Political Contributions and Activities

a.  Political Contributions. Use of Company funds for political contributions anywhere in the world requires approval in writing from the appropriate operating executive, the General Counsel and the Vice President, Government Relations.

b.  Political Activities. The Company encourages employees to be active participants in public affairs during non-work time, and to support the party and candidates of their choice, provided that the laws on corporate contributions are followed and the activities do not interfere with the employee’s ability to perform his or her Company responsibilities.

c.  Political Action Committee. The Company has established, in compliance with U.S. law, the General Mills Political Action Committee (GMPAC), which uses employee contributions to make political contributions to U.S. federal and state political parties, committees and candidates. Participation in the GMPAC by employees is strictly voluntary. The Company pays the costs of administering the GMPAC.

d.  Managers or supervisors must obtain formal approval from the General Counsel and the Vice President, Government Relations if there is any question as to the propriety or legality of an employee's political contributions or actions.

e.  The Company’s Public Responsibility Committee reviews a report of political contributions made with Company funds on an annual basis. The Public Responsibility Committee also periodically reviews the Company’s policy on political contributions.