GRI 415 Public Policy
GRI 415 requires disclosure of political contributions — financial and in-kind — made to political parties, politicians, and related institutions. As corporate political influence faces growing scrutiny, transparent lobbying and political contribution disclosure is increasingly material for investor trust and regulatory compliance.
GRI 415 requires disclosure of political contributions — financial and in-kind — made to political parties, politicians, and related institutions. GRI 415-1 requires disclosure of the total monetary value of financial and in-kind political contributions made directly and indirectly by the organisation, by country and recipient.
What GRI 415-1 requires
GRI 415-1 requires disclosure of the total monetary value of financial and in-kind political contributions made directly and indirectly by the organisation, by country and recipient.
Direct contributions: payments to political parties, political campaigns, ballot initiatives, referenda, and individual politicians.
Indirect contributions: payments to trade associations, industry groups, think tanks, and advocacy organisations where a portion of the payment is used for political activities.
In-kind contributions: provision of goods, services, or personnel time for political purposes — event hosting, staff secondments, advertising space, or vehicle use.
Many jurisdictions prohibit direct corporate political contributions — in those cases, disclose the prohibition and confirm zero contributions, alongside any indirect contributions via trade associations.
Lobbying transparency beyond GRI 415
GRI 415 covers political contributions — but investors increasingly expect broader lobbying transparency: total lobbying expenditure; the policy positions advocated; and the consistency between public sustainability commitments and private lobbying positions.
ESRS G1-5 (business conduct) requires disclosure of political engagement and lobbying activities — including the material positions taken on key legislation and how these align with the company's sustainability strategy.
The lobbying-sustainability consistency gap is a major ESG controversy area. Companies that publicly support Paris Agreement goals while privately lobbying against climate legislation face significant investor and NGO pressure. InfluenceMap and the Corporate Climate Responsibility Monitor track and publicise these inconsistencies.
Trade association lobbying — indirect exposure
Many companies make zero direct political contributions but fund trade associations that lobby intensively. This indirect exposure is material — if your trade association lobbies against climate policy while your company has net zero commitments, this inconsistency is reputationally significant.
Best practice: disclose all material trade association memberships and annual contribution amounts; assess alignment between trade association lobbying positions and company sustainability commitments; and publicly disclose where misalignment exists and how you are addressing it (including resignation from the association if necessary).
Some companies — Microsoft, Unilever, BP — have publicly resigned from trade associations or challenged their lobbying positions. This level of transparency is increasingly expected by investors with climate commitments.
Frequently asked questions
Are political contributions prohibited under CSRD?
CSRD does not prohibit political contributions — it requires disclosure of them under ESRS G1. Several EU member states prohibit direct corporate political donations under national law. Disclose both the legal framework and actual contributions (or zero if prohibited).
Do we need to disclose trade association membership fees?
GRI 415-1 requires disclosure of the portion of trade association fees used for political activities — not the total membership fee. In practice, trade associations rarely itemise the political spend component, so many companies disclose total fees paid with a note that the political portion is unknown.
How do ESG rating agencies assess GRI 415 disclosures?
MSCI and Sustainalytics score political contribution transparency positively — companies that disclose zero contributions (with confirmation of the prohibition) or itemised contributions score better than companies with no disclosure. The bigger flag is inconsistency between lobbying positions and stated sustainability commitments.