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Corporate Governance

Political Contributions and Lobbying Expenditures

Raytheon participates in the U.S. political process to ensure that the Company's interests as a leading member of the aerospace and defense industry, and as a large employer, are appropriately represented. The Company maintains a detailed oversight process to make certain that political contributions and lobbying expenditures are made in a legal, ethical, and transparent manner.

Raytheon Political Action Committee

The Company offers eligible employees an opportunity to make voluntary political contributions through the Raytheon Political Action Committee (RAYPAC), which supports candidates for federal office. RAYPAC is governed in accordance with Company policy by a Steering Committee comprised of senior management from each of the Company's business units as well as representatives from its government relations and legal functions.

RAYPAC is registered with the Federal Election Commission (FEC), and its activities are reported on a monthly basis. Contribution information may be found on the FEC website, www.fec.gov.

Raytheon also sponsors two state political action committees (PACs) to which eligible employees residing in those states may make voluntary contributions in connection with the local political process. These PACs operate under, and comply with, the statutes and regulations in effect in the state in which they operate. Contribution information can be found at the following state agency websites: Arizona Secretary of State and the California Secretary of State.

Direct Corporate Political Contributions

On a limited basis, the Company makes direct corporate political contributions to state and local candidates as well as organizations operated in accordance with Internal Revenue Code (IRC) Section 527. All of these activities are governed by a Company-wide policy. A fundamental principle underpinning this policy is Raytheon's commitment to the highest standards of ethical conduct. In accordance with Company policy, no contribution can be made from Company funds to any candidate, political committee or political party without the approval of Raytheon's Political Expenditure Review Committee (PERC). In 2014 the PERC authorized one direct contribution to an individual candidate at the state and local level. There were no corporate contributions during 2014 to Section 527 organizations.

2014 Corporate Contributions Summary

Section 527 Contributions

$ 0

State & Local Contributions

$ 6,000

Total 2014 Corporate Contributions

$ 6,000

Lobbying Expenditures

Raytheon responsibly and lawfully engages in the legislative process to communicate its views on legislative and regulatory matters affecting the Company's business and its various constituencies. Federal lobbying activities are regulated by the Lobbying Disclosure Act (LDA). In full compliance with the LDA, the Company's lobbying activities and expenses, as defined by Section 162 (e) of the Internal Revenue Code, are disclosed to the U.S. Congress on a quarterly basis. In addition, the Company files semi-annual reports detailing certain Federal Election Commission Act (FECA) contributions, honorary contributions, presidential library contributions, and payments for event costs. These reports are publicly accessible at the U. S. House of Representatives Office of the Clerk website. The Company also files periodic reports with state and local agencies reflecting lobbying activities as required by relevant state and local laws. For the jurisdictions that provide online availability, the Company's filed reports, as of January 31, 2015, can be found at the following linked websites:

Raytheon has in place sound procedures to assure the accuracy, timeliness, and oversight of its federal and state filings.

Board Oversight

The Board of Directors, through its Public Affairs Committee which is composed entirely of independent directors, periodically receives reports on political and lobbying activities.

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