A Multidimensional Model Of Responsible Lobbying Accounting Essay

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Practitioners and scholars have long neglected the necessary alignment of lobbying and CSR, although lobbying is a powerful corporate tool that should not contradict CSR. This conceptual paper contributes to closing the research gap by presenting a multidimensional model of responsible lobbying, defined as lobbying in congruence with the corporate responsibilities towards society. It constitutes three content-related modules calling for consistency between the firm's own CSR commitment and lobbying, consideration of perspectives and needs of stakeholders

and the alignment with the objectives and values of broader society. It claims that the basis for responsible lobbying needs to be an ethical, democratic, dialogue-oriented process.

Introduction

CSR has attained a high profile in recent years: many companies have learnt to understand that business policies and strategies should not only be profitable for the firm itself but also be desirable in terms of the objectives and values of society. Attempts to influence decisions made by legislators can be a powerful corporate tool that should not contradict stated CSR policies. Nevertheless, many companies still fail to extend their CSR principles to lobbying, as e.g. the German car industry's attempt to forestall stricter EU regulation of CO2 emissions in spite of commitments to protect the environment has shown. Others have launched measures to accomplish coherence between CSR policy and lobbying or have even taken a leading role in lobbying for an increased level of regulation. For instance, Vodafone, Google and Cisco have advocated strong EU greenhouse gas reduction targets and thus have proved the feasibility of lobbying in line with CSR commitments and the interests of wider society.

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So far, there has been very little academic attention to the linkage of lobbying and CSR: Lobbying literature neglects by and large the issue of responsibility, except few studies dealing with ethical aspects of lobbying (Ostas 2007, Grimaldi 1998, Oberman 2004, Weber 1996, Weber 1997). CSR scholars have started to look into the political role of corporations (Moon et al. 2005, Scherer and Palazzo 2007, Scherer and Palazzo 2011), but have focused mainly on corporate participation in processes of global governance, neglecting corporations directly influencing policy-making. The issue of responsible lobbying, understood as lobbying in congruence with the corporate responsibilities towards society, has recently caught some scholarly attention; but the few existing studies (Anastasiadis 2010) are exploratory and call for further substantiation of the issue.

There are good reasons to link CSR and lobbying both in theory and practice: First, CSR should be fully integrated and embedded in every aspect of the firm, and is therefore deficient and risks credibility if it fails to take lobbying into account. Second, lobbying is principally a legitimate activity in a democratic setting, it reflects freedom of opinion, enhances participation and may contribute to well-informed and balanced policy-making (Ostas 2007, Karr 2007: 9, Greenwood 2007). Yet, it has a rather poor reputation among the public due to concerns about privileged access to policy-.makers and abusive, selfish use of corporate power at the cost of society. Given the public criticism of lobbying, politically engaged firms need to link CSR to their lobbying practice in order to establish trust among politicians and administrators, and ensure the firm's legitimacy.

Recognizing the need to integrate CSR and lobbying leads to the challenge of defining what exactly entails responsible lobbying, respectively what makes lobbying compatible with the corporate responsibilities towards society. In practice, a step towards linking CSR and lobbying that has recently gained importance is the inclusion of lobbying issues in CSR reporting, like BASF, BAT, Marks&Spencer, Lafarge, or GlaxoSmithKline do. But transparency needs to be complemented by efforts to ensure coherency regarding the content of lobbying. Moreover, it is questionable whether it is sufficient to ensure that lobbying positions are acceptable according to the firm's own standards. Further measures are required that bring lobbying in line with the needs of stakeholders and interests of broader society.

This paper aims at contributing to closing the research void regarding the alignment of CSR and lobbying by developing a theoretically substantiated understanding of responsible lobbying. Due to the multi-layered and highly contested nature of both CSR and lobbying, multiple aspects both regarding the content and the process of lobbying need to be incorporated. Hence, a multidimensional model of responsible lobbying is introduced that allows for determining whether and to what extent firms meet their responsibilities towards society in their lobbying efforts.

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First, the paper provides a review of CSR literature - including related approaches such as sustainability and stakeholder theory - and lobbying literature in light of their relevance for responsible lobbying. Next, the multidimensional model of responsible lobbying is presented by elaborating on three content-related modules calling for consistency between the firm's own CSR commitment and lobbying, consideration of perspectives and needs of stakeholders

and the alignment with the objectives and values of broader society, and claiming that the basis for responsible lobbying needs to be an ethical, democratic, dialogue-oriented process. The paper concludes by suggesting that even though the model constitutes high demands towards firms, it provides a useful basis for determining what firms do and ought to do.

Literature review

CSR, sustainability and stakeholder theory

The literature on CSR reflects a well-established field, with a range of different approaches (Garriga and Melé 2004, Schwartz and Carroll 2008, Melé 2008). There is theoretical work including ethical-normative and instrumental approaches and a large amount of empirical, mostly quantitative studies (Lockett et al. 2006). Ethical-normative approaches claim that companies should act in a socially-responsible manner, because it is "the right thing to do" (Garriga and Melé 2004: 60, see also Quinn and Jones 1995). On the other hand, the business case approach encourages socially-responsible behavior by arguing that behaving responsibly will bring financial rewards (Kapoor and Sandhu 2010, Roman et al. 1999, critical: Margolis and Walsh 2001, Margolis and Walsh 2003, Vogel 2005). In practice, many CSR initiatives are based upon mixed motives of morality and ensuring the firm's survival and success, as firms hope to profit from reduced costs and risks, competitive advantage, enhanced reputation and legitimacy and acceptance in wider society.

There is no single definition of CSR agreed upon either by academics or practitioners of CSR (Carroll 1999, Valor 2005, Scherer and Palazzo 2007). Empirically, CSR policies and practices "reflect business responsibility for some of the wider societal good", and are concretized by firms that develop specific policies and practices that "lie at the discretion of the corporation" (Matten and Moon 2008: 405). One of the most cited CSR models is Carroll's (1979) CSR pyramid that conceptualizes four types of responsibilities for the corporation: 1. the economic responsibility to be profitable; 2. the legal responsibility to abide by the laws of society; 3. the ethical responsibility to do what is right, just, and fair; and 4. the philanthropic responsibility. While Carroll's model has its downsides, e.g. the static, hierarchical character of the pyramid, it still is a pragmatic and in many contexts useful model for describing and explaining CSR. It encompasses widely shared notions of CSR scholars, most notably the assumptions that corporations ought to consider social issues besides striving for profit, that they ought to behave ethically, and that philanthropy and community involvement is desirable (cf. Banerjee 2008: 62). Another commonality of most definitions of CSR is its understanding as beginning "where the law ends" (Davis 1973: 313). Yet, the beyond-the-law character of CSR has been put into question: critics have pointed out that voluntariness limits CSR to its instrumental character and implies the danger of CSR programs merely being launched to enhance profits and to forestall legislation (Sethi 2008: 94, Cragg 2005, Rowe 2005). Governments have started to promote CSR, partly through incentives, but increasingly also through obligatory measures. In addition, the beyond-the-law-approach is inutile in the context of responsible lobbying, since lobbying is precisely about influencing policy-makers and legislation.

Recently the political role of corporations has received some attention in CSR literature, alternatively under the headline "corporate citizenship" (Crane et al. 2008, Matten and Crane 2005, Moon et al. 2005) or "political CSR" (Scherer and Palazzo 2011, Scherer and Palazzo 2007). Matten and Crane (2005) argue for an extended view of corporate citizenship that describes the role of the corporation in administering citizenship rights for individuals. They posit that governments fail to provide citizenship rights ever more, and accordingly corporations play an increasing role in enabling civil rights, providing social rights and channeling political rights (Matten and Crane 2005: 174). Scherer and Palazzo (2007, 2011) present a political CSR approach based on the Habermasian concept of deliberative democracy (Habermas 1996) with the goal of embedding the corporation in democratic processes of defining rules and tackling global political challenges. Although neither the literature on corporate citizenship nor on political CSR takes lobbying sufficiently into account, this literature is a useful starting point for a study on responsible lobbying by pointing to new corporate responsibilities, to questions about legitimacy, accountability and potential threats to democracy through increasing corporate power.

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Capturing the CSR field is not only challenging due to the number of diverse definitions, but also because related concepts such as stakeholder theory and sustainability have been developed that are similarly difficult to grasp. Stakeholder theory has been conducive to the field by contributing to a clarification which groups in society corporations should be responsible to. It argues that not only the interests of shareholders, but also the perspectives and needs of other key groups that have „a stake" in the modern corporation such as customers, employees, suppliers, communities and policy makers should be taken into account in corporate decision-making (Donaldson and Preston 1995, Freeman and et al. 2010, Freeman 1984). Stakeholders have been defined as "any group or individual who can affect, or is affected by, the achievement of a corporation's purpose" (Freeman 1984: vi). Yet, this broad understanding of stakeholders poses practical problems: Due to limited time, resources and cognitive capacity, managers can hardly attend to all, possibly conflicting interests of various stakeholder groups. Thus, one of the key challenges of stakeholder management is to identify the most relevant ones. Augmented attention to corporate responsibilities towards the environment has resulted in growing relevance of the sustainability concept. One of the most common definitions of "sustainability" has been introduced more than 25 years ago by the World Council for Economic Development (WCED) who defined sustainable development as meeting "the needs of the present without compromising the ability of future generations to meet their own needs" (WCED 1987). At the outset, the term sustainability was primarily used for the macroeconomic context, but now it is being increasingly applied to the individual and corporate level (Steurer et al. 2005). According to the triple bottom line concept, corporations need not only to strive for profitability, but also for environmental quality and social justice in order to be successful (Elkington 1998).

CSR overlaps with stakeholder theory and sustainability at several points, yet none of the concepts is superfluous, instead they are complementary, mutually reinforcing concepts. In the context of this paper, CSR is understood as a broad umbrella term (cf. Matten and Moon 2008: 405, Scherer and Palazzo 2007: 1096) that raises attention to corporate responsibilities towards society. Stakeholder theory provides a valuable framework for recognizing and managing the demands of key groups, but describes only one aspect of CSR since responsible actions do not only result from external demands, but also from intrinsic motivation. CSR and stakeholder theory are mostly firm-centered approaches. In order to understand and fulfil the responsibilities towards society, firms need to consider the objectives and values that are centered outside the firm, at the societal level. Sustainability helps to build "a bridge to important global societal issues" (Wheeler et al. 2003) and to raise attention to long-term impacts of today's actions on society and the environment. Moreover, societal values and objectives such as justice and human rights provide guiding principle for firms aiming to be responsible members of society.

Lobbying literature

Over the past few years, lobbying has increasingly drawn academic interest from a variety of disciplines such as political science, organization theory, management and communication studies. The range of approaches has led to some terminological confusion, which is further aggravated by the inconsistent use of related terms such as governmental relations, public affairs and corporate political activity (CPA). Hillman and Hitt (1999) provide a widely used definition of lobbying as the „provision of information to policy makers by individuals representing the firms interest" (Hillman and Hitt 1999: 834). This paper follows their approach insofar that corporate lobbying is treated as one component of the overall political strategy, separated from other political activities such as financial contributions. Yet, it is recognized that all of these activities are closely related and interdependent. Moreover, lobbying is not regarded as a one-way provision of information, but as a communications process that involves interaction and exchange (see Jaatinen 1997).

A substantial amount of literature has dealt with the question of why firms become politically engaged. Hillman and colleagues (2004) identify four categories of antecedents of corporate political activity: firm, industry, issue, and institutional factors. Beside the question of motivation, a second main topic are the strategies and tactics employed (Hillman and Hitt 1999, Vining et al. 2005, Schuler and Rehbein 1997). This includes the question of whether lobbying should be conducted by consultant lobbyists or in-house lobbyists. Some scholars distinguish individual from collective action: While industry associations have historically played a significant role in corporate lobbying, the growing magnitude and power of large firms has put them in the position to carry out a great deal of lobbying on their own behalf (Streeck and et al. 2006). A key assumption of most theoretical perspectives is that firms engage in lobbying in order to obtain economic returns (e.g. North 1990); however, empirical evidence has been mixed (Hillman et al. 2004) and lead to the conclusion that lobbyists have less control over the policy outcome than often assumed (Baumgartner et al. 2009).

While the drawbacks of lobbying, such as the risk of disproportionate influence on law-making, are not to be neglected; many scholars still recognize the legitimacy of corporate attempts to shape legislation, most notably the pluralist stream in political science literature that treats interest groups as an integral part of the democratic public policy process legitimately conveying the interest of their members to government officials (Dahl 1982). Traditionally, lobbying has been depicted as a primarily self-serving activity and as a process of competition and power struggle that still does not endanger democracy due to the balancing effect of competing lobbyists. Few scholars have argued that legitimate lobbying needs to be restrained by ethical standards (Grimaldi 1998, Hamilton and Hoch 1997), and have discussed issues such as lobbying regulation and legal requirements (Hogan et al. 2008, Holman 2009), and rules of conduct and codes of ethics (Weber 1997, Susman 2008, Barker 2008). Ethical issues are still marginal in lobbying literature, but the necessity to build understanding and trust between the lobbyists and the policy-maker is increasingly recognized as a prerequisite to gain access and to exert influence (Schendelen 2002: 267, Levine 2009). This development may help to leverage the acceptance of ethical restraints and incorporation of broader interests in lobbying.

Responsible Lobbying

Responsible lobbying has long been almost a blind spot both in CSR and lobbying literature, but interest on the issue is rising. Particularly NGOs and activists have started empirical research by investigating how companies report on lobbying (SustainAbility and WWF 2005) and by examining the role investors play in driving a more coherent approach between lobbying and CSR (Blueprint Partners et al. 2007). Among the few scholarly works, the study by Anastasiadis (2010) provides conceptual and empirical groundwork by investigating the auto industry's lobbying in the EU and elaborating on company-internal processes of lobbying seen from a deliberative perspective. A template of responsible lobbying that grasps the complexity of the issue has not been achieved so far. Limiting responsible lobbying to consistency with the firm's own policies and commitments might be an easy to operationalize approach, but implies the downside of taking a narrow firm-centered view. AccountAbility and The Global Compact (2005: 14) describe responsible lobbying as "being consistent with an organization's stated policies, commitments to stakeholders, and core strategy and actions" and "advancing the implementation of universal principles and values". This definition encompassing several dimensions provides a useful starting point in the strive for a comprehensive understanding of responsible lobbying, but needs theoretical substantiation and elaboration, as the reminder of the paper will endeavor to accomplish.

A multidimensional model of responsible lobbying

In the following, a multidimensional model of responsible lobbying is introduced that covers both the content and process of lobbying. It constitutes three modules describing and prescribing the content of responsible lobbying: Module (1) implies seeking coherence between the firm's own CSR commitment and lobbying. Module (2) applies stakeholder theory and claims that consideration of the perspectives and needs of stakeholders such as consumers, environmental and civic groups is necessary to achieve responsible lobbying. Module (3) calls for the alignment with the objectives and values of society and applies approaches such as sustainability, human rights and justice to substantiate the content. The model is complemented by the basis of responsible lobbying that needs to be an ethical, democratic, dialogue-oriented process. Below, the four parts of the model are presented, including justifications of their choice and a discussion of their exact meaning.

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Module (1): Consistency with the firm's own CSR strategy and action

When investigating the awareness and practice of responsible lobbying the first aspect to consider is whether the firm acts in line with its own standards. Thus, module (1) focuses on CSR policy, on the strategy and actions that firms undertake to manage social and environmental impacts and to ensure morally sound decisions and actions. A growing number of companies have explicitly embraced CSR in recent years and have developed clearly articulated and communicated CSR policies that are a result of deliberate decisions. There are huge differences regarding CSR practice, among firms, industries and regions. Core areas range from environmental concerns to the improvement of working conditions, engagement in community development and advancement of human rights. Some companies focus on philanthropy, others take account of negative externalities resulting from their operations (Crouch 2006: 1534). Various tools and techniques have been developed that help to manage the firm's responsibilities and guide the decision-making of individual actors, including corporate ethics programs and corporate codes of conduct, ethics training for employees, the set up of managers or whole departments in charge of CSR, and CSR auditing and reporting. Ideally, CSR is implemented organization-wide and considered in every corporate decision and action.

Companies need to integrate their CSR principles into lobbying and avoid any contradictions regarding the objectives, norms and values underlying the CSR policy and the content of lobbying efforts. A "test of coherence" between CSR policy and actions and lobbying content is feasible when CSR principles are concrete and clearly communicated, but often CSR principles such as "We respect human rights" leave leeway for interpretation. In the latter case it is important that the "spirit" of CSR principles is paid attention to and taken as a guideline for lobbying. Lacking coherency between the firm's own CSR policy and lobbying implies risks. For example, RWE npower, a large UK energy supplier, has been publicly castigated for having promised to improve its environmental impact while keep on lobbying against stricter environmental legislation, namely by opposing legislation that disadvantages (climate damaging) coal and oil plants and opposing some of the rules proposed by the EU on energy efficiency, notably against reusing the waste heat from new plants (Harvey 2012).

It is essential that lobbyists are aware of the firm's CSR policy and actions, understand and act according to these principles. Codes of ethics and ethical training programs for both in-house lobbyists and consultants help to raise awareness for ethical matters. An institutionalized corporate process is required to ensure responsible lobbying. Monitoring lobbying by CSR experts can improve consistency, as e.g. the British multinational tobacco company BAT tries by having regulatory engagement of subsidiaries monitored by regional CSR committees. A more comprehensive approach would to ensure collaboration between the CSR and lobbying function instead of one-way monitoring. Corporate leaders, lobbyists and CSR managers/departments need to be aware of any corporate decision and action relevant for CSR and/or lobbying, they need to be in a constant dialogue and cooperate closely to strive for consistency between CSR principles and policy positions. Issue management can become the basis for collaboration since identifying, analyzing and prioritizing external developments and thus helping the firm to „anticipate and respond to changes" is likewise relevant for strategic management, CSR and lobbying. Cooperation needs to be extended to developing policy position and a lobbying strategy so that lobbying is in line with the firm's responsibilities towards society.

Module (2): Consideration of Stakeholders Perspectives and Needs

Module (2) builds on stakeholder theory and claims that a firm should not only take its own standards into account, but the views of stakeholders and the potential impact of advocated policy positions on them. This necessity pertains to a range of stakeholders that have to be identified and categorized in a firm-specific, continuous process. Obviously, lobbying involves communicating with governmental stakeholders and paying attention to their ideas and needs is required simply in order to be heard. Additionally, any firm that strives for responsible lobbying must accept the interests of other stakeholder groups such as employees, consumers, environmental and civic groups and has to ensure that policy goals do not contradict their needs. In some cases, the interests of the firm and stakeholders go hand in hand, e.g. if excessive regulation implies decreasing profit for the firm, higher prices for consumers and loss of workplaces for employees as potential consequences. In other cases, the interests of stakeholders do not coincide with the immediate goals of the firm, but still need to be considered in order to maintain corporate legitimacy.

There are various possibilities to incorporate the interests of stakeholders in lobbying efforts. In some circumstances it might be sufficient to learn to understand stakeholders' behaviors, values, and backgrounds and factor them in when developing lobbying strategies, in other cases dialogue and collaboration will be more appropriate. While companies have increasingly recognized the importance of managing stakeholder relationships, interactions often take the form of a monologue instead of more "interactive, mutually engaged and responsive relationships" (Andriof et al. 2002: 9). Morsing and Schultz (2006) distinguish three types of communication strategies towards stakeholders (cf. Grunig and Hunt 1984): (1) The information strategy aims at informing objectively. In the lobbying context, this strategy has gained relevance, especially since the widely used GRI reporting guidelines include a set of indicators pertaining to lobbying. Reporting enhances transparency and allows for a critical assessment of the firm by its stakeholders, but does not supersede two-way-communication. (2) The stakeholder response strategy enables stakeholders to respond to corporate actions, e.g. through opinion polls or market surveys. Regarding lobbying, asymmetric two-way-communication helps to determine the views of stakeholders on politically relevant issues, to factor in their needs and to demonstrate that their perspectives are considered. But it implies an imbalance regarding the effects of communication in favour of the company. (3) The stakeholder involvement strategy allows for symmetric two-way-communication: The firm invites concurrent negotiation with its stakeholders to explore their concerns. Stakeholders are involved, participate and suggest corporate actions. Symmetric communication calls for an explanation of the firm's goals, consultation with stakeholders on policy choices, meaningful reflection on the dialogue, and finally determination of the lobbying strategy in line with the interests of the firm and its stakeholders. Some firms have started to move in this direction, and have held stakeholder dialogues or consulted stakeholder advisory groups on issues such as carbon regulation. A genuine dialogue increases reciprocal sensitivity and understanding, helps to manage risks such as damaging publicity and reputation loss and paves the way for concerted problem-solving. When firms are confronted with contradicting stakeholder demands, e.g. investors might have a different take on policy issues than consumers, an open dialogue helps to balance and reconcile the conflicting interests.

NGOs are an increasingly relevant stakeholder group that transmits the interests of broader society and calls for attention in the lobbying context. There is a wide range of different NGOs, but many try to change business behavior through tactics such as media campaigns, boycotts, shareholder activism and also through collaboration with firms (de Bakker and den Hond 2008, Doh 2008). NGOs influence public opinion, and their criticism, e.g. regarding inconsistencies between CSR policy and lobbying, endangers corporate reputation and legitimacy. Seeking information, interacting and cooperating with NGOs contributes to aligning the firm's policy goals with the interests of society. Collaboration requires compromise, but may be necessary to avoid public criticism. Additionally, cooperating with NGOs improves the chances to lobby successfully. Although NGOs often possess less financial resources than business organizations, they have become important players in the political sphere (Baur 2011, Joachim 2011, Betsill et al. 2007) and have potential to influence policy-making due to a high level of trust and expertise. Issue-specific lobbying coalitions with NGOs enhance the chances to impact legislation through amassed resources and augmented credibility, and thus have increasingly developed in the U.S. and the EU. Sometimes collaboration becomes institutionalized: business-NGO alliances such as the Canadian Clean Air Renewable Energy Coalition, the U.K. Aldersgate Group and the U.S. Climate Action Partnership (USCAP) have been lobbying for more comprehensive climate legislation in their respective countries.

Internal stakeholders also deserve attention in the lobbying process. In some countries, the legislative framework does not support a strong participatory role of employees in firms, in others employees have a codified right to be involved in corporate decision making. Regardless of the institutional setting, the effects of a proposed policy on employees need to be considered, and an active involvement beyond those working in the lobbying and CSR department should be strived for. Such a process leads to a broader perspective on politically relevant issues and helps to ensure responsible lobbying. A starting point for the involvement of internal stakeholders could be the development of a corporate code of conduct for lobbying based on a broad internal dialogue (Anastasiadis 2010: 215-16).

Module (3): Alignment with the objectives and values of society as a whole

Module (3) calls for the alignment of lobbying with the objectives and values of society. This obligation constitutes the most demanding part of the model: even firms that strive for meeting this requirement might have difficulties to determine, incorporate and reconcile society's objectives and values. Defining irrevocable societal objectives and values as guidelines for responsible lobbying is hardly possible, especially since globally operating, but also nationally focused corporations are confronted with diverse values and norms and pluralism from the outside and within the organization. Globalization and increased connectedness of economies and societies have both challenged and amplified the need for global moral norms. Some currently widely accepted, transcultural points of reference exist, such as justice, human rights and a sustainable development, that ought to guide corporate decision-making. Their meaning in the lobbying context will be briefly discussed in the following.

Fairness and justice are widely accepted values of society that should guide responsible lobbying, although what they precisely entail leaves leeway for interpretation. The relevance of justice has been recognized by legal and political theory that has applied the idea of justice as a main principle to evaluate law (cf. Weinberger 1991), and by CSR scholars who have grounded calls for incorporating justice in the business context based on ethical and philosophical theories such as Rawls' Theory of Justice (Rawls 1971, cf. Hsieh 2004, Cohen 2010, Phillips 1997). From a moral point of view, the firm ought to consider whether and how an advocated policy impacts justice, that is whether it levels or minimizes equality, the fair allocation of resources and disparities within the organization and in broader society. Lobbying on issues such as social security, gender policy, employees' rights, compensation and tax policy touches upon justice, equality and welfare and influences organizational justice, that is people's perceptions of fairness within the firm (Greenberg and Colquitt 2005). These impacts have to be born in mind in order not to risk legitimacy, even when the immediate self-interest of the firm prescribes a different policy stance. Many business decisions and activities have implications for global justice and wealth distribution between industrialized and less developed countries (Young 2008, Hsieh 2004, Hsieh 2009, Newell and Frynas 2007). Lobbying touches upon global justice in terms of trade policy, foreign aid and international agreements, and often results in conflicts between business self-interest and the responsibilities towards global society. For instance, several commodity and maritime organizations have asked the U.S. Congress to rule that the state program Food Aid purchases and delivers U.S. farm products instead of buying commodities on the world market and have been criticized due to the resulting inefficient use of assistance aid and dependence of poor countries (Grossman-Cohen 2012).

Particularly firms that operate across various legal, ethical and cultural systems will find human rights helpful to guide lobbying efforts. Human rights are not specifically located within the nation-state, but are global, "inalienable rights of all members of the human family" (UN General Assembly 1948). They are moral rights and have gained a legal basis through international covenants such as the Universal Declaration of Human Rights. The human right concept is not without ambiguity due to its non-binding, vague character and the primarily Western origin of the idea (Pollis and Schwab 1979). Yet, the protection of human rights has been increasingly accepted, not solely as the responsibility of states, but as a complementary corporate duty (Kobrin 2009, Wettstein 2012, Arnold 2010, Cragg 2010). Firms are called upon to guarantee that human rights are not violated through business decisions and activities and to ensure coherency of policy positions and human rights. Political rights constitute a major part of human rights and lobbying needs to be executed in a way that does not endanger the right of others to take part in political life. Companies may go beyond the minimum requirement to respect civil, economic, social and cultural rights and lobby actively for human rights policies. Information and communication technology firms such as Google, Microsoft and Yahoo have undertaken such a step by collaborating in the 2008 founded Global Network Initiative that urges governments to abstain from human right infringements especially regarding freedom of expression and privacy.

Environmental quality and inter-generational justice have become major public concerns, pointing to sustainability as a relevant reference point for lobbying. Ecological worries have brought forth national and global environmental regulation and have constituted new moral and legal responsibilities for corporations. Firms have repeatedly resisted environmental legislation, or have steered policy makers toward soft, market-based solutions (Kolk and Pinkse 2007). But many firms have started efforts to internalize environmental externalities and to support sustainable development covering issues such as air pollution, biodiversity, climate change, efficiency of resource use and waste management. Some have not only sought compliance with laws, but have actively promoted sustainability policies on the part of governments, for example the Corporate Leaders Group on Climate Change founded by chief executives of several large companies in the U.K that have lobbied for clearer policies for carbon emissions (Visser and Adey 2007).

The discussion of justice, human rights and sustainability and their implications for responsible lobbying is not meant to be comprehensive due to a range of further reference points such as welfare and freedom. Values and objectives are socially constructed and can be only provisionally defined through discourse. In light of their abstract nature, what they exactly entail needs to be concretized in any given situation. Consequences of any proposed policy have to be weighed ex ante. The question whether a specific policy benefits or harms the values and objectives of society will not always result in an unambiguous answer, especially when a conflict of various societal objectives arises. For example, high employment rates and environmental protection are considered to be desirable, but both come into conflict when strict environmental regulation threatens the competiveness of the economy. In such a case, the firm should engage in a public discourse to clarify which specific policy serves society better and thus may be lobbied for, without abusing the conflict of goals in the immediate firm interest, e.g. by raising unfounded public fears.

The basis: an ethical, democratic, dialogue-oriented process

A firm should not only seek compatibility between its responsibilities towards society and lobbying regarding content, but must ensure that the process of lobbying does not contradict ethical criteria or endanger the functioning of democracy. Both legal and ethical requirements need to be considered. A number of countries have provided lobbying regulation schemes, legal frameworks that aim at making lobbying more transparent and compliant to ethical rules. Approaches to regulation differ (Chari et al. 2007), but include mostly the registration of lobbyists, regulation on the movement of public employees into the lobbying industry and requirements for the disclosure of political donations, thus stretching not only to lobbying in the precise definition underlying this paper (as provision and exchange of information), but including other political activities such as financial contributions.

Firms need not only to follow these legal requirements, but should establish an ethical, democratic dialogue with policy-makers. Companies have increasingly recognized the importance of trust and reputation among policy-makers in order to be treated as credible players in the lobbying field. As a prerequisite for building trust, firms need to provide balanced, reliable information, eschew ethically doubtful methods such as manipulation and deception and seek a genuine dialogue. Besides instrumental considerations, the need for an ethical, dialogue-oriented process of lobbying is normatively justified by ethics of dialogue like the discourse ethics developed by the German philosopher Jürgen Habermas. Habermas propagates communicative action, that is an exchange of communicative acts aiming at mutual understanding, rational agreement, or consent, as opposed to strategic action designed to achieve private ends without seeking mutual understanding (Habermas 1985). Discourse ethics and deliberation have been suggested to guide firms especially when engaging with stakeholders (Zakhem 2008, Scherer and Palazzo 2011, Scherer and Palazzo 2007, Gilbert and Rasche 2007, Foster and Jonker 2005, Smith 2004), but also for lobbying processes (Anastasiadis 2010). Habermas' ideal of an equal, power-free dialogue among all affected parties seems hardly reconcilable with lobbying that is traditionally characterized as power-oriented, opaque, and self-serving. Yet, discourse ethics deliver moral principles that help to design the lobbying process in a responsible way. Firms need to strive for a way of communicating with policy-makers that comes close to the Habermasian idea of an open discussion where no force but that of the better argument prevails (Habermas 1990). Means such as deception, coercion or threats are neither compatible with discourse ethics nor with the goal of establishing a trustful relationship with policy-makers. An ethical dialogue may be achieved by explaining the firm's position, listening and considering alternative arguments, giving earnest responses and convincing with the aim of facilitating broadly accepted decisions and mutual understanding. Such an approach corresponds to symmetric two-way-communication implying joint-creation of meaning by policy-makers and the firm (Crane and Livesey 2003: 48-49). If the firm succeeds in symmetric two-way-communication - which will not always be possible, e.g. if the policy-maker is not willing to engage in a dialogue -, the lobbying process gains moral quality, and it becomes more likely that the outcome serves the interest of all parties involved.

Several challenges remain for firms that strive to reconcile discourse ethics and lobbying. First, while a truly ethical dialogue requires that the better argument prevails, power relations are present in the policy-making process and they often impact the leverage of an argument. The power of corporations, especially large multinational corporations (MNCs), has heavily increased in the wake of globalization, deregulation and privatization and is reflected in immense resources and revenues and the considerable influence over people's lives. Although increased power goes along with increased responsibilities, firms may be tempted not only to use, but to abuse their power in the lobbying process. How much influence lobbyists exert depends on their resources, such as financial and informational resources (cf. Dür 2008: 1214). Providing financial incentives does not necessarily equate to bribery, but also refers to legal contributions, e.g. in the case of the widely spread political action committees (PACs) in the U.S. Even legal contributions are morally questionable if they facilitate access to policy-makers and thus curb democratic participation opportunities. Providing information to policy-makers may contribute to balanced policy-making, but firms need to abstain from abusing any informational advantage over policy-makers by misrepresenting or selectively providing information. Firms may be tempted to hinder legislation by adverting policy-makers to the possibilities of relocating production and pointing to probable job losses in case of stricter regulation. While the firm must be allowed to point out real risks, arguments that take the form of threats clearly violate discourse ethics and thus are inacceptable.

When seeking ethical, dialogue-oriented lobbying processes another major challenge arises from the Habermasian ideal of a free discussion among all affected. As noted above, responsible lobbying implies not only communicating with policy-makers, but whenever possible, an additional, broad dialogue with internal and external stakeholders needs to be established, thus adding democratic value to the process. Hitherto, firms rather tend to avoid public policy debates, often based on the argument that an issue is too complicated to be understood by non-experts. Technically highly complex issues do not release the firm from its responsibility to seek understanding, but rather call for explaining the matter in a balanced, comprehensible way to stakeholders. Yet, a broad dialogue is hampered when stakeholders refuse a constructive debate, namely confrontationalist NGOs who prefer to exploit scandals and exercise protest, or when confidential information is involved.

While deliberation promotes publicity as a remedy to civilise politics, indefinite transparency is not always possible or desirable in policy-making. Past research has shown that compromise becomes less likely in a public setting, since lobbyists and policy-makers fear to be accused of giving in too early (Naurin 2007). Opacity allows for greater flexibility, honesty and trust in the interactions between policy-makers and business (Anastasiadis 2010: 55-57), and facilitates effective problem solving. On the other hand, the democratic involvement of stakeholders necessitates publicly available information which can be achieved e.g. by publicizing position papers and explaining policy positions in CSR reports. There is no general rule for the appropriate level of transparency: firms have to balance the necessity to involve affected parties and to keep specific information private on a case-by-case-basis. When a certain degree of opacity is inevitable, considering what the reaction would be if the company's lobbying activities were to be publicized may help to ensure a responsible approach (cf. Hamilton and Hoch 1997).

Critical review of the model

The model is not flawless and critics might question the choice and compatibility of its various parts. The modules and the basis are all highly interdependent, yet none is redundant. While the alignment of the firm's CSR policy and lobbying is a concrete, firm-oriented and utile reference point for responsible lobbying, Module (1) is not sufficient. Firms that lack a clearly articulated CSR may still act responsibly due to institutional conditions or internalized values. Others might have a CSR policy, but neglect stakeholder demands, societal interest and the need to engage in an ethical dialogue. Module (2) is essential to concretize needs and perspectives of key groups towards the firm. Nonetheless, some stakeholders are more likely to be heard than others and non-humans and future generations cannot raise a voice at all. Although the firm's CSR policy should be based on the values and objectives of society and incorporate stakeholder needs, Module (3) is required since it allows for departing from a mere firm-centric view. Finally, the requirement of an ethical dialogue ensures that the lobbying process is responsible. One might argue that deliberation makes the values and objectives of Module (3) superfluous. Yet, an appropriate procedure does not render ethical standards unnecessary, but implies that reference points such as justice are to be identified and justified through public moral discourse (Ellis 2004). The modules might constitute conflicting criteria, e.g. when stakeholders demand short-term benefits that contradict sustainability. In such cases, the firm must engage in a public discourse in order to find a solution that balances conflicting requirements.

Admittedly, there are limits regarding the practicability of the model. It provides guidelines for responsible lobbying, but still leaves unavoidable leeway for interpretation in concrete situations. Looking at current practice, fulfilling all the requirements is a challenging, if not unreachable demand towards firm. However, there is no definite separation line between responsible and irresponsible lobbying. Responsible lobbying is not to be tested in a dualistic yes/no-approach, but rather on a continuum scale with various degrees of fulfillment. Some firms might fail regarding all requirements, others will perform well at one and fall short at another. The model enables firms to determine their weaknesses and strengths and detect areas that necessitate further learning and development.

7. Conclusion

The above presented multidimensional model of responsible lobbying provides a better understanding of the subject with due regard to its highly complex nature. The paper contributes to a newly emerging field of research that integrates CSR and lobbying literature for the benefit of both fields. The model lays the basis for determining the degree of responsible lobbying in practice and it is of normative value, as it constitutes what firm ought to do. Further studies are required that investigate empirically the current awareness and practice of responsible lobbying. The paper may also trigger theoretical and empirical research on antecedents of responsible lobbying, on internal and external factors that facilitate responsible lobbying such as the institutional setting, issue and firm characteristics.

Presumably, critical voices both among CSR and lobbying scholars will raise doubts whether an alignment of CSR and lobbying is necessary, feasible and/or recommendable. Some will argue for the sole responsibility of policy-makers to serve society's interest and to ensure fair legislation and will point out the needlessness of ethical-normative guidelines for business, since self-serving lobbying is counterbalanced by rival lobbyists so that the final policy outcome is automatically fair. This perspective neglects corporate power and the possibly unequal influence over policy-making. Another party might detect an oxymoron due to the alleged inherently selfish, irresponsible nature of lobbying. But since many corporations do lobby and will continue to influence policy-making as long as influential political authorities exist, it is more reasonable to strive for a responsible way of lobbying instead of ignoring the issue. Moreover, CSR will profit from an integrative approach: Responsible lobbying is not only about guiding or constraining lobbying, lobbyists that constantly scan the environment and communicate with policy-makers have the knowledge and capability to help to identify issues that affect and challenge the firm and to contribute to meeting societal responsibilities.

Several trends facilitate the prospects of responsible lobbying. First, many firms recognize the importance of reputation, legitimacy and thus launch CSR programs and engage in stakeholder dialogue. Second, while the relation between self-interest and societal interest can be conflict-prone in lobbying (and in that case firms are called upon to avoid inacceptable costs for society while pursuing legitimate self-interest), in other cases both will harmonize. For instance, "green lobbying" has been leveraged by the benefits that environmental legislation provides for an increasing number of firms that gain competitive advantage or profit due to a green business concept, such as the renewable energy industry. Moreover, stakeholders and the broader public play an increasingly important role for business lobbyists: Due to the potential of NGOs to influence policy-making, enhanced transparency and mobilization potential through the Internet, coalition building and grassroots lobbying, that is advocating through mass mobilization, have become common tactics. Both grassroots lobbying and coalition building necessitate compromise and facilitate responsible lobbying - at least as long as firms do not fall in the trap of creating fake Astroturf organizations to mimic true grassroots.

Literature

Table 1: The multidimensional model of responsible lobbying