Global Lobbying and Political Support Policy

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1 Global Lobbying and Political Support Policy Trusted to Deliver Excellence

2 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.. Lobbying and Political Support Policy version 1 Page 2 of 6

3 Common Terms Rolls-Royce Government Relations: one of the following: United Kingdom UK Government Relations European Union EU Affairs North America (US and Canada) Government Business Rest of the world contact your Regional Director/Country Director in the first instance or if you have no Regional Director or Country Director contact the Director of Rolls-Royce International Contact details are available on the Government Relations page of the Rolls-Royce intranet. Lobbying Activity: engagement with governments, their agencies and representatives in order to communicate with them on matters relating to Rolls-Royce business. Political Support: activity which requires Rolls-Royce, or its representatives, to come into contact with the political community or deal with political matters. Political Donation: a payment or transfer of value made to a political party, or organisation, think-tank, academic institution or charity affiliated with a political party, or any representatives of such parties, or individuals standing for public office. 1. Global Lobbying and Political Support Policy 1.1 Policy All Lobbying Activity and Political Support will be consistent with Rolls-Royce principles and standards as defined in the Code All employees who are contemplating Lobbying Activity or Political Support must seek advice from the relevant Rolls-Royce Government Relations to ensure compliance with local laws and regulations Rolls-Royce and its employees must not make any Political Donations on behalf of Rolls-Royce Rolls-Royce will act in an entirely open manner within the laws and regulations applying to Lobbying Activity, Political Support or Political Donations in all the countries in which the Company operates. Lobbying and Political Support Policy version 1 Page 3 of 6

4 1.1.5 Certain Rolls-Royce employees in the United States have the right under United States law to organise Political Action Committees to advance in a collective fashion to support their political and policy interests. These committees are funded by voluntary donations via payroll deduction and are administered by a committee of employees who act on their behalf, independently of the company. Rolls-Royce will comply with all laws and regulations governing Political Action Committees organised by its employees in the United States. 1.2 Lobbying Any third party conducting Lobbying Activity on behalf of Rolls-Royce must be approved under the Rolls-Royce Global Advisers Policy All employees, and anyone acting on behalf of Rolls-Royce in connection with any Lobbying Activities, will act at all times with honesty and integrity and will ensure that information they provide in their Lobbying Activities is transparent, factually correct and fairly represented All employees, and anyone acting on behalf of Rolls-Royce, will be open and transparent in their dealings with governments, their agencies and representatives and declare the interest they are representing Divisional Presidents, business leaders and functional heads will ensure that anyone in their division or function engaged in Lobbying Activity or Political Support is briefed on and complies with the Code and this Policy All employees must report as soon as possible if you know or suspect a breach of any ABC Policy by you or by another person, including those acting on behalf of Rolls-Royce who are not Rolls-Royce employees (for example, logistics providers). Reports should be made to a member of the ABC Compliance team, the Legal Function or the Ethics Line. 1.3 Report on Lobbying Activity The Director of Rolls-Royce International will submit an annual report to the Rolls-Royce Safety and Ethics Committee on the following: a. Rolls-Royce entries on Lobbying Registers; b. The structure of the Rolls-Royce Government Relations function globally; c. An overview of Advisers who have been undertaking Lobbying Activity and Political Support activity together with the payments made to those Advisers as provided by the ABC Compliance team; d. The information which will be included in the Rolls-Royce Annual Report and on the Sustainability section of the Rolls- Royce website in relation to Lobbying Activity and Political Support activity; and e. Information from Rolls-Royce North America as required by the United States Government under the Lobbying Disclosure Act of 1995 to report on a quarterly basis all expenditures incurred and issues lobbied. Lobbying and Political Support Policy version 1 Page 4 of 6

5 1.4 Political Support Activities Rolls-Royce does not have any preference for one political party over another but, from time to time, Rolls-Royce may be involved in activities which involve the political community, for instance visits to Company 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 As a matter of general principle, the Company will decline any invitation for political comment and, if there is any doubt, all employees should consult Rolls-Royce Government Relations for advice. 2. Where to find out more Government Relations The Rolls-Royce ABC Compliance team 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) Other documents you should read The Rolls-Royce Global Code of Conduct The ABC Policies and guidance documents on the Rolls-Royce Compliance intranet pages Lobbying and Political Support Policy version 1 Page 5 of 6

6 Document control - for internal use only STATUS Final VERSION NUMBER/FINAL Version 1 EFFECTIVE DATE 23 January 2015 NEXT SCHEDULED REVIEW January 2016 SPONSOR OWNER AUTHOR SUPERSEDES VERSION SCOPE Director of Risk Chief Compliance Counsel Chief Compliance Counsel First issue 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. Lobbying and Political Support Policy version 1 Page 6 of 6

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