Political Disclosure and Accountability

Management Approach

WestRock believes that it is a fundamental right and obligation of all citizens to engage in responsible dialogue about the laws, regulations and government policies that affect them. We strongly believe that active engagement in the political and regulatory processes is an important means of protecting our commercial, employee and stakeholder interests. Therefore, in the course of doing business around the world, we regularly interact with public officials.  

All forms of political engagement undertaken by or on behalf of WestRock, including, without limitation, lobbying, trade association participation and political contributions, must comply with all U.S. and international laws, this policy and our Code of Conduct.

Global Activities

WestRock is a global company with operations throughout North America, South America, Europe, and Asia Pacific. We work cooperatively with local, regional and national governments in the countries where we operate. From time to time, legislative, regulatory and other political issues may arise in these jurisdictions that affect our operations. After careful consideration and approval of senior management, WestRock may engage in dialogue with government officials on issues that affect our business goals and objectives. We engage in political activity and spending outside of the U.S. as permitted by, and in strict compliance with, all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act.

Participation in Trade Associations and Coalitions

WestRock is a member of several trade associations, coalitions and other organizations that provide information and assistance on public policy issues to our business. We participate in groups such as the American Forest & Paper Association, the National Association of Manufacturers, the Pulp and Paperworkers Resource Council, the American Benefits Council, and the U.S.-China, U.S.-India and U.S.-Brazil Business Councils not only to influence policy decisions, but to gain information that will help us improve our global operations. We value the diversity of opinions found within these groups and sometimes take positions contrary to those of these organizations when we believe it is the right thing to do.

Our membership in these organizations is intended to accomplish a wide range of objectives which support our initiatives where we believe engaging with other industry participants is beneficial to our business and compliant with our antitrust policies. The company makes payments to these organizations, including paying membership fees and dues. On a semi-annual basis, we track the portion of the company's payments to trade associations that were used for non-deductible lobbying expenditures, which does not include funds supporting election-related activities, per the rules and regulations of the Internal Revenue Service. If applicable, we will disclose the amount of dues reported by trade associations as political contributions, if any, in the Annual Contributions Report. Any such disclosure will also include the nature of the political contributions reported by trade associations. To see a detailed list of payments made to trade associations that the recipient organization may use for political purposes, see data table below.

WestRock Employee Political Action Committee

WestRock Employee Political Action Committee (PAC) is a voluntary, non-partisan political action committee that is registered with the U.S. Federal Election Commission (FEC). The PAC allows employees to combine personal, voluntary financial contributions to candidates seeking federal elective office who support issues important to our business, our employees, and stakeholders.

The PAC files monthly reports with the FEC, as well as pre-election and post-election FEC reports. Click here to see a comprehensive listing of these reports which includes all itemized receipts and disbursements.

Corporate Contributions

WestRock uses corporate resources to support our position on important public policy issues.  Click here to view the public policy issues that help form the basis for our election-related spending decisions. The objective is to help elect pro-business candidates who display high levels of integrity and character, and who recognize the contribution of our industry to the national economy and the communities in which we live, work, and serve.

Oversight of Political Activity and Spending Practices

The Government Relations department, with oversight from the Advisory Board, sets an annual budget and has a stringent process for the justification, approval and reporting of political contributions made in the U.S., where such contributions are permissible by law. The company’s political spending includes donations to candidates for elected office, as well as payments to trade associations. The company conducts regular trainings, compliance system reviews, and internal audits to ensure all PAC and corporate political contributions are made in accordance with the law and company policies.

The WestRock PAC Advisory Board evaluates funding decisions that we believe, in aggregate, will have the greatest benefit for our business, employees and stakeholders. We contribute to candidates who demonstrate a commitment to ethical political conduct. We also consider the geographical area of their representation, their position on key issues impacting our company, and their legislative leadership position or committee membership.

WestRock’s Audit Committee  annually reviews and approves the company’s “Government Relations Department’s Political Disclosure and Accountability” policy as well as all PAC and corporate political contributions to ensure alignment with our company policy and values. These contributions are also subject to comprehensive regulation by federal and state governments, including detailed disclosure requirements.

No political spending is given in anticipation of, in recognition of, or in return for, any official act. Company political contributions reflect our interests as a company and not those of any individual director, officer, or employee’s personal political preferences. The company does not make “independent expenditures” or contribute to “Super PACs”, 527 groups, 501(c)4s, or for any election ballot measure.

For more information on WestRock's Government Relations activities, visit our dedicated Government Relations site

WestRock Global Tax Policy

WestRock’s tax policy sets out the principles WestRock follows for tax compliance, risk management and governance, and tax strategy and how our Core Values are integrated into our overall approach to the Tax function. Access our tax policy here: WestRock Global Tax Policy