U.S. Political Contributions and Advocacy
ADM unlocks the power of nature to enrich the quality of life.
Our ability to fulfill this vital purpose is enhanced when government policies impacting our operations promote growth — growth that facilitates job creation; encourages ongoing investment in our business, our employees and the communities where we live and work; and returns value to our stockholders.
ADM believes that participation in the political process is an important element of our business, one undertaken for the benefit of all company stakeholders. We therefore support candidates for political office and organizations that share our pro-growth vision and support our work to offer sustainable, innovative solutions to meet the world’s most fundamental needs for food, drink and more.
In particular, we support candidates and organizations that share our views regarding: continued investment in America’s infrastructure, including our inland waterways, ports and highways; reducing barriers to trade to ensure the flow of nutrition around the globe; growth-oriented regulatory and tax policies; the importance of biofuels to help reduce the carbon intensity of our transportation; and the importance of food and agriculture in creating a sustainable future.
ADM supports individual state candidate campaigns, state political parties and select state and national political associations. ADMPAC, a political action committee funded by our employees’ voluntary contributions, contributes to federal candidates, state candidates, and various federal and state campaigns (for bylaws governing ADMPAC’s activities, please click here). In addition to individual candidates for public office and candidate committees, ADM does not generally contribute to 527 organizations, but will disclose any such contributions. We do not support independent political expenditures or 501(c)4 organizations.
ADM participates in supporting political candidates, always in strict compliance with all applicable regulatory and disclosure requirements. ADM expanded the scope and detail of public reporting of our political contributions, including those contributions which may not be subject to reporting requirements under applicable state or Federal law.
The ADMPAC board, which is composed of representatives of ADM’s businesses and functions, alone approves contributions to candidates and campaign committees by ADMPAC and the corporation in excess of $1,000. The company’s vice president of Government Relations and vice president of State Government Relations authorize corporate expenditures of less than $1,000. Decisions to support particular candidates and/or organizations are determined by the company’s best interests, not the personal political preferences of ADM executives, and we expect all lawmakers that we support to uphold our values, our integrity and commitment to the democratic process.
ADM’s 2021 corporate contributions through September 30, 2021 totaled $81,785. ADMPAC's contributions to federal candidates, state candidates, and various federal and state campaign committees through September 30, 2021 totaled $32,000. ADM announced in January 2021 that it was temporarily suspending ADM PAC contributions. Those donations resumed in July after a thorough review and changes to the ADM PAC bylawswhich states that contribution decisions will be based on a number of factors, including, but not limited to, the character and integrity of a candidate, and the candidate’s commitment to our Constitution, republic and democratic system. Itemized contributions are available in the links below for each year.
Reporting and Disclosure
ADM management reports on our company’s political contributions, compliance and strategy to the Board of Directors on a quarterly basis. The Board’s Nominating/Corporate Governance Committee, composed solely of outside directors, reviews and approves these contribution reports at each of its meetings to ensure we are in compliance with our political contributions policy. We submit quarterly reports to Congress detailing our federal lobbying, as required by the Lobbying Disclosure Act.
In addition, ADMPAC is required to submit to the Federal Election Commission regular, detailed reports of all distributions and contributions. These reports are available to the public online. ADM’s political activities and contributions are also subject to state-level regulations. States that allow corporate contributions to candidates or political parties require that the identity of the donors and the dollar amounts of political contributions be disclosed. This information is widely available on individual states’ websites.
ADM has memberships in several industry, trade and business associations representing agriculture, manufacturing and the business community.
This allows us to work with many organizations on a variety of topics and advocate on behalf of our shareholders, our business, our suppliers, our customers, our employees and our communities.
While we may not always agree with all of the positions taken by an association or its members, corporate memberships enable us to learn the views of others, obtain feedback, and ultimately, voice our concerns, perspectives and positions on proposed legislation and regulations in a more educated and thoughtful manner.
Some of our trade associations themselves engage in political advocacy. The amount of dues associated with this political advocacy is reported in ADM’s Quarterly LD2 filings.
ADM voluntarily discloses those Trade Associations that received more than $50,000 in non-deductible fees for federal lobbying expenditures in 2020 and will update this list on an annual basis.
- National Biodiesel Board: $407,263
- Growth Energy: $240,071
- Corn Refiners Association: $190,210
- Fuels America: $80,000
- National Association of Manufacturers: $68,000
- National Oilseed Processors Association: $53,093
On rare occasions, when ADM’s interests are directly affected, ADM supports efforts to influence the outcome of ballot initiatives at the state and local level. In 2021, ADM did not support any such initiatives.
Political Expenditures and Contributions
As a registered entity that employs lobbyists, ADM files six reports each year with the Clerk of the U.S. House of Representatives and the Secretary of the U.S. Senate. ADM’s LD-2 reports disclose expenses related to lobbying activities. ADM’s LD-203 discloses contributions made to Members of Congress.
Political Activity by ADM Employees
Some ADM employees choose to support the well-being of their communities by participating in the political activities of their choice. However, they may only participate in such activities on their own time and at their own expense. They may not use ADM property or resources for personal political activities. In addition, they are prohibited from engaging in any political activities on ADM’s behalf, unless authorized to do so. Employees may not attempt to coerce coworkers, especially those who report to them, to support their personal political causes or candidates.
Policy on Political Expenditures from Company Funds
As noted above, ADM engages in a centralized, deliberative process when making decisions about the company's political participation to ensure that all applicable laws are followed, and all appropriate disclosures are made. ADM’s Code of Conduct states:
ADM will only engage in the political process when allowed by law. Our company will only contribute to political candidates or campaigns with the prior written approval of our CEO or the Government Relations department. “Contribute” is a broad term and may include money, property, services and so forth.
Lobbying activities are highly regulated. We therefore may not make any contacts with government officials in an attempt to influence legislation, regulation, policy or other governmental actions on ADM’s behalf. The only exception to this rule is when you have specific permission from our CEO or the Government Relations department. Additionally, lobbying activity may require certain reporting requirements.