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Group Charitable Donations Policy

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Group Charitable Donations Policy Group Charitable Donations Policy 1. Purpose – why it matters Charitable donations – whether in the form of money or donations in-kind such as time, products or services – are an important part of our commitment to social responsibility and our third Value: every little help makes a big difference. However, donations may cause reputational harm to Tesco if they are made to inappropriate causes. In extreme cases, a charitable donation that is made in order to obtain a benefit for Tesco will be considered a bribe. 2. Scope This policy applies to: All business units that are either majority-owned by Tesco or operated by Tesco management. For the purposes of this policy, business units includes all retail businesses, along with Tesco Mobile (Ireland), Tesco Bank, Tesco International Sourcing Limited, Tesco Pension Investment, Tesco Business Services (Bengaluru) and dunnHumby; charitable foundations or trusts that are run by, or on behalf of, Tesco; Third parties, including contractors and suppliers, who make charitable donations on behalf of Tesco. 50% owned joint ventures are expected to put in place policies consistent with this policy, 3. Policy The following policy rules apply in relation to charitable donations: 3.1 Only make charitable donations with the appropriate authority: Section 6 of this policy sets out the delegation of authority (DOA) schedule for making charitable donations. The DOA schedule must be followed at all times. 3.2 No bribery: Charitable donations must never be made with the expectation of receiving any improper benefit for Tesco. Donations to charities associated with public officials and their families represent a significant risk for bribery. Appropriate reputational due diligence (e.g. using existing anti-bribery due diligence tools) must be conducted before such donations are made. 3.3 Cause-related marketing (i.e. the donation to charity of a percentage of a product’s retail price or profit) (CRM): CRM agreements may give rise to certain tax implications. A written contract must always be in place to support any CRM activity. 3.4 Charitable social events organised by Tesco: The Group Gift & Entertainment Policy provides guidance for colleagues who are organising charitable events. In particular, it is important to ensure that suppliers are not pressured into purchasing tickets for a charity event. 3.5 No use of expenses to process charitable donations. Cash donations to charity may not be made by a colleague on behalf of Tesco and reclaimed as personal expenses. Donations may only be processed through a business unit’s finance systems, using an appropriate account code. In exceptional cases, a company cheque may also be used to process a one-off donation. 4. Commercial sponsorship agreements Commercial sponsorship agreements, for example of a sporting team or cultural event, which are negotiated on commercial terms and which are principally intended to promote the Tesco brand via association with that team or event, are not deemed to be charitable donations by Tesco for the purposes of this policy. However, the DOA for sponsorship agreements, which is set out at Section 6 below, must be followed at all times. 2 5. Colleague fundraising for charities that are not officially supported by Tesco 5.1 Colleague fundraising for charities that are not formally supported by Tesco falls outside the scope of this policy. 5.2 However, should a colleague/colleagues wish to fundraise for a charity not officially supported by Tesco during their work hours, this must be explicitly pre-approved by the Head of CSR. 5.3 Where Tesco, or a Tesco-operated charitable trust, “tops up” the amount raised by colleagues, then the DOA for colleague fundraising, which is set out at Section 6 below, must be followed at all times. Colleague fundraising must never be for charities that may cause reputational harm to Tesco. 6. Delegation of authority and reporting to business unit Risk & Compliance Committee 6.1 The delegation of authority in relation to charitable donations and commercial sponsorship agreements is as follows: Decision Authority required Due diligence required 1 Selection of national charity Global: Executive Committee Reputational (e.g. partners (including e.g. Business unit: SLT and Group Exiger) Financial Charity of the Year) Communications Director 2 Donations by Tesco* up to Tesco Ireland Head of CSR - €500 to charities other than national charity partners 3 Donations by Tesco* >€500 to Tesco Ireland Corporate Affairs Reputational charities other than national Director charity partners 4 Donations by Tesco* >€5,000 Tesco Ireland CEO Reputational to charities other than national charity partners 5 Donations by Tesco* >€10,000 Tesco Ireland Leadership Team Reputational to charities other than national charity partners 6 Donations to charities closely Reputational Tesco Ireland Corporate Affairs associated with politically Director exposed persons or their families 7 Donations resulting from cause Tesco Ireland Commercial Reputational related marketing (CRM) Director and/or Marketing agreements Director 8 Commercial sponsorship Tesco Ireland Leadership Team Reputational agreements >€1,000 9 Top-up donations by Tesco* Tesco Ireland Corporate Affairs Reputational >€500 in support of colleague Director fundraising * including by Tesco charitable foundations or trust and third parties on Tesco’s behalf. 3 6.2 The business unit Head of CSR will maintain a log of all charitable donations or sponsorship agreements covered by the DOA table in section 6.1 above, with the exception of donations by Tesco up to €500 to charities other than national charity partners. 6.3 The business unit Risk & Compliance Committee will review the log of charitable donations and sponsorship agreements twice each year. 6.4 Business units are required to provide colleague training and awareness about this policy as appropriate. 7. Reporting breaches You have a duty to speak up if you believe the policy has been breached. Speak to your line manager in the first instance. If this is not possible, speak to your local Legal or Security contact, a member of your business unit leadership team or email [email protected] to report your concerns. Failure to comply with this policy may result in disciplinary action being taken against any colleagues concerned or the termination of contracts with third parties working for Tesco. 8. Related Documents This policy is supported by the following other Group policies: Anti-Bribery Policy; Gift & Entertainment Policy; Political Donations Policy. 9. Contact For further information, contact: [email protected] Ownership & Version control Policy owner: Jane Lawrie, Group Communications Director Governance approval: Group Risk & Compliance Committee Version: 1.8 Date approved: December 14, 2017 Date of last review: December 14, 2017 Next review by: December 14, 2019 Tesco Ireland review: Lorraine Shiels, Head of CSR, 25.07.2018 4 .
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