GRI 415: Public Policy 2016 · Topic Standard · Cross-sectoral
Disclosure GRI 415-1
Political contributions
Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.
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Reviewed by
Dr Ross Kurinko · GRI Certified Trainer
To prepare this disclosure
4 datapoints ↓
4 claims to verify ↓
5 evidence areas ↓
3 report examples ↓
Disclosure focus
This disclosure asks an organisation to explain whether it has made any political contributions during the reporting period, and if so, to set out the amount and nature of those contributions in a way that is clear and complete. The focus is on transparency: users should be able to see what was given, to whom or for what purpose, and whether the organisation has any policy or controls around such activity.
In practice, the key question is coverage across the whole organisation, not just head office or a few visible sites. The report should capture contributions made directly or through other parts of the business, so the disclosure reflects the organisation’s full position rather than a partial or flagship-only picture.
* This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
| Datapoint | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Contribution countries | List every country where the organisation has made political contributions, whether the payment or support was given straight to the recipient or through another party. | Political donations register, finance postings, approvals, and any intermediary records that show the country linked to each contribution. | Finance / Public affairs |
| Recipient details | Record who received the contribution or who ultimately benefited from it, using the named person or organisation and enough detail to identify them clearly. | Donation request forms, beneficiary declarations, payment instructions, and correspondence confirming the recipient or end beneficiary. | Public affairs / Legal |
| Political contribution total | Add up the full money value of all political contributions made in the period, including cash and non-cash support, and include both direct and routed-through-another-party amounts. | General ledger, donation logs, in-kind valuation schedules, third-party payment records, and consolidation workings showing the full total. | Finance |
| In-kind valuation method | Explain the method used to put a money value on non-cash political support, including the basis, inputs, and any assumptions used when that estimate was needed. | Valuation memo, pricing basis, internal calculations, supplier quotes, and approval notes for the estimate. | Finance / Public affairs |
Show GRI 415-1 sub-elements (LRA working checklist)
- List the countries where the contributions were made.
- If relevant, explain how you worked out the cash value of any non-cash support.
- Name the person or organisation that received the contribution or benefit.
- State the full monetary amount of political contributions, both cash and non-cash, made through direct and indirect routes.
LRA working checklist - paraphrased; see official source
How to prepare
- Set the reporting boundary first: decide which political payments, gifts or support items sit inside the period and which entities, channels and transactions you will include in the disclosure.
- Create a clear classification rule for what counts as a political contribution in your process, so direct payments, routed support and non-cash items are treated consistently.
- Gather source records for each item: identify the country involved, the recipient or beneficiary, and the supporting documents that show the amount or the basis used to calculate it.
- Compile the reported figures and narrative in one place, including the total monetary value of all included financial and non-cash contributions, with the in-kind amount shown where relevant.
- Record any exclusions, estimation methods and changes in approach, especially where the value of non-cash support has been derived rather than taken from a direct invoice or payment record.
- Check the draft against the official source and your evidence pack to confirm the countries, recipients, totals and estimation notes are complete, consistent and traceable.
Request the political contributions record from the relevant owner
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What political contributions were made in the reporting period, to whom, in which countries, for what total value, and how were any non-cash amounts estimated?
Use your organisation’s own terms first, then map them to this disclosure. For example, ask for the political donations, party support, campaign support, lobbying-related gifts, or other civic payments your teams already track, rather than using framework language in the request. This is a possible LRA training template only; adapt it to your organisation and check the official source before sign-off.
Weak request
Please provide the political contributions disclosure data for the year.
Why it fails: This is too vague for the owner to act on. It does not say which records to pull, which fields are needed, whether non-cash items matter, or what evidence should accompany the data. It also uses framework language without giving the team a practical internal framing.
Better request
Please send the political donations / party support / civic payments register for [reporting period] for [entity / boundary]. For each item, include the country, recipient name, cash or non-cash status, amount and currency, and the method used to estimate any non-cash value. Please also attach the source record or file reference and use your team’s own labels so we can map them for reporting.
Formal email template
Subject: Data request for political contributions reporting Hi [name], I’m pulling together the data pack for [reporting period] and need your help with the organisation’s political contributions records. Please send the following for [entity / business unit / boundary]: - each contribution made in the period - the country where it was made - the recipient or beneficiary name - the amount and currency - whether it was cash or non-cash - if non-cash, the method used to estimate the value - the source record or evidence reference for each item Please use the terms your team already uses internally, and include any notes needed so we can map the items correctly for reporting. This is a possible LRA training template only; please adapt it to your organisation and check the official source before sign-off. If it is easier, you can return the information in the table format below. Thanks, [preparer name]
Short Teams / Slack version
Hi [name] — could you send the [reporting period] political contributions record for [entity / boundary]? Please include country, recipient, cash/non-cash split, amount, and any non-cash valuation method, plus the source reference. Use your team’s own labels and I’ll map them for reporting. Thanks.
Industry examples
Consumer goods
Context. A group public affairs team tracks donations to local political organisations and occasional non-cash support such as venue hire.
Adapted request. Please share the public affairs support log for [reporting period] covering [entity / boundary]. For each item, include the country, recipient, whether it was cash or in-kind support, the value, and how any in-kind value was estimated. Please add the source reference for each entry.
Example response. A table showing 4 entries: 3 cash donations and 1 venue hire contribution, with country, recipient, GBP value, direct/indirect flag, and a note that the venue hire was valued using the contracted market rate.
Infrastructure / utilities
Context. A government relations team records political engagement spend separately from charitable giving and sponsorships.
Adapted request. Please provide the government relations spend log for [reporting period] for [entity / boundary], limited to political contributions and similar support items. Include the country, recipient, amount, currency, whether the item was cash or non-cash, and the valuation basis for any non-cash item. Please include the ledger or approval reference for each line.
Example response. A spreadsheet with 2 cash payments and 2 non-cash items, each tagged to a country and recipient, with a valuation note for staff time and event space based on internal cost allocation.
The full request pack — response form, data table, evidence metadata and sign-off — is in the Download Centre.
Draft your disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Explain how you defined political contributions for this disclosure, how you separated direct from indirect support, and the basis used to estimate any non-cash items.
Context note
Set out what the figures represent in practice, including the total amount given and how the split by country and recipient helps readers understand where the support went.
Fluctuation statement
If the figures moved materially from the prior period, describe the main drivers, such as changes in countries covered, recipients supported, or the mix of cash and non-cash contributions.
Content index entry
GRI 415-1 Political contributions — [location / page] / [notes]
Download Centre
Professional preparation tools and forms for GRI 415-1. Each download includes a concise “How to use” guide.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| We prepared the coverage figure by listing the countries linked to the relevant payments and checking that the country names matched the underlying records. | An assurer may question whether the country list is complete, whether any payments were missed, or whether locations were assigned consistently where records were unclear. | Source ledger extracts, payment approvals, supplier or recipient records showing country, mapping notes for any indirect payments, and a reconciliation from the source data to the published country list. |
| We identified the named recipient using the supporting transaction records and kept the basis for that identification on file. | An assurer may probe whether the recipient was named consistently, whether intermediaries were handled correctly, and whether the published label could be traced back to the source documents. | Contracts, invoices, payment instructions, correspondence, beneficiary registers, and a working paper showing how the recipient name used in the report was derived from the source evidence. |
| We calculated the reported amount from the full set of relevant payments, combining cash and non-cash items and checking the total before publication. | An assurer may test whether the total includes all relevant items, whether direct and indirect amounts were both captured, whether the arithmetic is correct, and whether any exclusions were justified. | Calculation workbook, general ledger extracts, journal entries, supporting schedules for cash and non-cash items, consolidation or aggregation notes, and a review sign-off showing the final total was checked. |
| Where we had to value non-cash items, we used a documented method and kept the assumptions, inputs, and review trail. | An assurer may challenge whether the valuation method was reasonable, whether the inputs were supportable, whether the same approach was used consistently, and whether the estimate was reviewed before release. | Valuation methodology note, pricing references or other input evidence, assumptions log, internal review comments, approval records, and any sensitivity or reasonableness checks performed before publication. |
Evidence pack to prepare
- The governing policy or written commitment behind this disclosure
- A methodology / definition note setting out how the disclosure was scoped and prepared
- Source-system exports the figures or facts were drawn from
- The internal approval / sign-off record for the disclosure before publication
- Minutes or records evidencing the relevant engagement or consultation
Common reporting gaps
- Figures are stated without the supporting narrative, or narrative without figures.
- Scope is inconsistent between the text and the numbers.
- The reporting boundary is left undefined.
- Material changes since the previous period are not disclosed.
- Estimates and measured values are not distinguished.
- Source records for the figures are not identified.
Mistakes to avoid when collecting the data
- Wrong owner
Chasing the wrong team for the figures means the data owner cannot confirm where the contributions were booked or who the recipient was.
- Framework language first
Asking for the data in reporting-framework terms instead of the business’s own labels leaves people unsure which ledger, register, or approval record to pull.
- No scope set
Failing to define which political payments sit inside the collection boundary leads to some entries being included twice and others being missed.
- Period mismatch
Using a different cut-off date from the one used in the source records produces totals that do not match the underlying transaction set.
- Mixed counting basis
Combining cash amounts with estimated non-cash values without separating the two makes the total impossible to trace back cleanly.
- Source labels lost
Copying the numbers without keeping the original country, recipient, and record labels removes the trail needed to check each line item.
- Merged populations
Putting direct payments and routed-through-another-party amounts into one bucket too early hides which figures belong to each source path.
- No estimate trail
Recording an in-kind estimate without the working papers, assumptions, and sign-off means nobody can see how the figure was built.
- No evidence sign-off
Collecting the data without a dated review trail leaves no proof that the figures were checked before the disclosure text was drafted.
Where judgement is often needed
- Acquisitions and disposals during the year
Decide whether to include amounts from businesses bought or sold part-way through the period, and explain the cut-off you used so the country list and total value match the reporting boundary you applied.
- Different local meanings of a political payment
Where country practice treats a payment as political in one place but not another, use a consistent internal rule, note the local variation, and explain how you classified each case.
- Direct and routed-through-third-party support
Separate payments made by the organisation itself from support given through another party, then disclose both the combined total and the basis used to identify indirect support.
- Who counts as the recipient or beneficiary
If a payment benefits more than one party or the named recipient is unclear, choose a clear naming approach, explain it, and keep the same approach across all countries.
- Estimating non-cash support
When a non-cash item cannot be measured exactly, use a reasonable valuation method, state that it is an estimate, and describe the inputs and assumptions behind it.
- Timing around year-end approvals and payments
Set a consistent rule for whether you record a contribution when approved, committed, delivered, or paid, and explain that timing basis if it affects the reported total.
- Small amounts and rounding
Apply one rounding approach to the monetary total and any country breakdowns, and make sure the rounded figures still reconcile to the underlying records.
- Privacy limits on naming recipients
If naming an individual or small group would create a privacy issue, aggregate the information only as far as needed, explain the limitation, and keep enough detail for the disclosure to remain useful.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Consumer goods · synthetic · written by LRA
This example shows how to describe where the support went, who received it, the combined value of cash and non-cash support, and the method used to value the non-cash element.
Synthetic illustration only. We recorded political support in two places: the UK and Germany. The recipient was a national political party in each case, and the total value across direct cash support and donated services was £180,000; this comprised £150,000 paid directly and £30,000 given through a trade association. For the donated services, we estimated value using the external market rate for comparable advertising and event support at the time it was provided.
Transport and logistics · synthetic · written by LRA
This example shows a second way to present the same disclosure points, using different countries, a different recipient type, and a different approach to valuing in-kind support.
Synthetic illustration only. Our group made political contributions in Canada and Australia, all to local election campaign committees. The combined amount was CAD 92,000, made up of CAD 70,000 given directly and CAD 22,000 provided indirectly through an industry body. We valued the non-cash support by using the amount we would have paid a third party for the same promotional materials and venue hire.
Draft output & visualisation ideas
How to turn the collected data into a draft disclosure. Suggested visuals and a GRI content-index line generated from this disclosure's datapoints.
Suggested visuals
- Where the contributions were made — map: A country-level view of the places where the organisation made political contributions, so readers can see the geographic spread at a glance.
- Who received the support — table: A simple listing of each recipient or beneficiary alongside the related contribution amount and whether it was direct or indirect.
- Total value by contribution type — stacked bar: A split of the overall monetary total into cash and non-cash support, showing how much of the total came from each type.
- Contribution value by country — bar: A comparison of the monetary value of contributions across countries, helping highlight which locations account for the largest amounts.
- Recipient and country summary — table: A combined summary that links each beneficiary to the country involved and the value attributed to that recipient.
From a number to a disclosure
What separates a figure from a disclosure.
Basic
We made political contributions totalling £12,000.
Better
We made £12,000 of political contributions in the UK to a trade association, with £9,000 in cash and £3,000 in donated staff time.
Best
We made £12,000 of political contributions during 2025 in the UK to a trade association, with £9,000 paid and £3,000 valued from staff time using our standard hourly cost, and the increase from last year reflects a one-off campaign support payment.
Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 415-1 — these are report practice, not exact disclosure examples.
| Company | Sector · Country | Year | Match | Page | Report | Assurance | ||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
 |
Indra Sistemas, S.A. | Software and Services · Spain | 2025 | Partial | p. 169 →p. 209 →p. 49 → | Sustainability Report 2025 → | — | |||||||||||||||
Evidence in Indra Sistemas, S.A.’s reportWhat the report shows Indra Sistemas, S.A.'s Sustainability Report 2025 includes a reference to ESRS S1 on page 259 and provides monetary values related to political contributions, donations, and sponsorships on page 209, with further details linked to regulatory frameworks. Additionally, estimated emissions accounting for 7% of total emissions based on transport distances are reported on page 255. However, there is no clear narrative or detailed explanation found elsewhere in the report to elaborate on these disclosures.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
|
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Abertis | Ground Transportation — Highways and Railtracks · Spain | 2024 | Partial | p. 256 →p. 257 →p. 260 → | Abertis Annual Report 2024 → | KPMG | |||||||||||||||
Evidence in Abertis’s reportWhat the report shows Abertis' 2024 Annual Report includes a narrative on taxes collected that do not affect profit or loss but are collected by the company, found on page 202. The report also provides workforce distribution data by gender and working time on page 224, and financial contributions related to currency impacts on the consolidated balance sheet on page 303. However, there is no clear or quotable evidence found elsewhere in the report specifically addressing other aspects of the disclosure, leaving some elements unclear or missing.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
|
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JB Financial Group Co., Ltd. | Banks / Diverse Financials / Insurance · South Korea | 2024 | Partial | p. 133 →p. 111 →p. 21 → | JB Financial Group 2024 Integrated Report → | KMR; Korean Standards Association | |||||||||||||||
Evidence in JB Financial Group Co., Ltd.’s reportWhat the report shows JB Financial Group's 2024 Integrated Report provides specific data on social contributions, including the number of subscribers to low-cost demand deposit accounts for microbusinesses (33,749 in 2024) on page 90, and monetary values for total contributions and other expenditures, which increased from KRW 3,621 million in 2022 to KRW 4,317 million in 2024 (p.89). The report also notes a reduction in domestic Scope 1 and 2 greenhouse gas emissions by 1,184 tCO2eq compared to 2020 (p.21). However, there is no clear or quotable evidence found regarding other narrative disclosures, and some sustainability policy details are referenced but not elaborated within the provided pages.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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Check your understanding
A group finance team has found two political donations during the year: one paid directly to a party in Country A and one made through a trade association in Country B. The amounts are £12,000 and £8,000, and the team also has a small in-kind support item valued at £2,000.What should the preparer pull together for the disclosure so the report covers the full picture of these contributions?
Model answer. They should capture the countries involved, identify who received or benefited from each contribution, and total all political support given both straight from the organisation and through another route. In this case, the combined value is £22,000, made up of £12,000 + £8,000 + £2,000. If any part was given in goods or services rather than cash, they should also explain how that non-cash value was worked out.
Why this matters. The disclosure needs both the places and recipients, plus one combined value for direct and indirect political support, with a method for valuing any non-cash element.
A subsidiary in Country C paid £5,000 to a local election fund, while the parent company paid £15,000 to a national political group in Country D. The group reporting team is unsure whether to show only the parent company’s payment because the subsidiary is separately managed.Should the preparer include both payments, and how should they be presented?
Model answer. Yes. The reporting should cover political contributions made by the organisation whether they were paid straight from the parent or routed through another group entity, so both payments belong in the total. The preparer should list the countries, name the recipient or beneficiary for each payment, and present the combined amount as £20,000.
Why this matters. Indirect support still counts, so group-wide political payments need to be captured together rather than only the parent’s direct spend.
The organisation gave office space and printing support to a campaign group, and the team has estimated the value at £3,400 using the normal commercial rental rate and standard print charges. There was no cash payment for this item.What extra explanation should the preparer include alongside the amount?
Model answer. They should explain the approach used to turn the non-cash support into a money value, such as the rates or pricing basis used. The report should show the £3,400 estimate and make clear that it is an in-kind contribution valued using the organisation’s chosen method.
Why this matters. When political support is not cash, the valuation approach needs to be described so readers can understand the figure.
During review, the preparer finds a £1,000 payment to a local political committee in Country E, but the beneficiary name is missing from the source file. The payment is otherwise supported by bank evidence.Can the disclosure be completed with only the country and amount, or does the missing beneficiary detail need to be resolved first?
Model answer. The beneficiary detail needs to be resolved before sign-off. The disclosure is not complete without identifying who received or benefited from the contribution, so the team should trace the payment record or other evidence until the recipient can be named and the country and amount can be reported together.
Why this matters. A country and amount alone are not enough; the recipient or beneficiary must also be identified.
Analyse this disclosure across real reports
See how companies actually report GRI 415-1 — drawn from their own published reports, with the exact pages, and an LRA AI-assistant that works through it with you. Available to LRA Community members and to students throughout their platform access.
Related framework references
How this disclosure maps across the major reporting frameworks.
Related & explore
Questions this page answers
What do I need to gather to draft GRI 415-1 Public Policy for this page?
Use the page’s plain-language explainer and the datapoints list as your starting point: contribution countries, recipient details, political contribution total, and the in-kind valuation method. The step-by-step preparation section then helps you turn that into a draft disclosure. ↑ section
How do I decide the scope for GRI 415-1 Public Policy on this page?
The page is set up to help you define scope through the preparation steps and the datapoints to prepare. Use those prompts to decide which contribution countries, recipients and contribution types are in scope for your draft. ↑ section
What evidence should I collect for GRI 415-1 Public Policy to be assurance-ready?
The page includes an evidence pack with five items and four assurance claims to verify, each with a claim, risk and evidence prompt. Together these are meant to help you build a file that supports review and assurance. ↑ section
How do I evidence the valuation method for in-kind political contributions in GRI 415-1?
The page flags in-kind valuation method as one of the datapoints to prepare, and the assurance section asks you to link claims to evidence. Use the workbook and evidence pack to show how the valuation was determined and where the supporting records sit. ↑ section
What should I put in the recipient details for GRI 415-1 Public Policy?
The page tells you to prepare recipient details, but it does not add extra definitions or a fixed template. Use the preparation section and the example disclosures to shape a clear, consistent draft based on the information you actually hold. ↑ section
Who should own the data for GRI 415-1 Public Policy in my organisation?
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the person or team that can collect and evidence the datapoints. The workbook is there to help you assign and track that work. ↑ section
How do I use the Prep & Assurance workbook for GRI 415-1 Public Policy?
The Download Centre includes a Prep & Assurance workbook in .xlsx format to support preparation and assurance readiness. Use it alongside the step-by-step guidance, evidence pack and common gaps list to organise the disclosure and supporting records. ↑ section
What are the common mistakes to avoid when reporting GRI 415-1 Public Policy?
The page includes a list of common reporting gaps and mistakes, so it is intended to help you spot missing or weak areas before drafting. In practice, check that your data, valuation method, evidence and narrative all line up. ↑ section
Can I use the synthetic example on the GRI 415-1 Public Policy page as a template?
Yes, but only as an illustrative guide: the page says the examples are synthetic and the quantitative table is there to show how a disclosure might look. Use it to shape your own draft, not as a source of real figures. ↑ section
What does the draft-output section give me for GRI 415-1 Public Policy?
The draft-output section provides visualisation ideas, narrative starters and a GRI content-index line. That makes it easier to turn your collected data into a first-pass disclosure for review. ↑ section
More questions this page can help with
- GRI 415-1 Public Policy checklist: what data points, evidence and workbook tabs do I need?
- How do I build an assurance evidence pack for GRI 415-1 Public Policy?
- What should a first draft of GRI 415-1 Public Policy include?
- How do I avoid common reporting gaps in GRI 415-1 Public Policy?
- Where do I find example disclosures for GRI 415-1 Public Policy on the page?
- How do I turn GRI 415-1 Public Policy data into narrative and a content-index line?
- What is the role of contribution countries in GRI 415-1 Public Policy data collection?
- What recipient information is needed for GRI 415-1 Public Policy?
- How should I document the in-kind valuation method for GRI 415-1 Public Policy?
- What does the printable Library Card PDF help with for GRI 415-1 Public Policy?
- How do the assurance claims on the GRI 415-1 Public Policy page help a reviewer?
- Is there a real company report example for GRI 415-1 Public Policy on the page?
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Sources, status and disclaimer
This LRA assistance tool is designed for educational and internal data-collection purposes. It is not an official interpretation of the GRI Standards, IFRS Sustainability Disclosure Standards or EU CSRD/ESRS requirements. When applying these frameworks in professional practice, users should consult and double-check the official standards, guidance and applicable regulatory sources.
