Pukka Herbs on Lobbying & influence

Does your company make representations to law-makers or government officials?

No

We do not employ lobbyists nor make representations to law-makers or government officials and we do not have any intention to do so. Our sustainability policy includes a commitment to fairness, openness, trust and integrity which is reflected in our responsible lobbying activities, carried out indirectly through membership with the following organisations who share our values:

  • Soil Association and the Organic Trade Board for organics
  • Alliance for Natural Health for freedom in health choices, genetically modified foods, environmental pollutants and health claims
  • Cruelty Free International for a ban in the testing of animals for cosmetics and consumer products and ingredients

Free and open access to government is an important matter of public interest. In democratic societies, citizens and civil society groups have the right to express their interests and concerns to elected or appointed government officials at national, regional and local levels. It is also recognised that businesses possess these same rights. Indeed, extensive, open participation is considered essential in promoting informed, evidence-based decisions regarding policy and law-making. Lobbying public office holders is therefore a legitimate and necessary activity.

A variety of organisations, such as charities, NGOs and trade associations as well as businesses, engage in lobbying for many reasons, with varying levels of success and influence. As Georg Kell, the executive director of the UN Global Compact, wrote a few years ago in a report on responsible lobbying: "Ensuring that lobbying doesn't undercut corporate responsibility is of great importance .... But probably more important is the question whether and how lobbying can become a positive force to support, or even expand, a commitment to responsible business."

However, as Transparency International explains, the means by which interests are expressed can be open to abuse. It is not in the interest of wider society if some organisations can unduly affect the decisions made, whether in formulating policy or creating favourable regulatory regimes or, more crudely, awarding contracts or granting special permits or other favours.

Some organisations seek influence by engaging specialist lobbying firms. These have expertise in gaining access to government officials and in putting issues before decision-makers. The core function of such professional lobbyists is to influence government in a way that is favourable to their clients. It is predominantly large businesses that engage them - and may spend large amounts of money to do so. Between 2008 and 2010, 30 Fortune 500 companies spent more on lobbying than they paid in federal income taxes. It is also possible for corporations to have indirect influence through, for example, support of think-tanks that are generating ideas and policy. The fact that rich and powerful business interests, or even wealthy individuals, can buy influence, and the special privilege that flows from it, undermines basic concepts of fairness and representative democracy.

There is a difference between legitimate and illegitimate lobbying but it sometimes requires clear values and fine judgement to identify where a particular action lies along the spectrum. For example, there may be practical benefits to individuals moving between posts in government and related jobs in commerce and industry as this may enable the two sides to better understand each other and brings practical experience to policy making, with benefits to wider society. On the other hand, a "revolving door" between the public and private sectors may result in networks of former colleagues being used for private business advantage and/or individual gain. Some nations maintain a register of lobbyists and also set minimum periods before former government people can take up paid employment as lobbyists.

Nonetheless, as it is possible for a business to have great influence without ever abusing it, this question provides an opportunity to explain how a business ensures it is careful and responsible when making representations to law-makers or government officials. Examples of the steps it may take include:

  1. setting out guidelines regarding hiring lobbyists or donating to interest groups whose functions include lobbying (including policy think-tanks and campaigning groups, e.g. on environmental and human rights issues);
  2. being transparent about financial support for politicians, political organisations and campaigns;
  3. making public the briefing materials and consultation responses provided to public bodies or officials;
  4. recording and restricting the amounts of spending on receptions, meals, gifts etc.;
  5. setting out circumstances where a 'conflict of interest' might arise and set out guidelines for actions and steps to deal with the problem.
Responsible lobbying

'Responsible lobbying' occurs when it is consistent with the stated policies of an organisation, its commitments to stakeholders, and to core strategy and actions, and also where it advances the implementation of universal principles and values in business practice.

Lobbying

'Lobbying' is the practice of seeking to influence the opinions and/or decisions of members of government, politicians or public officials. Methods of lobbying vary. They can range from individuals sending letters to their elected representatives, to businesses and trade associations making presentations, providing briefing material to decision-makers, networking with decision-makers and using personal contacts to extend influence and access to decision makers or government officials. Methods of indirect lobbying include donating to campaign groups and funding think-tanks.

Answering YES

All Businesses MUST

Describe how they engage with the law-makers and elected or appointed government officials

Describe any policies they have which inform such engagements

Explain whether they have engaged specialist lobbying consultants/companies, indicating their reasons for doing so how much they paid to such firms and specialists

All Businesses MAY

Explain any philosophy or values which underpin their actions

Describe any future intentions regarding this issue

Answering NO

All Businesses MUST

Confirm they do not make any representations to law-makers and elected or appointed government officials

All Businesses MAY

Describe any policies they do have regarding engagement with law-makers and elected or appointed government officials

Describe any future intentions regarding this issue

DON'T KNOW is not a permissible answer to this question

NOT APPLICABLE is not a permissible answer to this question

Version 1

To receive a score of 'Excellent'

Government contact and lobbying managed strategically and openly

e.g. Statement of philosophy or values
e.g. Clearly established parameters for engagement with law-makers and elected or appointed government officials
e.g. Policies and practices disseminated across workforce, suppliers and stakeholders
e.g. Training on this issue consistently provided for employees
e.g. Effectiveness of policies and practices regularly reviewed and evaluated
e.g. Fully transparent on all lobbying activities, including employment of professional lobbyists, publication of consultation documents and briefings produced
e.g. Engage with outside organisations to improve business practice on this issue

To receive a score of 'Good'

Government contact and lobbying managed with clarity

e.g. Statement of philosophy or values
e.g. Clearly established parameters for engagement with law-makers and elected or appointed government officials
e.g. Policies and practices disseminated across workforce and stakeholders
e.g. Effectiveness of policies and practices regularly reviewed
e.g. Publication of consultative documents and briefings

To receive a score of 'Okay'

Some rules and/or parameters evident

e.g. Some clear parameters for engagement with law-makers and elected or appointed government officials
e.g Statement of no contact, appropriate to business

To receive a score of 'Poor'

The business acknowledges performance below expectations

e.g. Statement of a future intent to improve
e.g. Ad hoc relationship with government etc

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