity and Political Support activity;
transparent in their dealings with governments,
and
their agencies and representatives and declare
the interest they are representing.
An overview of Advisers who have been
undertaking Lobbying Activity and
behalf of Rolls-Royce in connection with any
Activities is transparent, factually correct and
The structure of the Rolls-Royce
Government Relations function globally;
c.
1.2.2
Rolls-Royce entries on Lobbying
e.
Information from Rolls-Royce North
America as required by the United
1.2.4
Divisional Presidents, business
States Government under the Lobbying
leaders and functional heads will ensure that
Disclosure Act of 1995 to report on a
anyone in their division or function engaged in
quarterly basis all expenditures incurred
Lobbying Activity or Political Support is briefed
and issues lobbied.
on and complies with the Code and this Policy.
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1.4 Political Support
Activities
1.4.1
Rolls-Royce does not have any
1.4.2
As a matter of general principle, the
preference for one political party over another
Company will decline any invitation for political
but, from time to time, Rolls-Royce may be
comment and, if there is any doubt, all
involved in activities which involve the political
employees should consult Rolls-Royce
community, for instance visits to Company
Government Relations for advice.
sites, or requests to use facilities during
politically sensitive periods. Employees should
always seek advice from Rolls-Royce
Government Relations before giving approval
for such a visit.
2. Where to find out more

Government Relations
www.infocentre.rolls-royce.com/government_relations/default.htm

The Rolls-Royce ABC Compliance team
www.infocentre.rolls-royce.com/compliance/pages/compliance_contacts.htm
or specifically the office of the Chief Compliance Counsel – ABC:
Jo Morgan
Chief Compliance Counsel – ABC
Rolls-Royce plc
62 Buckingham Gate, London SW1E 6AT
Telephone: +44 (0) 207 227 9115
Email: Jo.Morgan@Rolls-Royce.com
3. Other documents you should read

The Rolls-Royce Global Code of Conduct
www.rolls-royce.com/global_code_of_conduct

The ABC Policies and guidance documents on the Rolls-Royce Compliance intranet pages
www.infocentre.rolls-royce.com/compliance
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Document control - for internal use only
STATUS
Final
VERSION NUMBER/FINAL
Version 1
EFFECTIVE DATE
23 January 2015
NEXT SCHEDULED REVIEW
DATE
SPONSOR
January 2016
OWNER
Chief Compliance Counsel
AUTHOR
Chief Compliance Counsel
SUPERSEDES VERSION
DATED/REFERENCE
SCOPE
First issue
Director of Risk
All employees globally, subsidiaries and JVs
© 2015 Rolls-Royce plc
The information in this document is the property of Rolls-Royce plc and may not be copied,
communicated to a third party, or used for any purpose other than that for which it is supplied, without
the express written consent of Rolls-Royce plc.
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