Responsible Lobbying & Public Policy Engagement Policy

1. Introduction and Purpose

As a certified B Corporation, Walsh's Learning to Achieve is legally committed to considering the impact of our decisions on our team, customers, suppliers, community, and the environment. This policy outlines our commitment to responsible engagement with public policy and defines strict guidelines should we ever choose to participate in direct lobbying activities, ensuring all actions align with our mission, ethical standards, and B Corp values.

Current Stance: Walsh's Learning to Achieve does not currently engage in direct lobbying activities, nor do we currently make political contributions. 

2. Definitions

2.1 Lobbying (Direct)

Direct lobbying is defined as the act of communicating with any elected official, governmental employee, or legislative staff member for the purpose of influencing specific legislation, regulatory action, or political decision-making.

2.2 Public Policy Engagement (Advocacy)

These are permitted activities that do not meet the definition of direct lobbying, including:

  • Responding to official requests for information from government bodies.

  • Participating in public forums, industry groups, or trade associations focused on public discourse.

  • Educating the public or policymakers on the societal, environmental, or economic impacts of existing or proposed policy.

  • Contributing to academic research or thought leadership on relevant topics.

3. Core Principles of Engagement

All public policy engagement by Walsh's Learning to Achieve must adhere to the following principles:

  1. Alignment with B Corp Principles: All advocacy efforts must prioritise the benefit of society and the environment, ensuring alignment with our B Corp certification requirements and impact goals. We will not support policies that negatively affect our stakeholders.

  2. Transparency: All expenditures, personnel involved, and policy positions taken will be documented and available for internal review and public disclosure where applicable.

  3. Integrity and Accuracy: All communications with public officials and policymakers must be truthful, accurate, and supported by objective data.

  4. No Quid Pro Quo: Engagement must be based on the merits of the policy and not predicated on or linked to political contributions or financial interests.

4. Policy on Direct Lobbying and Political Contributions

4.1 Prohibition on Direct Lobbying (Current)

Until formally reviewed and approved by the Board of Directors, Walsh's Learning to Achieve maintains a strict prohibition on the expenditure of funds for direct lobbying activities at the national and local levels.

4.2 Political Contributions Prohibition

Walsh's Learning to Achieve prohibits the use of corporate funds or resources for political contributions to any political party or candidate.

5. Engagement with Trade Associations

Walsh's Learning to Achieve may participate in industry trade associations. We acknowledge that these associations may engage in lobbying activities that we would not undertake ourselves.

  • Due Diligence: We will perform regular due diligence to ensure the primary lobbying positions of any trade association we join are not directly contradictory to our core B Corp mission and values.

  • Active Opposition: If a trade association takes a public policy position that is materially detrimental to our B Corp commitments (e.g., opposing climate action), the company will:

    1. Formally communicate its opposition to the association’s leadership.

    2. Publicly state its own, separate policy stance.

    3. Consider withdrawing from the association if the misalignment cannot be reconciled.

6. Framework for Future Lobbying Participation (If Policy Changes)

Should the Board of Directors approve participation in direct lobbying (reversing the ban in 4.1), the following minimum standards must be met:

  • Justification

    • Lobbying must be directly necessary to advance a core B Corp Impact Area (e.g., climate, worker equity).

    • Oversight: Must be approved by 75% of the Board of Directors.

  • Specific Focus

    • Efforts must be narrowly focused on specific legislation and measurable outcomes.

    • Oversight: Managing Director

  • Public Disclosure

    • All direct lobbying expenses must be published on the company website annually, detailing policy area and expenditure amount.

    • Oversight: Managing Director

7. Oversight, Review, and Accountability

  1. Policy Owner: The Managing Director is responsible for the ongoing administration and enforcement of this policy.

  2. Annual Review: This policy will be formally reviewed by the Board of Directors and the WLTA Advisory Board on an annual basis to ensure it remains relevant and effective.

  3. Reporting: Any employee or third party engaged in public policy advocacy on behalf of Walsh's Learning to Achieve must report their activities and expenditures to the Policy Owner quarterly.

This policy will be reviewed annually.

Date of last review: October 2025