Influencing Power - WWF UK

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8 Influencing PowerOur ApproachOur Approach2.02.1 Scope of the ProjectThe core of the research for this projectinvolved a benchmark of the Standard &Poors (S&P) Global 100, a widely recognisedlisting of major global companies, 26 toassess disclosure around companies’lobbying and public policy activities.Our research focused on the conduct oflobbying — assessing the level oftransparency and looking for evidence thatcompanies are actively linking lobbyingwith their stated commitments and values.The benchmark is not, however, anassessment of the content of corporatelobbying, nor is it an assessment of acompany’s overall CR performance.Transparency is a basic requirement of ourassessment. So companies that may beusing their influence over public policyresponsibly but without transparency willreceive a low rating. We feel this is justifiedas transparency is integral toaccountability, although we concede thatthere are a small number of specificcircumstances in which transparency couldbe counter-productive, for example in thecontext of corruption or human rights infailing states or dictatorial regimes.Overall our assessment is based on theconcepts of:— TransparencyDoes the company provide informationon its lobbying and public policyactivities?— MaterialityDoes lobbying and public policyinformation focus on the most materialissues for the business (see Panel 3.4)?— ConsistencyAt least within the scope of this report,consistency refers to alignment betweena company’s lobbying activities and itsvalues and business principles. How fardoes the company go in demonstratinghow lobbying is linked to and supportiveof its core values and principles?Although the focus of this report is onbenchmarking company performance, webelieve these principles apply to all groupsinvolved in lobbying government includingNGOs.2.2 MethodCollecting the relevant documentation forreview then involved a two step processand included:— Checking if the company has apublished report covering theirapproach to CRFor conglomerates we focused on thegroup or corporate report rather thanreports relating to just one country orarea of operation. 27— Reviewing the group or corporatewebsite for information on lobbyingand public policy positionsIn order to manage the time spentreviewing websites (in some casescompanies have over 1,400 pages onCR issues) we limited our search forinformation to 20 minutes on the basisthat if more time than this was needed,we would consider the information tobe too far buried to be considered‘transparent’.Having collected the relevant material,we analysed the documentation basedon a rating system derived from theSustainAbility/UNEP report benchmarkingmethodology, 28 but focusing exclusively onlobbying (See Figure 2.1).
Influencing PowerOur Approach2.3 LimitationsIt is our view that the method outlinedabove allows us to paint a picture of theapproach that companies in the S&P Global100 take to lobbying in the context of theirvalues and principles. The higher a companyscores, we believe, the more it can claim tobe transparent and consistent in itsapproach to lobbying.However, there are some important caveats.For example:— The research assesses the transparencyof lobbying based on company-suppliedpublic information for 100 companies.The approach does not allow us to assesswhether some material information isnot being disclosed — which wouldrequire an investigative approach moreappropriate for a much smaller group ofcompanies.— Companies may be influencing policy inways that are inconsistent with theirstated policy positions, through supportfor organisations like trade associationsor think-tanks (see p.14).However, company influence throughsuch third parties was considered only inso far as information was provided incompany reports or websites.— There are many forms of soft influenceon public policy, ranging from supportingthink-tanks that influence the broadpolicy environment to fosteringrelationships with government officials(e.g. by hiring former government staffor the secondment of staff betweenbusiness and government). This is anabsolutely critical area but hard tomeasure and was considered in therating only where company informationwas available.— The S&P Global 100 was chosen as thebasis of the benchmark in order to have awidely recognised listing of major globalcompanies, representing a spread ofindustrial sectors and geographies.However, this listing includes only thelargest companies and will notnecessarily reflect the corporate sectormore broadly. It also disregardscompanies in many world regions,especially outside the OECD countries.— As noted, political cultures and thebusiness–government interface canvary enormously from one country tothe next. Many of the underlyingassumptions in this paper are based onan Anglo-American model as we wereunable adequately to address a diversityof cultures within the scope of thisproject (although see comments onp. 14). We acknowledge this bias as amajor gap, but hope that the papermakes a helpful contribution to a debatewhich others will certainly expand upon.9Rating the Quality of InformationThe quality of theinformation andapproach adoptedby each companywas given one of thefollowing ratings.NoneNo informationprovided onlobbying. Or thecompany makesgeneral references,such as a simplestatement ofcompliance with thelaw on politicalcontributions, butprovides no insightinto activities orimpacts.BasicCoverage recognisesthe relevance oflobbying to corporateresponsibility issues.DevelopingAs above butinformation alsoincludes signs thatrobust systems andprocesses are beingdeveloped to activelymanage and discloselobbying and publicpolicy activities.The company likelydiscusses at leastone ‘material’ issuein some depth.SystematicCoverage of lobbyingindicates thatsystems exist toactively manageand disclose lobbyingand public policyactivities. Thecompany likelydiscusses policypositions on severalmaterial issues insome depth.However, approachto lobbying is stillnot fully integratedwith companyvalues, businessprinciples and corebusiness decisionmaking.IntegratedAs above and inaddition there isan explicit linkmade betweencorporate valuesand principles, corebusiness decisionmaking(includingcorporate governance)processesand a company’sapproach to publicpolicy.There is likely, forexample, to beevidence of adecision-makingprocess leadingfrom basic valuesand principles tospecific businessobjectives andlobbying thatsupports theseobjectives.Figure 2.1
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