Questions & Answers

Question-ID: 510

Release Date: Apr 30, 2024


Questions & Answers

In ESRS G1-5, what is the dividing line between ‘indirect political contributions’, whose financial or in-kind amounts must be disclosed according to paragraph 29 (b)(i) and AR 10, and ‘lobbying activities’, whose financial or in-kind amounts may be disclosed as per AR 12?

Key Terms
  • Political contributions
  • lobbying activities

Background

The concept of ‘political contributions’ is defined in AR 9 of ESRS G1-Business Conduct. This paragraph states that political contributions refer to support provided directly to political parties, their elected representatives or persons seeking political office.

The concept ‘indirect political contributions’ is defined in AR 10 of ESRS G1-Business Conduct. This paragraph states that these refer to ‘those political contributions made through an intermediary organisation such as a lobbyist or charity, or support given to an organisation such as a think tank or trade association linked to or supporting particular political parties or causes.’

GRI, in its standard 415: Public Policy defines ‘indirect political contributions’ as ‘financial or in-kind support to political parties, their representatives, or candidates for office made through an intermediary organization such as a lobbyist or charity, or support given to an organization such as a think tank or trade association linked to or supporting particular political parties or causes.’

The ESRS and GRI refer to ‘indirect political contributions’ as contributions linked to political parties and political causes.

On the other hand, ‘lobbying activities’ as defined in Annex II of ESRS refer to ‘activities carried out with the objective of influencing the formulation or implementation of policy or legislation, or the decision-making processes of governments, governmental institutions, regulators, European Union institutions, bodies, offices and agencies or standard setters.’

Answer

Political contributions support political parties and/or election campaigns in their respective political causes, and they can be direct or indirect. Indirect political contributions are made on behalf of a company by an intermediary organisation, such as a think tank, a business association or a charity. While political contributions are most commonly financial, e.g., donations, event sponsorships or purchases of tickets at campaign or fundraising events, they can also be non-financial (‘in kind’), e.g., providing certain services like printing of posters, website design or permission to use facilities.

Lobbying, on the other hand, is about influencing policies, political decisions, laws and other regulations, usually when they are being drafted or prepared but also in the implementation stage. The typical targets of lobbying activities are therefore decision-makers in governments and ministries, supervisory authorities and other government agencies as well as members of parliaments and/or their assistants. Lobbying, too, can take direct or indirect forms. In the latter case, the company entrusts the lobbying to a specialised service provider or to a not-for-profit intermediary such as a business association.


Relations

Paragraph
Content
2023 ESRSESRS G1 - BUSINESS CONDUCT...Disclosure Requirement G1-5 – Political influence and lobbying activitiesAR 12.

The undertaking may provide the following information on its financial or in-kind contributions with regard to its lobbying expenses:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Appendix A - Application RequirementsAR 10.

‘Indirect political contribution’ refers to those political contributions made through an intermediary organisation such as a lobbyist or charity, or support given to an organisation such as a think tank or trade association linked to or supporting particular political parties or causes.

2023 ESRSESRS G1 - BUSINESS CONDUCT...Disclosure Requirement G1-5 – Political influence and lobbying activities29. (b)

for financial or in-kind political contributions:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Disclosure Requirement G1-5 – Political influence and lobbying activitiesAR 12.

The undertaking may provide the following information on its financial or in-kind contributions with regard to its lobbying expenses:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Disclosure Requirement G1-5 – Political influence and lobbying activitiesAR 10.

‘Indirect political contribution’ refers to those political contributions made through an intermediary organisation such as a lobbyist or charity, or support given to an organisation such as a think tank or trade association linked to or supporting particular political parties or causes.

2023 ESRSESRS G1 - BUSINESS CONDUCT...Disclosure Requirements29. (b)

for financial or in-kind political contributions:

2023 ESRSESRS G1 - BUSINESS CONDUCT...Appendix A - Application RequirementsAR 10.

‘Indirect political contribution’ refers to those political contributions made through an intermediary organisation such as a lobbyist or charity, or support given to an organisation such as a think tank or trade association linked to or supporting particular political parties or causes.

2023 ESRSESRS G1 - BUSINESS CONDUCT...Metrics and targetsAR 12.

The undertaking may provide the following information on its financial or in-kind contributions with regard to its lobbying expenses:

2023 ESRSESRS G1 - BUSINESS CONDUCTDisclosure Requirements29. (b)

for financial or in-kind political contributions:

2023 ESRSESRS G1 - BUSINESS CONDUCTAppendix A - Application RequirementsAR 12.

The undertaking may provide the following information on its financial or in-kind contributions with regard to its lobbying expenses: