GACA 1.1: How to write a responsible lobbying policy

The Government Affairs and Collective Action (GACA) topic in the B Lab Standards V2 requires companies to have a public policy on responsible lobbying. This policy helps you demonstrate that any lobbying you do supports positive social and environmental outcomes and is consistent with your broader impact commitments as a B Corp.

This article explains the GACA 1.1 standard and how your company can meet it.

What is GACA 1.1 in the standards ? 

GACA1.1 is a Year 0 requirement for all companies.  To achieve and maintain B Corp Certification, your company must have a public policy on responsible lobbying.

Responsible lobbying means lobbying that:

• Aims to create a positive impact for society and/or the environment,

• Is based on reliable or scientific data, and

• Is aligned with your overall sustainable strategy and impact commitments (for example, the B Lab Standards or the UN Sustainable Development Goals). 

Importantly, GACA1.1 requires companies to publicly commit to lobbying that contributes to positive impact. It does not prohibit other lobbying activities, provided that these activities do not undermine the company’s positive-impact commitments. 

What do we mean by lobbying?

In GACA, B Lab uses a specific definition of lobbying adapted from Transparency International’s Corporate Political Engagement Index. “Lobbying”  and “advocacy” are often used interchangeably and refer to activities carried out by, or on behalf of, an organized group that include:

• Communicating directly or indirectly with public officials, policymakers, or their representatives with the aim of influencing public decision‑making; and/or

• Seeking to influence public opinion, directly or indirectly, beyond normal advertising and marketing practices, in order to shape public decision‑making.

This covers both direct engagement with public actors and indirect efforts to influence public opinion where the ultimate goal is to influence public decision-making (for example, future regulations). 

GACA also explicitly includes indirect lobbying via intermediary organizations such as lobbyists, consultants, or trade organizations.

When does GACA 1.1 apply?

GACA1.1 applies if your company engages in lobbying now, or may do so in future. 

If your company does not engage in lobbying or advocacy, you can still meet this requirement by publicly declaring that you do not lobby.

You should have your policy (or non‑lobbying statement) in place and publicly available before your Year 0 audit.

How to write a responsible lobbying policy

Structure your lobbying policy so it clearly covers the following elements required by GACA1.1:

1. Purpose and scope

• Explain why your company lobbies and define the scope of the policy (which entities, geographies, and activities it covers). State that the company will lobby only in ways that contribute to positive social or environmental impact, and refer to frameworks such as the B Lab Standards and/or the Sustainable Development Goals (SDGs) to guide this commitment.

2. Evidence‑based approach

• Explain that your lobbying is based on reliable or scientific data.

• Briefly explain what “evidence-based” means in your context (for example, using peer-reviewed research, recognised international standards, or reputable public data). 

3. Political contributions and integrity

• Clarify your approach to financial and in‑kind political contributions (such as donations to candidates, parties, political action committees, or ballot measures).

• Describe the controls you have in place to prevent corruption, bribery, conflicts of interests, or undue influence in any lobbying or political engagement. 

4. Intermediary organizations (e.g. trade associations, industry groups)

• Explain how you assess whether the lobbying positions of intermediary organizations (trade associations, chambers of commerce, professional associations, etc.) are aligned with your policy. Describe

  • How you review those positions,

  • How you respond when there is misalignment (including publishing your own position where relevant), and

  • Any “red lines” that would lead you to end the relationship if misalignment cannot be resolved. 

5. Governance, controls, and risk management

• Identify which governance body or executive role is accountable for the lobbying policy (for example, Board committee, CEO, or General Counsel). Describe:

  • How the policy is approved, reviewed, and updated, 

  • How it is implemented in practice (e.g. internal procedures, training, approval workflows), and 

  • How you monitor and respond to non‑compliance or breaches.

6. Stakeholder concerns and grievance channels

• Explain how stakeholders (such as workers, affected communities, customers, investors, or civil society organizations) can raise concerns about your lobbying or political engagement. 

• Link or refer to your company’s grievance procedure under PSG3, making it clear that lobbying-related concerns can be raised and will be addressed.

Form and approval of the policy

Your highest governing body must approve the policy.

The policy can be:

• A standalone document (e.g. “Responsible Lobbying & Political Engagement Policy”), or 

• Integrated into another document, such as a code of ethics or broader governance policy, as long as it fully meets GACA1.1 compliance criteria (content on approach, governance, controls and risk management).

In all cases, you must publish the policy (or a clearly signposted section of another document) on your website in a location that is accessible to all stakeholders.

Non-lobbying statement (if you do not lobby)

If your company does not engage in lobbying or advocacy, you can meet GACA1.1 by publicly stating that: 

• You do not conduct lobbying or advocacy as defined above, and

• You will update this statement and adopt a responsible lobbying policy before engaging in any such activities in the future.

How to document GACA 1.1 in the B Impact self-assessment

When completing the self-assessment in B Impact, under the GACA 1.1 sub-requirementt:

• Indicate whether your company engages in lobbying
  Answer the questions on the platform about whether you lobby or conduct advocacy. Use the definition above to guide your response.

• Upload or link to your public lobbying policy (or statement)

  • If you lobby: upload or link to your public responsible lobbying policy, making sure it includes all GACA1.1 elements: approach, evidence‑basis, political contributions, intermediaries, governance, controls, risk management, and grievance channels. 

  • If you do not lobby: link to your public non‑lobbying statement on your website or B Corp profile. 

• Provide governance evidence
  Provide meeting minutes or other evidence that your highest governing body has reviewed and approved the policy (or the decision and statement not to lobby).

• Use additional guidance where needed
  For more detailed examples of acceptable evidence and documentation, see Government Affairs & Collective Action Evidence Examples. This resource explains the types of documents and evidence that companies can provide.