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GRI 415: Public Policy·Disclosure GRI 415-1

Political contributions

Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official Global Reporting Initiative source.

Legal status

GRI 415: Public Policy 2016 remains the applicable published GRI Topic Standard and is effective for reports or other materials published on or after 1 July 2018.

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Published passport

Last reviewed 2026-08-03
RK Reviewed by Dr Ross KurinkoLinkedIn Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert 15+ years on FTSE 100 & Fortune Global 500 disclosures Canary Wharf, London LRA educational guidance · Not issued or endorsed by Global Reporting Initiative

Standard

GRI 415: Public Policy

Disclosure GRI 415-1 · 2016

Effective

2018-07-01

Official source: Open ↗

Last reviewed

2026-08-03

LRA educational guidance · Not issued or endorsed by Global Reporting Initiative

To prepare this disclosure
10LRA preparation fields 20claims to verify 14evidence areas 3report examples

Disclosure focus

This disclosure requires the organization to report the total monetary value of direct and indirect financial and in-kind political contributions by country and recipient or beneficiary.

A political contribution is financial or in-kind support given directly or indirectly to political parties, their elected representatives or persons seeking political office.

Indirect contributions can include qualifying support provided through lobbyists, charities, think tanks or trade associations linked to political parties or causes.

The organization should distinguish qualifying political contributions from general lobbying expenditure, association membership fees, charitable donations, sponsorships and other public-affairs expenditure.

Where in-kind contributions were made, explain how their monetary value was estimated.

Financial political contributions must be calculated in accordance with national accounting rules where these exist.

If no contributions were made, report the zero result explicitly. Policies and controls belong primarily to the management approach under Disclosure 3-3 and do not replace GRI 415-1.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official Global Reporting Initiative source.

Before you start

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key information to prepare

Preparation field What to capture Evidence hint Owner
Qualifying contribution Transaction meeting the GRI political-contribution definition. Ledger, public-affairs registers, approvals, contracts and classification records. Public Affairs / Compliance
Contribution route Direct contribution or qualifying indirect contribution through an intermediary. Intermediary records, contracts and political-beneficiary evidence. Public Affairs / Legal
Country Country assigned under the documented reporting method. Transaction, recipient and beneficiary-location records. Finance / Public Affairs
Recipient or beneficiary Political party, elected representative, candidate or qualifying indirect beneficiary. Payment instructions, contracts, correspondence and recipient registers. Public Affairs / Legal
Financial value Monetary value calculated under applicable national accounting rules. General ledger, accounting policy and national-rule analysis. Finance
In-kind value Estimated monetary value of qualifying non-cash support. Valuation schedules, market evidence and service records. Finance / Public Affairs
In-kind valuation method Method and inputs used to estimate the monetary value. Methodology memo and supporting assumptions. Finance
Currency and conversion Transaction currency and reporting-currency conversion, where relevant. FX source, transaction date and consolidation workbook. Finance
Country-recipient total Combined financial and in-kind value for the relevant country and recipient or beneficiary. Controlled reporting table and reconciliation. Sustainability Reporting
Zero conclusion — if applicable Evidence that no qualifying contributions were made. Entity confirmations, ledger searches and public-affairs sign-off. Compliance / Finance
＋ Show GRI 415-1 sub-elements (LRA working checklist)

How to prepare it

Apply the GRI political-contribution definition.
Identify financial contributions within the reporting boundary.
Identify qualifying in-kind contributions.
Review lobbying, association, charity and sponsorship payments to determine whether any meet the definition.
Identify direct and indirect contribution routes.
For indirect contributions, identify the intermediary and relevant political link.
Identify the country and recipient or beneficiary for each contribution.
Apply applicable national accounting rules to financial contributions.
Estimate the monetary value of in-kind contributions using a documented method.
Convert currencies consistently where necessary.
Aggregate values by country and recipient or beneficiary.
Prepare an organization-wide total as optional supplementary information.
Reconcile the disclosure to accounting, approval and public-affairs records.
Where no contributions were identified, verify the zero conclusion across the reporting boundary.
Apply an appropriate reason for omission where required information cannot be reported.
Verify the disclosure against GRI 415-1(a)–(b) and compilation requirement 2.1.

Request the data

Request the disclosure evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Please provide the GRI 415-1 political-contribution register for [reporting period]. For each potentially relevant transaction, include: paying entity; transaction date; country; recipient or beneficiary; intermediary, where applicable; political party, representative, candidate or cause supported; financial or in-kind classification; direct or indirect classification; amount and transaction currency; applicable national accounting treatment; reporting-currency value; in-kind valuation method and inputs, where applicable; approval reference; and source-system reference. Please include potentially relevant lobbying, association, sponsorship and charitable payments for classification, but do not classify them automatically as political contributions.

Use the organisation's own role and document names, but preserve the defined GRI terms and the scope described above.

Better request

Please provide the GRI 415-1 political-contribution register for [reporting period]. For each potentially relevant transaction, include: paying entity; transaction date; country; recipient or beneficiary; intermediary, where applicable; political party, representative, candidate or cause supported; financial or in-kind classification; direct or indirect classification; amount and transaction currency; applicable national accounting treatment; reporting-currency value; in-kind valuation method and inputs, where applicable; approval reference; and source-system reference. Please include potentially relevant lobbying, association, sponsorship and charitable payments for classification, but do not classify them automatically as political contributions.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

Political contributions were identified using the GRI definition. Financial contributions were calculated under applicable national accounting rules. Country attribution and currency conversion were based on [method]. In-kind contributions were valued using [method].

Context note

Keep mandatory GRI Requirements, GRI recommendations and additional LRA preparation controls clearly distinguished. Apply a GRI 1 reason for omission where required information cannot be reported.

Download Centre

Preparation tools & forms

Professional preparation tools for GRI 415-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI Assistant.

Free · Community members
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Assurance readiness

For each claim, check the evidence

Claim Risk Evidence to check
We applied the GRI definition of a political contribution.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
We distinguished political contributions from general lobbying expenditure.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
We did not classify all trade-association fees as indirect political contributions.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
We did not classify all charitable donations or sponsorships as political contributions.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Financial contributions include applicable donations, loans, sponsorships, retainers and fundraising tickets.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
In-kind contributions include only qualifying political support.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Subsidiary payments were not labelled indirect solely because the parent company did not make them.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Indirect contributions are supported by evidence of an intermediary and relevant political link.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
All reporting entities within the GRI boundary were considered.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The monetary values are reported by country and recipient or beneficiary.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
A global total does not replace the required country-and-recipient breakdown.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Financial contributions were calculated under applicable national accounting rules.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Transaction currencies and conversion methods are documented.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The in-kind valuation method is disclosed where applicable.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
In-kind valuation inputs are traceable and consistently applied.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Financial and in-kind values were not double counted.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Direct and indirect routes were reconciled before aggregation.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
The recipient or beneficiary information can be traced to source records.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Where no contributions were reported, the zero conclusion was verified across the reporting boundary.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.
Any unavailable required information is addressed through the applicable GRI reason-for-omission requirements.The published response does not support this human-reviewed assurance check.Trace the statement to current approved records and the official IFRS source.

Evidence pack to prepare

Common reporting gaps

Only an organization-wide total is reported.
Amounts are not broken down by country and recipient or beneficiary.
Countries are listed without corresponding values.
Recipients are listed without corresponding values.
Only financial contributions are included and in-kind contributions are omitted.
The in-kind valuation method is not explained.
Applicable national accounting rules are not considered.
General lobbying expenditure is reported as political contributions.
All trade-association fees are classified automatically as indirect political contributions.
Charitable donations and ordinary sponsorships are included without a political link.
Qualifying indirect contributions through intermediaries are omitted.
A subsidiary payment is classified incorrectly as indirect.
Financial and in-kind values are double counted.
The global total does not reconcile to country-and-recipient values.
The recipient or beneficiary is unclear.
Only the intermediary is disclosed even though the political beneficiary is known.
The country represents the payment-processing location rather than the documented contribution country.
Currency conversion is inconsistent.
The report states that contributions are prohibited but does not state whether the reported value was zero.
Policies and controls are presented instead of the monetary-value disclosure.
A zero result is left blank rather than stated explicitly.
An in-kind contribution is reported without monetary valuation.
A privacy or confidentiality concern is used to omit recipient information without applying the GRI reason-for-omission requirements.

Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative example 1

Illustrative synthetic example — Consumer goods
Country
Recipient or beneficiary
Financial contribution
In-kind contribution
Total monetary value
United Kingdom
Political Party A
GBP 100,000
GBP 20,000
GBP 120,000
Germany
Candidate Committee B
GBP 40,000
GBP 0
GBP 40,000
France
Political Party C, through Association D
GBP 20,000
GBP 0
GBP 20,000
Total
GBP 160,000
GBP 20,000
GBP 180,000
The GBP 20,000 in-kind contribution represented advertising and event support valued using external market rates. The Association D payment was included because evidence showed that the amount supported Political Party C.

Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.

Illustrative example 2

Illustrative synthetic example — Transport and logistics
Country
Recipient or beneficiary
Financial contribution
In-kind contribution
Total
Canada
Election Committee A
CAD 50,000
CAD 0
CAD 50,000
Australia
Candidate B
CAD 20,000
CAD 10,000
CAD 30,000
Australia
Political Party C, through Industry Body D
CAD 12,000
CAD 0
CAD 12,000
Total
CAD 82,000
CAD 10,000
CAD 92,000
The in-kind contribution comprised venue hire valued using an external market rate. The Industry Body D payment was included because the amount was linked to support for Political Party C.

Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.

Illustrative example 3

Illustrative synthetic example — No political contributions
The organization made no direct or indirect financial or in-kind political contributions during 2026. The total monetary value was EUR 0.

Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.

Illustrative example 4

Illustrative treatment — Association membership fee
The organization paid EUR 200,000 in ordinary membership fees to industry associations. No evidence showed that the payments supported particular political parties, candidates or causes. The fees were therefore not classified as political contributions.

Synthetic LRA illustration. Replace every figure and fact with the reporting organisation's evidence.

Company reports

How companies report GRI 415-1 in practice

Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.

Real published reports
Indra Sistemas, S.A.
Software and Services · Spain · 2025
Open report →

Indra’s Sustainability Report 2025 provides a direct zero-contribution response.

The report states that Indra Group does not make political contributions, whether financial or in kind. It also states that its Code of Ethics prohibits direct or indirect funding of political parties, representatives or candidates.

The report separately discloses lobbying-association membership fees and donations and sponsorships. These amounts should not be treated automatically as political contributions because the report explicitly distinguishes them from political funding.

The card should:

use the direct no-contribution statement on report page 166 as the primary GRI 415-1 evidence;

report the monetary value as zero;

remove the claim that page 209 provides political-contribution values;

remove the ESRS S1 reference;

remove emissions information from page 255;

distinguish lobbying-association fees and general donations from political contributions; and

classify the disclosure as an adequate zero-contribution response.

Because no contributions were made, a country-recipient breakdown and in-kind valuation method are not applicable.

Indra explicitly reports that it makes no financial or in-kind political contributions and prohibits direct and indirect political funding.

Abertis
Ground Transportation — Highways and Railtracks · Spain · 2024
Open report →

Abertis provides a direct zero-contribution response in its 2024 Annual Report.

The report states that Abertis does not make political contributions, directly or indirectly, whether financial or in kind, in any country or geographical area.

The card should:

use this statement as the principal GRI 415-1 evidence;

report a zero political-contribution result;

remove tax information from page 202;

remove workforce data from page 224;

remove foreign-currency and balance-sheet information from page 303;

state that the country-recipient breakdown is not applicable because the value is zero; and

classify the disclosure as an adequate zero-contribution response.

Registration in the EU Transparency Register is useful lobbying context but is not the required monetary political-contribution value.

The company’s 2024 report expressly states that it makes no direct or indirect financial or in-kind political contributions in any country or geographical area.

JB Financial Group Co., Ltd.
Banks / Diverse Financials / Insurance · South Korea · 2024
Open report →

JB Financial Group’s 2024 Integrated Report provides substantive GRI 415-1 information on report page 89.

The report presents:

zero expenditure for local, regional or national political campaigns, organizations or candidates;

zero political or lobbying contributions; and

KRW 4,317 million in trade-association or tax-exempt-group expenditure.

A footnote states that donations or support for political campaigns, election funds and lobbying organizations are prohibited under the Group’s management principles and applicable laws.

The card should:

treat the political-contribution result as zero;

distinguish the KRW 4,317 million of association expenditure from political contributions;

remove microbusiness-account subscriber figures;

remove general social-contribution discussion;

remove Scope 1 and Scope 2 emissions;

use report page 89 as the substantive source; and

classify the disclosure as an adequate zero-contribution response, subject to confirming that no portion of the association expenditure qualifies as an indirect political contribution.

General association expenditure should not be added automatically to the GRI 415-1 value.

The official JB Financial Group website lists the 2024 Integrated Report, and the Group’s policies prohibit illegal direct or indirect political support.

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Framework references

Relevant GRI requirements and related disclosures

Available framework references and nearby disclosures relevant to preparing this requirement.

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