As predicted in previous reviews, the question of corporate lobbying began to enter the mainstream of corporate citizenship in the first half 2003. One aspect of this was the increasing interest of citizens groups on the matter. Friends of the Earth hit out at Shell's Phil Watts who, as the chair of the International Chamber of Commerce (ICC), was accused of "anti-accountability lobbying." This was after the ICC had launched a campaign against the Alien Tort Claims Act in the US, with the UK branch declaring this as a major plank of its lobbying operation in the UK. 23 Soon after, in report on the state of sustainability reporting, the first technical recommendation from the judges of the main accountancy body of the UK was that "reports should disclose the lobbying positions an organisation takes on key public policy issues." 24

Such concerns are already covered to a limited degree in the OECD Guidelines for Multinational Enterprises. The 5th general policy principle says that such companies should "refrain from seeking or accepting exemptions not contemplated in the statutory or regulatory framework related to environmental, health, safety, labour, taxation, financial incentives, or other issues." This could be interpreted to mean much more than bribery, and include lobbying for various exemptions such as those provided in free trade zones, and weak monitoring and enforcement of various laws. The 11th general policy principle states that corporations should "abstain from any improper involvement in local political activities": the key issue being what might constitute "improper". On environmental issues, the Guidelines are clearer, with point 8 stating that corporations should "contribute to the development of environmentally meaningful and economically efficient public policy, for example, by means of partnerships or initiatives that will enhance environmental awareness and protection." 25

As mentioned above, the ability of the OECD code to ensure responsibility and accountability is questioned. Therefore, others factors will be important for making the political activities of companies a mainstream part of corporate citizenship. Given the particular power of investors, the 2003 revised guidelines for ethical investment, developed by the Interfaith Centre on Corporate Responsibility (ICCR) mark a significant development. The new guidelines incorporate criteria on political lobbying, such as "The company has in place a system of review that aligns and integrates its corporate social responsibility principles in relation to its lobbying activities at all levels" and "The company establishes participatory structures representative of all stakeholders to ensure compliance with its lobbying policy." The criteria are not explicit about whether they cover the lobbying activities done on behalf of companies by their trade associations and other bodies of which they are members. Nevertheless, a member of the Ecumenical Committee on Corporate Responsibility (ECCR) told us that they had already used the guidelines in their discussions with a major pharmaceutical company.

Meanwhile, in March, a coalition of European investment funds with $943 billion under management included recommendations on lobbying in their statement calling on pharmaceutical companies to take swift steps to ensure that poor countries have access to essential medicines. This call was coordinated by ISIS Asset Management and the Universities Superannuation Fund, who were behind a similar initiative two years ago to place pressure on oil companies doing business in Burma, and a current initiative to address global climate change. Specifically the statement suggested that companies use their influence with governments to address the public health crisis in the global South, and also being both transparent about, and assessing the impact of, their public lobbying positions on national and international trade law relating to intellectual property. The suggestion was that major risk management issues are arising from the lobbying positions taken.26

The increasing focus on the political activities of corporations means that corporate citizenship might increasingly be seen as necessarily including support for governments and intergovernmental agencies to intervene in markets. Given the need for all companies to change if we are to promote sustainable development, voluntary corporate responsibility need not, perhaps by definition should not, be "voluntarist" and promote de-regulation. Indeed, we may increasingly consider that the highest form of responsibility is to work for accountability.