Political Activity Disclosure

Conagra Brands believes political participation at all levels of government is important to our business and our country and as such encourages voluntary participation by its employees in public policy debates impacting the food manufacturing sector. Conagra Brands' government affairs initiatives are narrowly focused on educating governmental officials and the public on a range of public policy issues that are important to Conagra Brands' businesses. These initiatives are not based on personal agendas of individual directors, officers, or employees, but rather to advance matters that we believe will create or preserve shareholder value. These educational efforts are supplemented by voluntary giving by individual employees to the Conagra Brands Good Government Fund (the "Conagra Brands Employee PAC"); by membership in trade associations; and by encouraging grassroots support by employees and others for issues that affect Conagra Brands' business objectives. Apart from membership in trade associations (some of which may engage in political activity), individual business units and functions are not authorized to make political donations. Political spending must be coordinated with the Government Affairs team and approved, in advance, by the Vice President of Government Affairs.

Conagra Brands provides annual reports on its corporate political activities and reviews initiatives with the Nominating, Governance and Public Affairs Committee of the Board of Directors.

All financial contributions adhere to federal, state and local laws regarding contribution limits on amount and source, criteria and reporting requirements. Contributions may not be made in anticipation of, in recognition of, or in return for an official act by the recipient of the contribution.

Company Political Activities

U.S. Federal Contributions: Conagra Brands does not contribute corporate funds to federal candidates or federal political committees. However, U.S. government lawmakers and state lawmakers routinely make decisions that affect Conagra Brands. Because of that impact, Conagra Brands has established the Conagra Brands Employee PAC, to support candidates for public office who understand Conagra Brands' business objectives.

Conagra Brands Good Government Association (the Conagra Brands Employee PAC): Conagra Brands supports candidates (primarily U.S. House and Senate) for office via the Conagra Brands Employee PAC. Conagra Brands offers eligible employees an opportunity to coordinate and maximize the effect of their political efforts by voluntarily contributing to the Conagra Brands Employee PAC, in accordance with Federal Election Commission (the "FEC") regulations. Participation by employees is entirely a matter of personal choice.

The Conagra Brands Employee PAC offers employees, regardless of their political affiliations, a legal and ethical way to speak with a unified voice on issues important to our Company. The Conagra Brands Employee PAC typically raises and distributes less than $100,000 annually.

The Conagra Brands Employee PAC is non-partisan. It contributes to candidates, regardless of political party, who are supportive of Conagra Brands' corporate business interests and public policy goals. The bylaws of theConagra Brands Employee PAC provide basic organizational material and incorporate FEC regulations. In addition to its bylaws, the Conagra Brands Employee PAC adheres to the following principles:

  1. participation or non-participation by eligible employees is always voluntary;
  2. the Conagra Brands Employee PAC does not seek, request, or expect any specific benefit for its contributions to candidates or for any official act;
  3. the Conagra Brands Employee PAC reports its contributions to elected officials and candidates as required by law, and to the Conagra Brands Employee PAC contributors periodically; and
  4. Conagra Brands Employee PAC contributions are intended primarily for individuals seeking federal elective office.

In deciding the timing and amount of contributions, the Conagra Brands Employee PAC considers:

  1. the candidate's views and record on issues critical to Conagra Brands' success;
  2. the presence of Conagra Brands' facilities in the candidate's district;
  3. the committees on which the legislator serves (in the case of incumbents); and
  4. the strength of the candidate and the impact a contribution might have on the race.

Conagra Brands fully discloses Conagra Brands Employee PAC activity through reports filed with the FEC. These reports are publicly available on the FEC: www.fec.gov

Conagra Brands does not contribute corporate funds to external political action committees.

Independent Expenditures: The U.S. Supreme Court determined in 2010 that corporations may make unlimited expenditures for independent communications to the general public that expressly advocate the election or defeat of a clearly identified federal candidate. Even though permitted by law, Conagra Brands has chosen not to engage in such activity.

State and Local Contributions: Where permitted by law, Conagra Brands may contribute directly to state and local candidates, state party committees and other political entities. Any contribution in this regard is approved in advance by the Vice President of Government Affairs. In 2015, Conagra Brands spent $22,000 in corporate funds on state and local political activity. Such contributions are made predominantly in the State of Nebraska and those contributions may be found at: http://nadc.nol.org. Set forth below is a summary of individual state and local contribution expenditure incurred by Conagra Brands in excess of $1,000 in 2015.

Douglas County GOP

   $1,000

Douglas County Democrats

   $1,000

Jean Stothert (Omaha mayor)

   $5,000

Governor Ricketts Inaugural Cmte

 $10,000

NE Chamber PAC

   $5,000

   

No corporate funds were spent on state ballot initiatives in 2015.

Lobbying Disclosure: Conagra Brands interfaces with federal politicians and their staffs, federal agencies, and state politicians as needed on matters of importance to Conagra Brands. Conagra Brands is required to submit lobbying reports with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives detailing our U.S. federal lobbying activities and expenditures. These reports are available at: http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm

Section 527 Activity: Conagra Brands does not make corporate contributions to groups organized under Section 527 of the Internal Revenue Code, except in rare instances to the organizational committees of the Democratic and Republican national party conventions and the annual Democratic and Republican Governor's conferences. These limited corporate political contributions are pre- approved by theVice President of Government Affairs. No such expenditures were incurred by Conagra Brands in 2015.

Trade Associations: Conagra Brands is a member of a number of trade associations to keep abreast of business and technical issues and emerging standards within our industries, and to be part of advancing important public education efforts regarding issues of concern to our industry. Our participation in trade associations is subject to management oversight and membership requires management approval.

The following is a list of trade associations to which Conagra Brands paid dues over $30,000 in 2015 and the amount used for political activities (as reported to us by the trade association).

  • American Frozen Food Institute 2015 dues $104,000 (political activity $10,400)
  • Greater Omaha Chamber of Commerce 2015 dues $37,460 (political activity $2,996)
  • Grocery Manufacturers Association 2015 dues $705,640 (political activity $184,172)
  • International Foodservice Manufacturers Assn 2015 dues $62,941 (zero political spend)
  • National Association of Manufacturers 2015 dues $40,000 (political activity $10,800)
  • National Pasta Association 2015 dues $60,000 (zero political spend)
  • The Food Group 2015 dues $36,000 (political activity $15,625)

**This information is current as of September 2016 and will be updated semiannually.**