RECOMMENDATIONS ON LOBBYING TRANSPARENCY FOR ORGANISATIONS AND PUBLIC POLICY ADVOCATES

In order to increase the transparency of their lobbying activities organisations and public policy advocates should take the following 10 steps regarding their efforts to influence public policy formation.

1. Make lobbying part of their corporate social responsibility (CSR) policy: Acknowledge that lobbying activities can be harmful to the public interest and therefore need to be conducted in a socially responsible way. Just adhering to current law and regulation is not sufficient and therefore lobbying should be part of the CSR policy of your organisation where it formulates additional rules and guidelines for its behaviour.
2. Make transparency a cornerstone of the CSR effort in the field of lobbying: Acknowledge that being transparent about lobbying activities is an important way to contribute to democratic legitimacy and to improve the quality of the policy-making process. Transparency provides third parties with a chance to participate, thereby increasing the diversity of opinion and broadening and deepening the knowledge base used in formulating new public policies. Transparency is also needed for holding all participants in this process to account.
3. Register all lobby efforts: Register your organisation, the costs that fall within the scope of lobbying activities, and the names of the employees responsible for lobbying. This can be done through existing registries in your country and the European Union that can be referred to on your organisation’s website. Registering your organisation, names of employees and lobbying budget gives the public insights into the size of the lobby and provides transparency about which people carry out lobbying activities.
4.  Develop a list of policy issues that are of material importance: Develop a list of policy issues that are of material importance to your organisation in its communication with policy-makers and supervisors. Make a distinction between the issues that take priority and the topics that do not belong to the selected priorities. Issues that are the subject of most communications with government authorities are defined as priority issues. An issue can also be identified as a priority when it is raised as a key issue through stakeholder engagement. Describe for all priority issues the possible impact of your organisation’s position(s) on the public interest.  Laws and regulations are issues that affect your organisation, as well as issues that receive a lot of media attention. It is relevant for the public to be aware of the issues that your organisation takes a position on and which issues take priority above others. Of these priority issues, the main potential conflicts with the public interest should be reported.
5. Publish all submissions for (public) consultation: Publish and archive all written submissions for (public) consultation on a dedicated and accessible place on your website. Use alerts, for example, via email and Twitter, to notify interested parties and the wider public of updates and other changes on this page. Submissions are position papers, questionnaires and other documents drafted for a (public) consultation. Transparency will be improved when all submitted documents for consultations are collected and published in one digital space, where they are then kept unchanged. Public policy positions are available to the public in a structured and accessible manner. The reason for creating a space on your website to collect this information is that the development of positions on key issues is an ongoing process. A website fits best with this process, as opposed to an annual report, which represents a snapshot.
6. Publish all written documents shared with regulators and policy-makers: Publish and archive on the specially designed web page – as far as possible, and give reasons when it is not possible – documents that have been shared with external parties (like regulators and policy- makers) that express the positions of your organisation regarding public policies and other matters referred to in public debate. Documents about the positions of the organisation on certain topics are not always prepared with a view to a public process (e.g. consultation), but serve as preparation for other types of meetings or (lobbying) activities (such as discussions with policy-makers, roundtables and expert groups). These documents are of interest to the public, because they explain the views and interests of your organisation.
7. Publish all work commissioned by your organisation and make the funding transparent: Publish all legal opinions, surveys, academic studies and reports by independent institutions that were commissioned and/or funded by your organisation. Be transparent about any academic positions funded by your organisation and the agreements made with the hosting institution.
8. Publish details of meetings with policy-makers: Notify the public regarding existing contacts with regulators and policy-makers. Report on planned personal meetings that take place, who participates in those meetings and which subjects are discussed. Report also on membership of expert groups and panels. The frequency of contact, combined with the topics discussed, gives an indication of which topics require most attention from your organisation. Since it is unrealistic (and perhaps ineffective) to report all details of all moments of contact/communication with decision-makers and policy-makers, it is good to limit the reporting to an overview of planned personal meetings on topics that have been identified by your organisation as priorities.
9. Publish lobbying efforts of third parties that represent your organisation: Report about the role of your organisation (membership of boards or specific commissions) within the organisation that also lobby on your behalf and the lobby activities of such organisations themselves,  where relevant for the prioritised policy issues of your organisation. Not only your organisation’s own lobbying should be transparent. The lobbying that takes place on policies by entities that your organization is a member of should be equally transparent. The lobbying activities that are reported should include meetings with regulators and policy-makers, membership of expert groups and written documents. This should be either published on your organisation’s website or should be referred to specifically.
10. Report on job mobility between your organisation and the public sector: Be transparent about the ‘revolving door’ phenomenon. Report annually the number of job changes between your organisation and the public sector. Specify at what level in your organisation this mobility has taken place. Revolving doors may have harmful effects because knowledge and connections from a previous workplace can be deployed within the same field but from an opposite point of view. More generally, it may lead to an undesirable level of identification between policy-makers, supervisors and your sector.