Keurig Dr Pepper Inc

Advocacy & Public Policy

We recognize that individual company action often needs to be supported by constructive policy solutions. In order to accelerate our collective progress, KDP participates in the public policy-making process in support of a variety of our ESG initiatives. These policy issues include, but are not limited to, restoring resources for a more circular economy, supporting sustainable global agricultural supply chains, reinforcing responsible marketing and labeling and ensuring product quality and food safety.

KDP's advocacy efforts include direct engagement with public officials as well as participation in trade associations, coalitions and stakeholder meetings. Given the diversity of interests of those groups, the positions they take do not always align with our Company's views. However, we understand and appreciate the value of the collaborative process and strive to maintain a strong voice in shaping policy agendas that are critical to our corporate responsibility strategy. We annually publish a report which details our trade association memberships and associated, as well as our and support contributions. We also adhere to all local, state and federal lobbying laws requiring registration and reporting of our direct engagement and associated membership. A link to this information is provided on our website.

In the U.S., the Company administers the Keurig Dr Pepper PAC, a political action committee registered with the Federal Election Commission (FEC). The KDP PAC is funded solely through voluntary contributions from eligible employees and we have not held a fundraising campaign since 2018. All PAC contributions are bipartisan and given to federal and state candidates, where permissible by law, without regard to political party affiliation. Corporate funds are not contributed to the PAC, and the receipts and disbursements of the PAC are reported and available, as required, at the FEC's website.

**POLITICAL ENGAGEMENT – MAKING A POSITIVE IMPACT** Keurig Dr Pepper (KDP) is committed to sourcing, producing and distributing our beverages responsibly, while making a positive impact on our consumers, customers, communities, employees and various other stakeholders. We consider it our duty and responsibility to support this commitment through our efforts to engage in the political process and the development of public policy. Our political activities and contributions comply with all applicable U.S. laws and regulations and related disclosure requirements. We lawfully engage in the political process through: - **Trade Associations: We participate in trade associations for a variety of reasons, including their ability to provide** a unified voice in legislative and regulatory matters and monitor industry policies and trends. - **Political Contributions: We provide political contributions to U.S. federal and state political parties, committees** and candidates, either directly or through our political action committee, both of which are governed by our [Political Contributions Policy.](https://www.keurigdrpepper.com/content/dam/keurig-brand-sites/kdp/files/Political_Contributions_Policy_November_2019.pdf) - **Lobbying: We engage in lobbying efforts to educate policy-makers and participate in public dialogue on important** policy issues. Our political advocacy efforts focus on key issues related to our Company's strategic goals, our products and other issues such as taxation, regulations and labor issues. **GOVERNANCE & OVERSIGHT** Board & Code of Conduct As with any public company, our Board of Directors has ultimate oversight over our political engagement activities. Our Vice President of Government Affairs and our Chief Legal Officer periodically review our policies and practices regarding political activities and political contributions. The Vice President of Government Affairs periodically updates the Board of Directors on the Company's political, lobbying and other grassroots advocacy activities including political contributions. Additionally, our Code of Conduct prohibits: - The use of Company funds, facilities and other assets to support, directly or indirectly, any political candidate without the approval of our Vice President of Government Affairs and our Chief Legal Officer. - Reimbursement to employees, directly or indirectly, of personal political donations. Government Affairs Team Our Government Affairs team, led by our Vice President of Government Affairs, is responsible for managing the Company's political engagement strategy and periodically reviews our legislative priorities and political contributions with our PAC Committee. KDP's Government Affairs team addresses industry, federal, state and local legislative and ballot initiatives, engages in lobbying efforts where appropriate and lawful, and manages our political contributions and membership in trade associations. **POLITICAL ACTION COMMITTEE** The KDP U.S. Political Action Committee (KDP PAC) was established in 2010 to provide our employees with a means to engage in the civic process and to support candidates and ballot initiatives that enable us to succeed as a Company committed to growth, integrity, innovation and value. Except for administrative expenses, our KDP PAC is funded solely through voluntary contributions from eligible employees and members of our Board of Directors who choose to participate in the political process by pooling their resources. To learn more about the factors that guide our KDP PAC's [contributions, please review our Political Contributions Policy.](https://www.keurigdrpepper.com/content/dam/keurig-brand-sites/kdp/files/Political_Contributions_Policy_November_2019.pdf) --NEW-PAGE-- The KDP PAC's Executive Committee has oversight over all political contributions and maintains funds in a segregated account with Treasury oversight. All contributions are administered by an independent third party. Our KDP PAC complies with all applicable laws concerning political contributions, including laws requiring public disclosure of such contributions with the Federal Election Commission (FEC). All contributions made by our KDP PAC are reported in filings with the FEC and are publicly available on the commission's website [http://www.fec.gov.](http://www.fec.gov/) KDP has not solicited any KDP PAC contributions since 2018. **TRADE ASSOCIATIONS** The majority of our public policy advocacy work is done through our membership in the American Beverage Association (ABA), which is the trade association of the non-alcoholic beverage industry in the United States, as well as affiliated statelevel beverage associations. These groups represent the beverage industry in the United States at the national, state and local level on issues that are of critical importance to our business, including our licensed bottlers. Our participation in these trade associations, including membership on a trade association board, does not mean that we agree with every position a trade association takes on an issue. From time to time, our corporate positions may differ from those of the trade associations of which we are members. When we take positions that differ from our trade associations, we engage with the associations to express our views. Every year, we disclose the trade associations to which KDP pays annual dues or membership fees, as well as those associations that received more than $25,000 per year in non-deductible fees for federal lobbying expenditures. We will update this list on an annual basis. Absent approval from KDP, trade associations, such as the ABA or the Consumer Brands Association, may not use company funds for independent campaign expenditures or contributions to any federal, state or local candidate, ballot measure, party committee, non-candidate organization (such as political convention host committee) or organization organized under Section 527 of the Internal Revenue Code. **CORPORATE POLITICAL CONTRIBUTIONS** U.S. law prohibits companies from contributing to candidates for federal office, but many states allow corporate contributions to state and local candidates, committees, political organizations, and ballot-issue campaigns. Our contributions are not based on the personal preferences of individual Company leaders. We base our contribution [decisions on criteria defined in our Political Contributions Policy.](https://www.keurigdrpepper.com/content/dam/keurig-brand-sites/kdp/files/Political_Contributions_Policy_November_2019.pdf) KDP did not make any direct state and local political contributions at the corporate level in 2018, 2019, 2020, 2021 and 2022. **LOBBYING** KDP discloses its U.S. federal, state and local lobbying activity and expenditures as required by law.

Advocacy & Public Policy

KDP believes we have a duty and responsibility to participate in the collaborative public policy-making process and strives to maintain a strong voice in shaping policy agendas that are critical to our continued growth and KDP Impact strategy. These include, but are not limited to, working to restore resources for a more circular economy, supporting sustainable global agricultural supply chains, reinforcing responsible marketing and labeling and ensuring product quality and food safety.

Our advocacy efforts include direct engagement with public officials, participation in trade associations, coalitions and stakeholder meetings. All advocacy activities and contributions comply with applicable U.S. laws and regulations. KDP discloses its U.S. federal, state and local lobbying activity and expenditures as required by law via the Lobbying Disclosure website. We also voluntarily publish a report every year which details our trade association memberships, including those associations that received more than $25,000 per year in non-deductible fees for federal lobbying expenditures. In 2024, we began voluntarily publishing a report which details third parties who are registered to directly advocate on KDP's behalf.

KDP administers the Keurig Dr Pepper Political Action Committee (PAC) which is registered with the Federal Election Commission and funded solely through voluntary contributions from eligible employees. PAC contributions are bipartisan and given to federal and state candidates, without regard to pollical party affiliation. KDP has not solicited any KDP PAC contributions since 2018. The KDP PAC's Executive Committee has oversight over all political contributions and maintains a fund in a segregated account with Treasury oversight. All contributions are administered by an independent third party. KDP does not make direct corporate political contributions to candidates, parties, nor their committees even where permitted by applicable law. More information on the governance of campaign contributions and factors that guide contributions can be found in our Policy on Responsible Public Policy Advocacy in the United States.

###### Advocacy & Public Policy

KDP participates in the public-policy making process within the U.S. at both the state and federal levels of government. We focus a significant portion of our advocacy efforts on public policies that align with and accelerate progress of our Drink Well. Do Good. platform, since we recognize that individual company action often needs to be supported by enabling public-policy interventions. These policies include, but are not limited to, restoring resources for a more circular economy, supporting sustainable global agricultural supply chains, reinforcing responsible marketing and labeling and ensuring product quality and food safety.

Our public-policy activities include direct engagement with public officials as well as participation in trade associations, coalitions and stakeholder convenings. While our positions may not always align with those entities, we strive to maintain a strong and credible voice in shaping the views and policy agendas of these groups. Information pertaining to our direct engagement and associated expenditures are reported to the U.S. Congress in accordance with the Lobbying Disclosure Act of 1995. We adhere to all local, state and federal lobbying laws requiring registration and reporting, and a link to this [information is provided on our website.](https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance)

In the U.S., the Company administers the Keurig Dr Pepper PAC, a political action committee registered with the Federal Election Commission (FEC). The KDP PAC is funded solely through voluntary contributions from eligible employees and we have not held a fundraising campaign since 2018. All PAC contributions are bipartisan and given to federal and state candidates, where permissible by law, without regard to political party affiliation. Corporate funds are not contributed to the PAC and its receipts and disbursements are reported and available, as required, at [the FEC's website.](https://www.fec.gov/)

**Responsible Public Policy Advocacy in the United States Policy – Making A Positive Impact**

**Updated: March 26, 2024**

Keurig Dr Pepper Inc. (KDP) participates in public policy advocacy in the United States to help ensure our
interests are appropriately represented. Well-crafted public policy is an enabler that helps support KDP
to meet commitments to our various stakeholders. This is particularly true with respect to our Drink Well.
_Do Good. purpose statement where public policy plays a critical role in helping us achieve our corporate_
responsibility commitments under our four strategic pillars: (1) Environment; (2) Supply Chain; (3) Health
& Well-Being; and (4) People & Communities.

We maintain a thorough oversight process to help ensure that our advocacy activities and political
contributions through the KDP Political Action Committee (PAC) are transparent and made in accordance
with all applicable disclosure and campaign finance laws as well as company policy.

**I.** **Governance and Oversight**

KDP Board of Directors

The KDP Board of Directors has oversight responsibility over our public policy advocacy, including our
lobbying, KDP Political Action Committee activities, and payments to trade associations and other taxexempt organizations that may be used for political purposes. Our Vice President of Government Affairs
reports to the Board on these matters on a periodic basis.

Government Affairs Team

Our Government Affairs team is led by our Vice President of Government Affairs who reports directly to
our Chief Corporate Affairs Officer, a member of KDP's Executive Leadership Team. Our Vice President of
Government Affairs is responsible for managing KDP's public policy engagement strategy and regularly
reviews our legislative priorities and political contributions with KDP's Executive Leadership Team. KDP's
Government Affairs team addresses industry, federal, state and local legislative and ballot initiatives,
engages in lobbying efforts where appropriate, and manages the KDP Political Action Committee and
memberships in trade associations.

**II.** **Advocacy Focus and Lobbying Activities**

We engage in advocacy activities aimed at educating policymakers and contributing to the public
discourse on important public policy matters that promote sustainable growth.

Our public policy advocacy efforts focus on key issues related to our company's strategic goals, including
efforts that align with KDP's Corporate Responsibility Strategy and help enable us to meet our Corporate
Responsibility Commitments.

We disclose our U.S. federal, state and local lobbying activity and expenditures as required by law. We file
federal lobbying reports quarterly with the Office of the Clerk of the U.S. House of Representatives and
the Secretary of the U.S. Senate. We file state lobbying disclosures when required with the relevant
governing state agencies.

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**[Lobbying Disclosures](https://lda.senate.gov/system/public/)**

KDP consultants who support the company's advocacy efforts may also be required to file lobbying reports
regarding their activities on behalf of KDP pursuant to the Lobbying Disclosure Act or applicable state law.
KDP publicly discloses its third-party lobbying consultants on an annual basis.

**[Registered Third Party Lobbyists](https://www.keurigdrpepper.com/wp-content/uploads/2024/04/Registered-Lobbyists-2023.pdf)**

**III.** **Trade Association Engagement and Alignment**

We are members of several industry trade associations that may engage in public policy activities on
behalf of an industry sector. A significant amount of our public policy advocacy is done through our
memberships in the American Beverage Association (ABA) and the Consumer Brands Association (CBA),
as well as state level beverage associations. These groups represent the beverage and consumer product
goods industries in the United States at the national, state and local levels on issues that are of critical
importance to the industry sector.

Our participation in trade associations, including membership on a trade association board, does not
mean we agree with every position a trade association takes on an issue. From time to time, our corporate
positions may differ from those of the trade associations of which we are members. When we take
positions that differ from our trade associations, we engage with the associations to express our views.

Our Vice President of Government Affairs, Chief Corporate Affairs Officer, and General Counsel review
KDP's engagement and continued alignment with trade associations and their issue specific policies
annually.

We disclose annually the trade associations to which KDP pays annual dues or membership fees.

**[Trade Associations](https://www.keurigdrpepper.com/wp-content/uploads/2024/04/Industry-Associations-Dues-and-Support-2023.pdf)**

Absent approval from KDP, trade associations may not use company funds for independent campaign
expenditures or contributions to any ballot measure campaign.

**IV.** **Corporate Political Contributions & Code of Conduct**

KDP does not make direct corporate political contributions to candidates, parties, nor their committees
even where permitted by applicable law. In addition, KDP does not make direct independent expenditures
on behalf of candidates running for local, state, or federal office.

Additionally, our Code of Conduct prohibits:

- The use of company funds, facilities and other assets to support, directly or indirectly, any political
candidate without the approval of our Vice President of Government Affairs, Chief Corporate Affairs
Officer, and our Chief Legal Officer.

- Reimbursement to employees, directly or indirectly, of personal political donations.

**V.** **KDP Political Action Committee**

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We believe that providing financial support to responsible candidates enables us to succeed as a company
committed to growth, integrity and innovation. The KDP PAC) provides our employees with a voluntary
means to participate in the democratic process and to support U.S. candidates in a bi-partisan manner
based on factors outlined in our Political Contributions Criteria.

Except for administrative expenses, the KDP Political Action Committee is funded solely through voluntary
contributions from eligible employees. Coercion of any employee to contribute to the KDP PAC or to make
any political contribution of any kind is unacceptable. Our employees have the right to be engaged in the
political process in their individual capacity as they see fit and make political contributions of their own
time and money to the candidates or parties of their choice. All contributions promote the interests of
the company and are made without regard for the private political preferences of KDP executives.

Our KDP PAC complies with all applicable laws concerning political contributions, including laws requiring
public disclosure of such contributions with the Federal Election Commission (FEC). All contributions made
by our KDP PAC are reported in filings with the FEC and are publicly available on the commission's website
[http://www.fec.gov.](http://www.fec.gov/)

All payments from the KDP PAC to support U.S. or state political parties, committees or candidates must
be approved by the KDP PAC Executive Committee. KDP PAC funds are kept in a segregated account with
Treasury oversight and the KDP Board of Directors reviews its operations on a periodic basis.

All contributions from the KDP Political Action Committee to U.S. candidates for political office are guided
by the following criteria:

- The Candidate's position on legislation or policy issues that affect KDP business activity.

- The Candidate's district or state represents an area where KDP has operational facilities or
employees.

- The Candidate's service on key committee assignments or caucuses that deal with legislation or
policy issues important to KDP operations and sustainable growth.

- The Candidate's current leadership role or potential leadership assignment to city, county or state
legislatures or the U.S. Congress.

- The Candidate's position on policies that align with our Corporate Responsibility commitments.

**VI.** **Other Political, and Social Welfare Organizations**

If KDP makes contributions to organizations that are organized under IRS Code §501(c)(4) or IRS Code
§527, the contributions will be disclosed on an annual basis. KDP did not make contributions to these
types of organizations in 2023.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Keurig Dr Pepper's climate policy combines three primary approaches—namely, mitigation, adaptation and engagement. These approaches and associated commitments support the United Nations' related Sustainable Development Goals (SDGs) for Affordable and Clean Energy and Climate Action: SDGs 7 and 13. These SDGs call for "affordable, reliable, sustainable and modern energy for all,† and "urgent action to combat climate change and its impacts,† respectively.

Engagement. Working collaboratively with others is the only way to have significant and lasting impact on climate change. We commit to:

Engaging with governments to support healthy economies, encourage significant reductions in GHG emissions, and improve resilience and support adaptation

Collaborating directly with other companies in the food and beverage sector and via multi-stakeholder platforms and collaborations to align efforts to maximize our collective positive impact and scale climate change mitigation and adaptation practices

Collaborating with NGOs, leveraging their expertise and providing them with the resources they need to do their work
Communicating openly with stakeholders about progress and challenges

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Keurig Dr Pepper's climate policy combines three primary approaches—namely, mitigation, adaptation and engagement. These approaches and associated commitments support the United Nations' related Sustainable Development Goals (SDGs) for Affordable and Clean Energy and Climate Action: SDGs 7 and 13. These SDGs call for "affordable, reliable, sustainable and modern energy for all," and "urgent action to combat climate change and its impacts," respectively.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes