Guidance for political engagement
Last updated 7/07/2020
Why it matters
Tesco is a politically neutral business. We do not have any political party affiliations and we do not make political donations. As our Code of Business Conduct states, as part of doing business we engage with governments, regulators, public interest groups, industry associations and other bodies around the world. We do this to inform them of our position on issues that affect our customers and our colleagues.
We provide this information either directly to stakeholders or through our memberships of trade or policy focused organisations. These memberships help to increase our understanding of issues and enable us to engage constructively in relevant policy and regulatory debates at an industry level.
We always ensure that we comply with all laws governing political engagement in each of the markets we operate in. Any political engagement should be undertaken within an agreed framework within each market, with input from the Group Government Relations team. Colleagues should only engage with a government on Tesco business with approval from the in-market Government Relations or Communications Director.
Purpose of guidance
This guidance expands upon the principles on Engaging in Political Activity that are communicated to all colleagues in our Code of Business Conduct. It aims to:
- Inform key colleagues across the Group of the principles that guide any political engagement on behalf of Tesco.
- Equip colleagues across the Group - and so guide and inform local decision-making - on issues relating to political engagement and activity which may be over and above any local laws that regulate political activity.
This guidance applies to colleagues employed by companies that are either majority-owned by Tesco or operated by Tesco management. This includes, but is not limited to the following groups and teams:
- Government Relations
- Corporate Affairs
- Group Communications
- Legal Directors
- Country Leadership Teams
- Store Directors / Managers
- Consultants, contractors and agency staff in relation to their work for, or on behalf of Tesco
Each country business can use their own discretion around political engagement on individual issues. However, in addition to respecting local laws, there are three principles which all businesses in the Tesco should adhere to:
- Neutrality: We are politically neutral and do not have any political party affiliations.
- Transparency: We are transparent in our political activity and do not attempt to improperly influence any government official or policy maker to gain a business advantage for the Tesco Group. At all times every individual involved in political engagement should be comfortable that, if their behaviour were made public, it would not cause concern.
- Customer focus: We engage policy makers on behalf of our customers, and we do not engage in any political activity which may undermine our customer experience; colleagues and customers come first.
Political visits and activities in stores & distribution centres
Tesco plays an important role in local communities and politicians often want to visit our stores and distribution centres. We encourage this type of engagement and have set out the following guidance to support colleagues involved in such visits.
a) Outside of an official election or referendum campaign period:
- We allow locally elected politicians, members of the government and senior opposition “shadow” ministers with the relevant policy brief to visit a stores or distribution centre in an official capacity. This could include local elected representatives hosting their surgeries in store, and more information on how colleagues should approach these requests is set out in the annex below.
- We do not allow politicians from extremist parties or single-issue parties to visit our stores in an official capacity.
- We do not allow candidates (people standing for office but not yet elected) to come into our stores, either to visit or to hold surgeries, as they are not elected and so have no mandate.
To ensure we put our colleagues and customers first, any visit is at the local store manager’s discretion. Colleagues should inform the Government Relations team if they are hosting a politician, and if they are uncertain as to whether a politician is from an extremist party or not.
b) During official election periods or referendum campaigns Tesco adopts a different approach to protect the business’s politically neutral, transparent and customer focus principles. Because we are politically neutral, and our colleagues and customers come first, we only allow campaigning to take place outside of the store. We do not allow any campaigning inside the store and ensure a consistent approach is applied which:
- protects our political neutrality;
- protects the business against potential reputational risk; and
- gives a clear message that we respect each individuals’ political views.
It is important that campaigners must:
- not be accompanied by more than two people
- not be from extremist or single-issue parties
- not put undue pressure on our customers or colleagues
If campaigners are disruptive colleagues can ask them politely to leave.
It is important to note that stopping campaigning altogether would be impossible as many of our stores open onto public land.
- Elections: any vote for political office at either local, national, supranational (e.g. EU election) level where the public in that area of the country is able to vote. This includes national or local referenda.
- Election period: often defined at the country level but generally considered to be the immediate pre- election period, e.g. six weeks before the vote in the UK.
- Campaigning: Handing out leaflets or talking to customers about political issues so politicians can get elected or the public makes a particular referenda choice.
Colleagues must always operate within legal parameters. Any relevant local laws regulating lobbying, the UK’s Bribery Act (and equivalent legislation) and other regulations must be followed. In addition, some markets have voluntary codes and registers covering lobbying, and activity must adhere to these where appropriate.
It is a decision for the local market whether to sign up to voluntary initiatives but colleagues should keep transparency front of mind; we are a signatory to the EU’s voluntary lobbying register on this basis. Colleagues should inform their local Communications and Legal teams if they choose to sign a register.
We are politically neutral and should not sell products or provide services that endorse political parties, nor take paid advertising revenue from them for any activity. Take particular care with the giving of gifts and entertainment to any public officials. Our Group Gift & Entertainment policy provides further guidance.
We are politically neutral: we do not make donations to political parties, nor do we receive donations or services from political parties.
Any requests for political donations, including the sponsorship of events organised by politicians or political parties, must be passed to your local Government Relations or Legal teams for resolution.
International visits by politicians and officials
Tesco is sometimes asked to co-operate with and support visits by politicians and officials to our other markets. The local market should consult the Group Government Relations team to ensure that anything we agree to is in accordance with the relevant laws, and our Group-wide principles, which are:
- We are always happy to provide support for visa applications or store visits/meetings with trade bodies in our markets.
- Depending on the nature of the visit, it may be appropriate to contribute towards some of the travel and accommodation costs of the visit but this must be done in accordance with the Group Gift & Entertainment policy.
- Outside of any formal meetings during the visit, any entertainment or gift expenditure must be given and recorded in accordance with the Group Gift & Entertainment policy.
If you are in any doubt, please consult the Group Government Relations team.
Appointing external advisors from a government relations perspective
Appointing external advisors can help increase our understanding of market conditions and the policy environment in which we operate. This can enable us to engage constructively in policy and regulatory debates relevant to our business. A decision whether to appoint external advisors is a matter for the in-market team, and there is a standard recruitment and approval process covering their selection, vetting and appointment which should be followed. Any recruitment of an external advisor must adhere to local laws and regulations.
Membership of third party organisations
Like most businesses, we are members of different trade associations and third-party organisations. It is for each market to decide which organisation it wishes to be a member of. In general, we believe these groups provide a key role in helping to formulate effective public policy that champions consumer and sectoral interests.
If you feel our views are not adequately represented by an organisation of which Tesco is a member, or you identify a conflict of interest, it is for the local market to decide whether to reconsider the relationship with the third- party organisation.
Any engagement with associations must be undertaken in compliance with competition law. If you are in any doubt, please consult the Group Legal department.
Engaging in political activity
Colleagues are allowed to undertake political activity in their own time and must always be clear that they are acting on their own behalf and not for Tesco. Further guidance is set out in the Code of Business Conduct.
This policy is supported by the following Group policies:
- Code of Business Conduct
- Group Anti-Bribery policy
- Group Conflicts of Interest policy
- Group Charitable Donations policy
- Group Gift & Entertainment policy
- Group Competition Law guidance: Meetings with competitors
Who to contact
For further information on the Group Guidance for Political Engagement please contact firstname.lastname@example.org.