PRINCIPLES OF RESPONSIBLE PUBLIC POLICY ADVOCACY

Source: Inspired by Transparency International Ireland (Author John Devitt).

Adapted to Public Policy Advocacy

1. Legitimacy

Legitimate public policy advocacy means that:

• The public policy advocate’s arguments will be judged on the strengths of the case he/she presents to convince policy makers.
• A Public Policy Advocate will not resort to making payments to public officials or donations to political parties to influence public policy. He or she should also not offer employment to public representatives or officials as a way of influencing their behaviour or decisions.
• Other conflicts of interest should be avoided that would interfere in the judgement of a policy maker. Any personal or business relationships between the public policy advocate and public officials should therefore always be disclosed to clients, colleagues and the relevant authorities.
• A public policy advocate will be prepared to walk away from a client that insists on engaging in unethical or unlawful activity and will also be ready to report wrongdoing to the appropriate authorities.

Implementing this principle:

Organisations should engage with their stakeholders and determine whether their public policy  positions are aligned with universal principles and standards such as the UN Global Compact. Where possible, organisations should publish risk benefit analyses of their positions and make them available to their stakeholders. They might also subject their policies to external review and criticism. They should also publish any funding they provide in support of scientific research or think tanks. In addition, all organisations should implement and publish policies on payments, gifts and political donations. They should also implement policies on recruitment of staff from the public service.

2. Transparency

Transparent public policy advocacy implies that:

• Where possible and without compromising commercial or client confidentiality, organisations should proactively publish their public policy advocacy submissions, policy papers and evidence to support their positions.
• The public policy advocate  or the organisation he/she works for, will not use covert tactics to influence public policy or public opinion. Such tactics might include setting up or funding ‘front groups’ that will pose as independent organisations that, in reality, are pursuing the funding organisations’ interests.
• Public policy advocates should also avoid using such groups to petition public representatives for the introduction of policies without those representatives knowing the true nature of the group petitioning them.

Implementing this principle:

Some statutory registers require that public policy advocates disclose their clients, budgets and the objectives they pursue. But organisations should report on public policy advocacy without a legal requirement to do so. An organisation’s policies, internal public policy advocacy guidelines and other information related to their public policy advocacy activities – such as financial and other contributions to political parties, policy papers and other written input sent to policy-makers - should be published on its website.

3. Consistency

Consistency implies that:

•  An organisation should align its internal and external messaging to ensure it is not sending different messages to its internal and external stakeholders. Public policy advocates should also be open with stakeholders in developing views and positions.
• Organisations should declare if their position is different from that of a network that they belong to (such as a trade association).
• In formulating positions, professionals and organisations should also consider how their activities, policies and public policy advocacy objectives are consistent with universal principles and values.

Implementing this principle:

Consistency can be measured by conducting a periodic audit of an organisation’s public policy advocacy and political activities. An audit will allow an organisation to compare its internal policies with universal standards, its actions with its public statements and its internal and external messaging. The audit should also detect any differences in policy between representative organisations such as trade bodies and the organisation itself. It can be conducted by an organisation’s communications team with input from other internal stakeholders such as board members and management. Input from external stakeholders including NGOs and community groups will also help test whether an organisation is practicing what it preaches. The results of an audit should inform an organisation’s CSR/sustainability policies as public policy advocacy strategies. They should also be communicated with its key stakeholders – particularly those that have provided input into the audit. A company’s annual sustainability report and website could be used to share the findings of its audit and demonstrate its commitment to responsible public policy advocacy and political activity. In addition, it is advised that organisations create common core messages across platforms and regions. This is particularly important for multi-national companies who will often have representatives engaging policy makers in numerous jurisdictions.

4. Accountability

Accountability implies that:

• Professional public policy advocates will familiarise themselves with the relevant professional standards and publish their commitment to those standards.
• Organisations will ensure that public policy advocacy positions are monitored by its board of directors and that management will account to their board for public policy advocacy activities.
• Public policy advocates should be prepared to advise clients if their proposed actions are illegal/ improper, and in appropriate circumstances, refuse to act.
• Notwithstanding the public policy advocate’s duty of confidentiality to his/her client, where a client engages in illegal activity the public policy advocate should report this to the relevant legal authorities.

Implementing this principle

An organisation should publish its commitment to responsible public policy advocacy standards on its website and ensure that public policy advocacy strategies are aligned with those standards. A public policy advocacy audit can also help highlight public policy advocacy tactics that are potentially at odds with accepted standards, and compare the risks and benefits of a particular public policy advocacy objective to an organisation. Where possible, an organisation or representative association should appoint a compliance officer to investigate apparent breaches of responsible public policy advocacy standards. This should be accompanied by an internal disciplinary system to allow for fair and thorough examination of a breach and to allow for action to be taken to prevent further lapses. Accounting for one’s actions is a continuous process and a public policy advocate  or organisation should also engage with its stakeholders in a systemic way. Stakeholders – particularly those communities that are affected by the organisation’s public policy advocacy – should be consulted on the organisation’s positions and activities. A process of ongoing consultation will help an organisation respond to its stakeholders and account for its decisions in a timely way. The role of internal stakeholders in determining public policy advocacy positions – particularly board members and senior management –should also be clear and reported upon in an organisation’s annual report or sustainability review.

5. Opportunity

Opportunity implies that:

• Organisations will engage in research and dialogue to reflect on the relevance of particular issues to a business and to collaborate with their stakeholders to identify risks and potential benefits of their public policy advocacy positions.
• Where the relevance of a given issue is established, organisations should also identify entry points for joint intervention such as weak anti-corruption or environmental regulations and engage in public policy advocacy collectively to ensure that such regulations are fit for purpose.
• Business and civil society should work together to promote higher standards of transparency and accountability from their counterparts in government.
• Trade and professional associations should also work with civil society groups in advancing responsible public policy advocacy standards and working towards more open, accountable government.

Implementing this principle: 

 A review of CSR, sustainability or public affairs strategy can offer an opportunity for a business to identify emerging public policy issues in which it has a direct or indirect stake. While reviewing its policy priorities, it can identify relevant stakeholders – including civil society partners – with whom it can work. One way of engaging with civil society organisations is to hold or sponsor joint workshops and meetings on issues of common concern. Dialogue can evolve into a partnership or collective action plans to engage in public policy advocacy or monitor compliance with agreed standards of behaviour. Online platforms and forums such as conferences provide additional opportunities for learning, dialogue and external communication. The goal of such activities might not always be to change a specific government policy but to also influence the underlying policy climate and change behaviour in a way that complements any desired policy reform.