Deliberative Lobbying? Toward a Noncontradiction of Corporate Political Activities and Corporate Social Responsibility?

Abstract

Recently, researchers have claimed that food and beverage corporations should be excluded from the development of public health policy because their lobbying activities strategically undermine the promotion of public health. At the same time, recent political corporate social responsibility (CSR) theory holds that corporations have a responsibility to help solve global public issues. We address this described misalignment and show that corporations may fulfill this “new political role” if they turn to novel forms of corporate political activity (CPA) establishing a minimal standard for not contradicting their CSR. Therefore, we put forward a normative concept called deliberative lobbying based on discourse, transparency, and accountability, which aims to resolve public issues and advance CPA. In three lobbying cases, we show misalignments and contradictions that harm both society and the corporation. We position deliberative lobbing as an argument to maintain self-regulation against critics claiming that corporations should be excluded from all political processes.

Keywords

ethics corporate social responsibility corporate political affairs public affairs lobbying

Introduction

“Self-regulation is like having burglars install your locks” (Oswald, 2013). This assessment from the Australian professor of global health, Rob Moodie, was made in an interview about the food, beverage, and alcohol industries engaging in voluntary regulation for public health promoting an essay in the medical journal The Lancet. We argue that this statement from a medical expert bears fruitful potential to be explored in management studies regarding the interplay of corporate social responsibility (CSR) and corporate political activity (CPA). Transnationally operating corporations in these industries engage in self-regulation and lobbying to prevent hard law regulation from authorities and at the same time engage in CSR activities that purport a responsible picture of the companies in the very same matters. Indeed, these diverging strategies subordinate public issues to corporate goals, threaten a company’s image, reputation, and legitimacy and prevent organizational synergies (Anastasiadis, 2014; Den Hond, Rehbein, Bakker, & Lankveld, 2014). Moreover, given such strategic discrepancy and the ineffectiveness of voluntary self-regulation, Moodie et al. (2013) claim that food and beverage corporations should be excluded from the development of public health policy. This harsh position is based on “evidence to show that the food, drink, and alcohol industries use similar tactics and strategies to the tobacco companies to undermine public health interventions” (Moodie et al., 2013, p. 673). The authors call for “a substantially scaled up response from governments, public health organizations, and civil society to regulate the harmful activities of these industries” (Moodie et al., 2013, p. 671) as, in 2010 alone, more than 34.5 million people died of noncommunicable diseases (NCDs) due to unhealthy products.

The authors of The Lancet study wish to exclude corporations categorically from political processes. However, following recent CSR theories, such as political CSR or corporate citizenship (Matten & Crane, 2005), corporations have a “new political role” to play to contribute to resolving public issues. Political CSR theory (here following Scherer & Palazzo, 2007, 2011) suggests that this may be achieved through voluntary soft law engagement, not aimed to prevent regulation, as Moodie et al. (2013) claim is the case in the food industry, but to fulfill corporations’ new responsibilities. Thus, there are several breaches between political CSR theory and actual CPAs that this article addresses on a theoretical and normative level: First, self-regulation is presented as the solution to address public issues in political CSR theory, while in CPA it is used as a mode to prevent regulation. Hence, we address theoretically,

On what grounds do corporations engage legitimately in self-regulation parallel to their lobbying?

Second, recent research in the area finds that “the disconnect between companies’ thinking on lobbying and CSR . . . is dangerous for those firms’ ongoing legitimacy” (Anastasiadis, 2014, p. 261). Misalignments of CPA and CSR threaten not only the legitimacy, but also the reputation (Den Hond et al., 2014) of corporations in society. We focus on the strategies that corporations can apply to align CSR and CPA, and hence ask normatively,

How should corporations align CSR and political strategies to foster their legitimacy in society?

Third, contrary to Moodie et al. (2013) and their call for strict exclusion of corporations from political processes, in this article we address on a normative level:

How should corporations engage in corporate political activities to solve public issues?

We argue that corporations may be political actors as proposed by political CSR theory if they change their corporate political tactics to what we term deliberative lobbying that aims to fulfill the normative demands of political CSR known as discourse, transparency, and accountability (Scherer & Palazzo, 2007). Hence, deliberative lobbying is defined here as a CPA aligned with CSR that, based on discourse, transparency, and accountability, aims to resolve public issues. We review instrumental lobbying as a CPA and present the specific corporate lobbying cases of PepsiCo, Coca Cola, and Miller Brewing Company. These cases describe instrumental lobbying practices that are not orientated toward solving public issues, but toward the companies’ own benefit (Barley, 2007). We then take the cases to show how and why deliberative lobbying can alter CPA such that detrimental misalignments between CSR and CPA may be overcome (Den Hond et al., 2014). Through this analysis, we make the case that corporations may not be excluded from political processes as suggested by critics like Moodie et al., but should bring in their expertise via the new form of deliberative lobbying to find solutions to public issues in concert with other stakeholders. Organizations should engage in deliberative lobbying because CSR and CPA strategies become more effective when strategically aligned, CSR activities may maintain credibility, synergies between CSR and CPA emerge, and organizational reputation is enhanced (Den Hond et al., 2014). Strategies and obstacles of deliberative lobbying are discussed, too. We conclude by illustrating avenues for future research such as a focus on the intraorganizational perspective, the question of deliberative lobbying and actors, and the limits of voluntariness.

Toward Deliberative Lobbying

Instrumental Lobbying as a Nonmarket Strategy

Lobbying is part of nonmarket strategy, defined as “a concerted pattern of actions taken in the nonmarket environment to create value by improving its overall performance” (Baron, 1995, p. 47). Schuler, Rehbein, and Cramer (2002) identify the goal of any engagement in political activities as pursuing strategic advantage, and Richards (2003) points out that corporate lobbying imposes costs on corporations that need to be justified by the value they add to the company. Nonmarket strategy therefore views CPA as “attempts to shape government policy in ways favorable to the firm” (Hillman, Keim, & Schuler, 2004, p. 838). Therefore, this was also termed “instrumental” CPA that is “judged by what private returns it brings to the firm” (Schuler, 2008, p. 164). Definitional uncertainty reigns when it comes to the different forms of lobbying. This is predominantly due to the fact that different disciplines cover these activities (management studies, public relations, political sciences) and provide differing perspectives on these practices. Moreover, new forms of lobbying emerge faster than academics can track and, given their “covert” nature, are often hard to document. Thus, any classification of lobbying practices bears the limitations that it is selective of disciplines and not necessarily reflects the state-of-the-art as pursued in Brussels or Washington at the same time.

To use practitioners’ words, the main goal of instrumental lobbying is to lobby “for a more favourable hearing” (Thomson & John, 2007, p. 121) in the ears of politicians. From a theoretical point of view, various objectives (often simultaneously) lead companies to lobby: profit maximization, preserving the status quo, nonrational motivations such as ideological convictions of executives, or the institutional and stakeholder–context (Lowry, 2007). Overall, lobbying may be defined as “activities undertaken with the aim of influencing legislative/regulatory processes and outcomes” (Anastasiadis, 2014, p. 263). Instrumental lobbying appears mainly in three forms although we follow Hillman et al. (2004), who state that research on CPA does not keep pace with developments of new strategies in practice. CPA via standardization processes is an example of creative forms of lobbying that researchers may only study ex post (Frankel & Højbjerg, 2012).

“Classical” lobbying affects public policy by providing or exchanging (usually expert) information formulated by interest groups, which are a genuine part of the democratic system. These groups operate at the interface of society, economy, and public policy. Hillman and Hitt (1999) refer to lobbying as part of a company’s information seeking strategy, which aims “to affect public policy by providing policy makers specific information about preferences for policy or policy positions and may involve providing information on the costs and benefits of different issue outcomes” (p. 834).

Most importantly, in contrast to the deliberative nature of political CSR, instrumental lobbying is an informal and discrete action that is “covert rather than overt” (Harris & Lock, 1996, p. 320) and takes place between two stakeholder groups and is therefore not inclusive: the interest group/corporation (potentially represented by a public affairs agency) and the public policy actor (legislators, bureaucrats, government officials). The actor is a professional lobbying firm, an internal lobbyist such as a public affairs officer, or a corporate executive (Lord, 2000). Moreover, discourse is labeled bargaining and occurs in informal settings or sometimes even gray zones.

Grassroots lobbying is one of the most effective forms of lobbying (Lord, 2000; Nownes, 2006), where lobbyists do not approach public policy makers directly, but take a detour via the constituents of a certain community or issue field to reach the politician indirectly (Thomson & John, 2007). Here, lobbyists try to “influence public policy by gaining support of individual voters and citizens, who, in turn, express their policy preferences to political decision makers” (Hillman & Hitt, 1999, p. 834). Sectors with high public visibility such as health care, arts and entertainments, and energy engage especially in grassroots activities (Walker, 2012). An even more synthetic form of grassroots lobbying is labeled astroturf lobbying. Astroturf lobbying is a specious form of grassroots activities because public activism for an issue is artificially created by lobbyists. “Astroturf refers to apparently grassroots-based citizen groups or coalitions that are primarily conceived, created and/or funded by corporations, industry trade associations, political interests or public relations firms” (SourceWatch, 2013).

Researchers and practitioners proposed alternatives to instrumental lobbying such as ethical (e.g., Gao, 2008) or responsible (AccountAbility & United Nations Global Compact, 2012; Baron, 2008) approaches. Where instrumental lobbying is setting the agenda for CSR, ethical and responsible lobbying is quite the opposite. Here, the normative claims set the agenda for CPA. Forms of ethical lobbying are diverse in their philosophical roots: They may include notions of utilitarianism, theories of rights, theories of justice, or a mixture of these (Gao, 2008). The responsible lobbying concept, as proposed by the United Nations, contains guidelines for organizations on how to implement instrumental lobbying practices responsibly in their CPAs. However, these notions have not yet prevailed in practice. Thus, building on the transformative concept of political CSR, we position deliberative lobbying in line with Weber’s normative claim to think “about how corporations should, ideally, understand their proper role in the political process” because “[u]ntil the vision changes, the rules of the game are not likely to change” (Weber, 1996, p. 259).

Deliberative Lobbying as Lobbying Aligned With CSR

The concept of nonmarket strategy and the resulting lobbying place the interest of firms rather than society at the center. Therefore, public issues are subordinated to the firms’ goals (Schuler, 2008; A. Sharma & Lee, 2012). Nonmarket theory further adopts the paradigm of economic rationality and regards the resolution of societal issues as a responsibility of (state) political actors (Boddewyn, 2003). This paradigm prevails even if some authors suggest that firms may invest their resources to embrace upcoming regulation instead of preventing it (Fremeth & Richter, 2011; Peterson & Pfitzer, 2009). However, there have been reflections on how companies can take on public or political responsibilities for the firm’s and society’s benefit, especially in the context of developing countries. Often, such activities contribute to or substitute local infrastructure. However, the democratic deficit and the possibly strong dependency of local communities coupled with their distrust are important backlashes to consider (Valente & Crane, 2010).

Following a political CSR notion (Scherer & Palazzo, 2011), organizational activities aim to embed corporations in deliberative democratic processes to solve public issues as political actors, which blurs the distinction between the economic and the political spheres that is purported by nonmarket strategy. This claim of a “new political role” (Scherer & Palazzo, 2011) is assigned to corporations that operate transnationally. Under this paradigm, firms become political actors, which is why the question of how to align CSR and CPA is crucial. Furthermore, the growing literature emerging from this scholarly approach renders it the most recent and novel approach in CSR theory to be investigated.

According to political CSR theory, transnational corporations are powerful players in today’s globalized business world and through their vast resources have the responsibility to influence public policy (Schuler, 2008). Political CSR therefore encourages firms to take an active role in global public policy with the goal of addressing and resolving public policy issues. This shift includes issues such as “public health, education, social security, and protection of human rights” that previously belonged more to the domain of nation states (Scherer & Palazzo, 2007, p. 1109; 2011, p. 899). The resulting corporate actions are voluntary and proactive in the form of self-regulation or multistakeholder initiatives (Mena & Palazzo, 2012; Scherer & Palazzo, 2011). While other perspectives on political CSR exist (Frynas & Stephens, 2015), this article focuses predominantly on the view offered by Scherer, Palazzo, and colleagues that incorporates Habermasian theory and offers self-regulation as the primary tool.

Although this theory was initially conceptualized for weak or failing nation states, it may be applied to established democracies as well. Given the vast resources corporations allocate to lobbying, corporations have substantial influence in political processes. As the example of the ultra-processed food industry and the cases from the beverage sector described below show, entire sectors are undermined by corporate lobbying money and democratic processes are leveled out by this influence, which results in failures of policy processes. These corrupted processes occur at any level (local, regional, national, and supranational) in developed and developing democracies. Therefore, we hold that political CSR may also be applied to mature democracies.

Critics have claimed that voluntary self-regulation is ineffective and should be replaced by a global governance framework (Banerjee, 2010, 2014; Fleming, Roberts, & Garsten, 2013). However, insightful cases of political CSR show how companies fulfill their political responsibilities through self-regulation and multistakeholder initiatives (Haack & Scherer, 2014; Mena & Palazzo, 2012). The effectiveness of self-regulatory initiatives also depends on enforcement mechanisms and membership rules and is cultural and context-specific (Gilbert, Rasche, & Waddock, 2011; Potoski & Prakash, 2005). From a CPA perspective, self-regulation is employed instrumentally to divert policy makers’ attention from hard law regulation (Fooks, Gilmore, Collin, Holden, & Lee, 2013; Moodie et al., 2013). Thus, the status of self-regulation as a form of accepting and fulfilling political responsibilities has been damaged through past instrumental lobbying behavior and the questioned validity and effectiveness of selected initiatives. We argue that if corporations engage in a legitimate and deliberative form of lobbying, self-regulatory activities may regain their role as proclaimed by political CSR theory and again become the accepted tools to address governance gaps and public issues. Thus, a simultaneous engagement in self-regulation and lobbying is possible if a new form of CPA is applied. Theoretically, political CSR observes a conceptualization of politics grounded in deliberative democracy (Habermas, 1996), moral legitimacy, and the entrenchment of the corporation in global political structures (Banerjee, 2011; Den Hond & De Bakker, 2007; Kobrin, 2008). From this perspective, the political and economic spheres are conflated (Osland, 2003). In this deliberative view, collective action aimed at forming “shared social conditions” (Young, 2004, p. 377) is pursued by a variety of actors. As opposed to the understanding of nonmarket strategy, businesses are expected to make noninstrumental, nonopportunistic decisions focused on the solution of public issues. This may happen by means of “communicative activities in which they try to persuade one another” (see Young, 2004, p. 377), for instance, by engaging in CPAs such as lobbying.

Based on the theory of deliberative democracy, the normative demands of political CSR can be summarized as discourse, transparency, and accountability (Scherer & Palazzo, 2007):

Discourse: Ethical discourse in a Habermasian sense results in consent and agreement. It is based on communicative action, a discourse process in which participants adhere to the four validity claims of ideal speech (truth, sincerity, appropriateness, and understandability) to reach consensus (Habermas, 1984). No one may be excluded from joining the discourse; minority voices must not be marginalized or prevented from stepping into the dialogue. During the discourse, any statement may be challenged, and information and counter-arguments may be presented by anyone at any time. Moreover, “[e]very subject with the competence to speak and act is allowed to take part in the discourse” (Habermas, 1984, p. 89).

Transparency (of the process): The discourse process leading to moral legitimacy has to be transparent to stakeholders (Scherer & Palazzo, 2007). Discourse participants should be “transparent to themselves and others in what they actually do and believe” (Habermas, 2001, p. 99). Processes are transparent if interested stakeholders “can obtain a proper insight into the issues that are relevant for them” (Dubbink, Graafland, & van Liedekerke, 2008, p. 391).

Accountability (of the actors): Participants have to know who their partners in dialogue are and thus may have the possibility to hold them accountable for their statements and resulting actions (Rasche & Esser, 2006). By being accountable to their stakeholders, corporations may uphold their license to operate; however, it gives society control over corporations. From a Habermasian point of view, corporate accountability as part of moral legitimacy is constantly re-defined through deliberative discourse processes (Scherer & Palazzo, 2011).

Based on these three demands, we propose a new form of lobbying that advances the political CSR spectrum and aids companies in fulfilling their new political role by incorporating their citizenship rights into their business conduct (Nyberg, Spicer, & Wright, 2013). We argue that a shift away from nonmarket strategy lobbying toward political CSR–inspired lobbying results in a novel notion of CPA to align CSR and CPA in companies (Den Hond et al., 2014). Previous work on alternative lobbying approaches advised companies to embrace upcoming policy and to advocate for future regulation instead of fighting it (Fremeth & Richter, 2011). But the novel type of lobbying proposed here goes even further. We term this new notion deliberative lobbying and it is added to the existing frameworks of CPA, applicable from the subnational to the global level, in relation to communities or global bodies such as the World Trade Organization, and in multiple areas of policy (Windsor, 2007).

Deliberative lobbying is a corporate political activity aligned with CSR that, based on discourse, transparency, and accountability, aims to resolve public issues.

We argue that deliberative lobbying presents an alternative to instrumental lobbying practices aligning CSR and CPA to promote solutions to societal problems. Although there are examples where lobbying efforts have had positive effects (e.g., “lobbying for good”; Peterson & Pfitzer, 2009), those are single cases when looking at the evidence presented by Moodie et al. (2013) with regard to the food industry.

To counter the call for excluding companies from public policy processes, a renewal is suggested from instrumental to more deliberative CPA that as a minimum standard does not contradict CSR. However, we are hesitant to propose full alignment, even if from a normative stance this would be the most desirable solution: As Den Hond et al. (2014) argue, aligning CSR conduct and CPA provides synergies for companies. Alignment gives organizations the opportunity to participate substantially in public policy processes, contribute their expertise, and thereby help solve public issues. Stakeholders are said to perceive organizations that speak with one voice more positively than those that speak with a forked tongue. Mutually trusting stakeholder relationships are the basis for reestablishing and maintaining legitimacy for organizations (Heath, Waymer, & Palenchar, 2013). As the case of the car industry shows (Anastasiadis, 2014), divided strategies of CSR and CPA jeopardize companies’ legitimacy overall. As “CC [corporate citizenship] and CSR are both political” (Anastasiadis, 2014, p. 289), we argue that both should be aligned to safeguard a company’s reputation, its relationship with stakeholders and resulting legitimacy, and also the credibility of CSR.

Misalignment, instead, has negative effects on the organization’s reputation (Anastasiadis, 2014; Den Hond et al., 2014). In a study on the tobacco industry, Fooks et al. (2013) hold that deliberately not aligning both strategies may result in the misuse of CSR for public affairs purposes. This results in what they call (without referring to Scherer and Palazzo’s work) “political CSR.” This other “political CSR” has the power to set the limits of governmental actions and undermine political processes overall. Thus, misalignments of CSR and CPA not only harm the organization’s reputation, but also threaten the concept of CSR through politicization and challenge the functioning of political processes. Hadani and Coombes (2012), for instance, found that the goodwill derived from corporate philanthropic activities will positively influence a firm’s CPA and will also help in handling difficult stakeholders better. In this vein, Rehbein and Schuler (2013) propose that firms that engage in corporate community programs are also more effective in their CPA efforts.

However, Scherer, Palazzo, and Seidl (2013) argue that with corporations being complex organizations, sometimes paradoxical strategies are more successful in preserving legitimacy than monolithic strategies focused on consistency. In their perspective, there is no “one size fits all” solution to complex organizational problems that emerge from heterogeneous environments. Thus, different legitimacy strategies must be employed simultaneously to encounter these issues, which necessarily leads to inconsistencies that have to be solved by integrating organizational structures, internal reflection, and a shift to individual decision making. Certain contingencies will favor such paradox strategies (Hahn, Preuss, Pinkse, & Figge, 2014). The power of an organization, for instance, will determine the choice of strategy in response to environmental demands (Scherer, Palazzo et al., 2013). Moreover, the dynamics of the environments and the rapidity of communication technologies can influence strategic choices. Social media applications, for instance, have altered the way organizations must, and are also able to, respond to societal demands when it comes to CSR and its communication (Castelló, Morsing, & Schultz, 2013; Fieseler, Fleck, & Meckel, 2010).

Nevertheless, we argue that strategic contradictions should not occur when it comes to CSR and CPA, as they may result in an exclusion of corporations from political processes as proclaimed by Moodie et al. (2013), which cannot be in the interest of corporations. Furthermore, this leeway of paradoxical strategies creates loopholes that can be exploited and possibly lead to further undermining of CSR and loss of trust. It is important that corporations contribute to the solution of public issues via CPA because they are, as described by political CSR, vital political players that may contribute their expertise and resources. As the example of the car industry shows, firms loose legitimacy if they do not realize their ascribed political role (Anastasiadis, 2014).

To analyze alignment strategies, we present three instrumental lobbying cases; we show how the pursuit of instrumental lobbying results in strategic misalignments when compared with the firms’ CSR strategies. Afterward, we illustrate how and why deliberative lobbying can alter CPA such that strategic misalignments between CSR and CPA can be overcome.

Cases From the Food and Beverage Industry Undermining the Lobbying Corporations’ CSR Activities

Instrumental lobbying not only uses up large amounts of corporate resources, but it also produces a strategic misalignment when compared with the official CSR strategies of the same companies. Such misalignment stems from opposing corporate strategies that are pursued by different departments within the same company (Den Hond et al., 2014) and result in challenged legitimacy. This threat to legitimacy is reflected in Moodie et al.’s call to exclude corporations from public policy processes. The following lobbying cases from the United States and Europe illustrate why this claim might be justified and how deliberative lobbying can alter CPA to be consistent with CSR. Different regulatory frameworks have been chosen given that institutional settings are important when it comes to lobbying (Woll, 2007) and research on different national contexts of lobbying and CSR is still missing (Den Hond et al., 2014); see Table 1.

Table 1.

Examples of Lobbying Corporations’ CSR Activities.

Company	Example	Official CSR strategy	Uncovered lobbying strategy
PepsiCo	Soda tax	Reducing the average amount of added sugar	Opposing soda tax
Coca Cola and Cadbury	Food traffic light	Coca Cola: Fight obesity Cadbury: Educate people to make informed decisions	Opposing traffic light labeling system
Miller Coors/Miller Brewing Company	Responsible alcohol consumption	Drunk driving and underage access prevention	Maintaining high blood alcohol levels for drivers and a low minimum drinking age

Note. CSR = corporate social responsibility.

PepsiCo

In 2009, the United States experienced a lively debate around the introduction of an excise tax on sugary drinks. The legislative proposal included a tax of US$0.03 per 12 ounce on sweetened beverages and was discussed in the Senate as well as the House. This so-called soda tax was abandoned due to massive lobbying efforts by the beverage industry, led by the American Beverage Association as the major industry group and PepsiCo as one of the main producers (Center for Responsive Politics, 2013b).

In the same year, PepsiCo’s spending on lobbying reached US$9.45 million, whereas the year before, it amounted to the comparatively smaller figure of US$1.1 million. The same peak is observed in the American Beverage Association’s lobbying expenditures, which came to a total of US$18.8 million in 2009, compared with US$668,000 in 2008 (Center for Responsive Politics, 2013b).

The beverage industry applied various lobbying strategies, such as biasing research findings, to prevent the soda tax. The website of the American Beverage Association displayed selected articles from peer-reviewed journals that contested the link between soda consumption and obesity. However, an author of one of the studies was employed by a producer of corn syrup (Hamburger & Geiger, 2010). In addition, the association’s spokesperson accused opponents of the soda tax of engaging in “scientific McCarthyism,” arguing that “[c]igarettes kill. Soda doesn’t,” and attacked the soda tax advocates for their research findings: “They pick and choose the facts that support their view and they attack anyone who disagrees” (Hamburger & Geiger, 2010). In contrast, a study from 2001 found that the link between child obesity and sugary drinks is evident: “The odds ratio of becoming obese among children increased 1.6 times for each additional can or glass of sugar sweetened drink that they consumed every day” (Ludwig, Peterson, & Gortmaker, 2001, p. 507).

The beverage industry’s opposition to the soda tax in 2009 was successful as there is currently no excise tax on sugared beverages in the United States. This lobbying effort is especially remarkable when the CSR (or sustainability) strategy pursued by beverage companies at the same time is investigated more closely.

PepsiCo, one of the major opponents of the soda tax and a member of the American Beverage Association, stated in its 2009 sustainability report, “As an industry leader, we have a responsibility to help develop solutions to key global challenges, such as obesity” (PepsiCo, 2009, p. 7). One of the company’s main goals is to reduce the average amount of added sugar in “key global beverage brands, in key countries, by 25%, by 2020, with a 2006 baseline” (PepsiCo, 2009, p. 3). However, by limiting the specification of “key” brands or countries in the statement, PepsiCo avoided liability when confronted with the de facto numbers. According to Kleiman, Ng, and Popkin (2012), PepsiCo increased the daily calories sold per capita worldwide of its beverages by 13%. The numbers decreased only in the United States, whereas more calories per capita were sold in China and Brazil.

One main lobbying strategy for avoiding the soda tax was using research that challenged the link between soda and obesity. In PepsiCo’s CSR strategy, the link between obesity and sugared drinks is avoided. In fact, PepsiCo states that it aims to fight obesity by increasing “the range of foods and beverages that offer solutions for managing calories” (PepsiCo, 2009, p. 6). The discourse is also changed from the harmful consequences of soda intake to the lack of physical activity as one of the main causes for obesity. A program such as the “Health’s Change4Life” campaign in the United Kingdom, which urges parents to take their children out to play, serves as an example of such a strategy. Furthermore, such programs showcase the shift of responsibility from the soft drink producer to the individual, in this case to the parents who are responsible for the weight of their children.

Coca Cola and Cadbury

Another major lobbying case that far exceeded the amounts spent on lobbying against the soda tax was concerned with the introduction of a food traffic light system in the European Union (EU) in 2010. This legislative proposal planned to mandate nutritional information on food packages. It included an illustration of the amount of healthy and unhealthy components, such as salt, sugar, and fat per 100 grams, in the form of a traffic light on the front of the food package. The food industry spent around US$1 billion lobbying against this labeling. Major players against this legislation initiative included the industry association CIAA (confederation of the food and drink industries of the EU) and the industry-sponsored research institute European Food Information Council (EUFIC). Industry advocated for a voluntary system called the guideline daily amount (GDA) that shows the amount of calories per portion of packaged food. However, critics say that the GDA is misleading because the size of the portion can be chosen freely by the company, the color coding of the traffic light is missing, and the labeling is voluntary.

When the consultation process among the EU member countries began, the food industry pursued a strategy of co-opting policy makers to vote against regulation. For instance, after being announced as a shadow rapporteur (member of parliament who monitors a dossier for political groups; European Commission, 2013) for the committee discussing the legislative proposal on food labeling, Member of the European Parliament (MEP) Liotard received 50 emails from the food industry within 1 hr. Another shadow rapporteur, MEP Schlyter, said about the debates in the committee, “In the earlier discussions people were much more open-minded . . . But they have been exposed to so much industry pressure that it shifted focus” (Corporate Europe Observatory, 2010b, p. 6). During the same phase, research supporting the voluntary GDA labeling was published by the EUFIC, whose official mission is “to enhance the public’s understanding of credible, science-based information on the nutritional quality and safety of foods” (EUFIC, 2012, p. 1). A study on food labeling was published in a peer-reviewed journal, indicating the author’s connection to EUFIC, but concealing that EUFIC is an industry-sponsored think tank. More studies on consumer preferences for the GDA were issued with EUFIC support, but they lacked a comparison between GDA and the traffic light system. However, such a comparative study was conducted simultaneously with these other studies and found that people understood the traffic light system more easily than the GDA (Corporate Europe Observatory, 2010b).

Just before the vote on the labeling took place, several industry associations targeted voting members of the European Parliament with recommendations for the vote via email. The European organization representing the meat processing industry, for instance, stated that “consumers have the right of not being misled or confused and therefore that a correct enforcement of the existing labeling legislation throughout the EU—rather than new burdensome rules—is urgently needed” (Corporate Europe Observatory, 2010a, p. 16). The International Butchers’ Association wrote,

The basic principle for the new regulation must be: a minimum of mandatory labeling elements, to avoid that the consumer will be overstrained with a flood of information or even misled and to avoid that SMEs [small and medium-sized enterprises] will have to cope with heavy administrative burdens. (Corporate Europe Observatory, 2010a, pp. 6, 25)

The lobbying efforts of the food and beverage industry were successful (European Union, 2006); the proposal was not adopted by the European Parliament. Although the effort at the European level to introduce mandatory labeling failed, in June 2013 the major supermarket chains in the United Kingdom and some food producers agreed to voluntary traffic light labeling on the front of packages. The only two major players in the industry that did not sign this voluntary agreement and still adhere to the GDA are Coca Cola and Cadbury (Hall, 2013).

Coca Cola stated in its online sustainability report that “it is the responsibility of food and beverage companies like ours to provide fact-based nutrition information about their products to facilitate consumer choice” (Coca Cola, 2012); combined with sponsored consumer education programs concerning nutrition, they thus argue that they meet their social responsibility. Recently, Coca Cola also listed the number of calories of every beverage on the front of the packages. While, on one hand, the company argues that providing nutritional information is important to consumers, on the other hand, it lobbies at the EU level against the most transparent and understandable system of food labeling, the traffic light system (Corporate Europe Observatory, 2010b). Furthermore, in its 2013 sustainability strategy, Coca Cola acknowledged the issue of obesity: “Since 1980, global obesity rates have doubled. In addition to our product innovation of diet and light beverages, we have also increased our support of exercise and nutrition programs” (Coca Cola, 2013, p. 10). The Coca Cola “Coming together” campaign with the slogan “Help us fight obesity” therefore supports fitness classes and nutrition education for children, which cost around US$13 million in the first year. On the program’s website, tips for a healthy lifestyle under slogans such as “Hate Exercise? This Will Change Your Thinking” are provided to consumers. Again, the evident link between sugared beverages and obesity is concealed, and the focus is shifted toward physical activity and education. In fact, Coca Cola, in its CSR strategy, sells as a success that it “offer[s] more than 3,500 products, including more than 800 low- and no-calorie beverages that add up to a full range of hydration options” (Coca Cola, 2013, p. 8). When this is stripped down, it means that 23% of the beverages that Coca Cola produces is low calorie, compared with 77% being sugared drinks. Promoting low- and no-calorie beverages as part of the social responsibility strategy to fight obesity also conceals the dangerous side effects of artificial sweeteners like aspartame or sodium cyclamate that are used in diet, light, and zero-calorie products in some countries despite being banned in the United States by the Food and Drug Administration (FDA) since 1969 (Carroll, 2009).

Like Coca Cola, Cadbury opposed the introduction of food traffic light labeling at the EU level and also the voluntary agreement on the traffic light system introduced in the United Kingdom in 2013. Cadbury belongs to Mondelez International, formerly Kraft Foods, a brand conglomerate including such brands as Milka, Oreo, and Jacobs, with net revenues of US$35 billion in 2012 (Mondelez, 2012). It is hardly surprising that Cadbury (as a brand of Mondelez) takes the same line as Coca Cola and points to the individual responsibility of consumers, the role of education, and the need for physical activity to fight obesity. Regarding food labeling, the company states that “[w]e provide nutrition labeling on all products in all markets worldwide—even when it’s not required” (Mondelez, 2013). Mondelez (2013), as Cadbury’s parent company, even claims to be “dedicated to front-of-pack labeling that delivers meaningful information at a glance and fits local needs.” However, outside the CSR department, this strategy statement in favor of clear labeling is not manifested given the contradicting lobbying strategy pursued at the same time.

In the cases of both Coca Cola and Cadbury, the inconsistency between the lobbying and the CSR strategy becomes visible and highlights that nonmarket strategy lobbying and CSR may often pursue conflicting goals within one company.

Miller Coors/Miller Brewing Company

The alcoholic beverages industry spent around US$19.5 million on lobbying in 2012 (Center for Responsive Politics, 2013a), which makes it one of the major players in the public policy game. Often, the methods of this sector have been compared with the lobbying strategies applied by the tobacco companies in previous decades. The link between tobacco and alcohol seems evident: Altria, formerly named Philip Morris, holds 26.8% of SABMiller, the world’s second largest beer brewer (Altria Group, 2013). Its board is composed of at least five former or present directors of the tobacco industry (Daube, 2012). This alcohol–tobacco connection also surfaces in the lobbying tactics used and the communication strategies applied.

The main concern of alcohol producers is that alcohol is being highlighted in the public policy agenda, just like tobacco in the 1990s. Many upcoming issues such as alcohol taxes, restrictions on marketing and advertising, young people and alcohol, and drunk driving have therefore been addressed in the lobbying activities of alcohol producers. Daube (2012) states that “[b]oth tobacco and alcohol companies devote substantial attention to CSR activities—described from the tobacco industry documents as providing ‘air cover’ to distract governments and the community” (p. 108f.).

When the World Health Organization (WHO) prepared a strategy to reduce the harmful use of alcohol, it also invited key stakeholders in the alcohol industry to submit their comments. When asked about effective strategies to reduce alcohol-related harm, Miller Coors, a daughter company of the Miller Brewing Company (owned by SABMiller), listed individual responsibility and the education of consumers to make informed choices as the main points. Moreover, it recommended a “flexible menu of policy interventions that can be adapted to national contexts” (WHO, 2009, p. 30). Miller Coors further suggested that alcohol producers should provide information about alcohol on packages and online and partner with other organizations to address responsibility issues regarding alcohol (WHO, 2009). WHO’s global strategy did not specify which information companies are required to make available to the consumer or in which way.

With regard to drunk driving, Miller Coors’ CEO states in the company’s CSR report, “[P]reventing drunk driving is an important issue for our communities and the sustainability of our industry” (Miller Coors, 2013b). Under the initiative called the “drunk driving prevention pledge,” where consumers can pledge online not to drive drunk, Miller Coors further states, “Drunk driving is completely preventable” but not, as one might suppose, by not drinking, but by using other, “safe alternatives to driving drunk” (Miller Coors, 2013a). However, information emerging from the internal documents of Philip Morris (now Altria, the parent company) suggests that the beer producer is not seriously concerned with drunk driving. On the contrary, it advocates the maintenance of the current, higher blood alcohol levels for drivers (Bond, Daube, & Chikritzhs, 2009, p. 11).

The same conflicting strategies of internal policy positions and CSR emerge when looking at the issue of preventing underage access to alcohol. While Miller Coors states in its CSR report that “we do not want underage consumers . . . We care greatly about preventing underage drinking” (Miller Coors, 2013c), internal documents reveal that the Miller Brewing Company, the mother company of Miller Coors, “works behind the scenes” (Bond et al., 2009, p. 7f.) in the United States to “encourage the 27 states not already imposing a minimum drinking age of 21 to delay any enactment” (Bond et al., 2009, p. 12). Hence, alcohol producers praise themselves for their socially responsible programs on issues like drunk driving prevention and prevention of underage access to alcohol, while trying to reach opposing outcomes on the same topics via their lobbying strategies. “Companies that play an active role in promoting the binge drinking culture and opposing action to reduce harm from alcohol are not socially responsible” (Daube, 2012, p. 110). In brief, it seems that alcohol producers engage in CSR as “air cover” (Daube, 2012, p. 108) to detract from their other market and nonmarket strategies.

Moodie and colleagues (2013) claim in their study on NCDs that corporations in the food industry engage in “harmful activities” (p. 671) when entering the policy arena. For this reason, they call for a categorical exclusion of corporations from all public policy processes. Looking at the three illustrated cases, current instrumental lobbying and CSR practices seem to head in the same direction as Moodie et al. (2013) suggest. The examples illustrate that misalignments occur when companies pursue CSR strategies at the same time as instrumental lobbying strategies.

Deliberative lobbying may have the power to lead to aligned strategies of CPA and CSR and thereby contribute to the resolution of global public issues. Applied to the cases of the food and beverage companies, we will show in the following paragraphs how deliberative lobbying aligns CSR and lobbying.

Deliberative Lobbying in a Managerial Context

As became evident in the illustrative examples above, entire industries and not only single “bad apples” systematically undermine issues associated with CSR, such as public health. To counter this trend, we present deliberative lobbying in the light of Habermasian deliberative democracy as a manageable way out and show how deliberative lobbying as a minimal standard can align CSR and CPA.

Along the three normative demands of political CSR (discourse, transparency, and accountability), deliberative lobbying presents an alternative to existing instrumental lobbying strategies, as it does not undermine political processes but contributes to them in an informative way and aligns with companies’ CSR strategy. It fosters the role of food producers as legitimate stakeholders in public health discussions that have a right or even a responsibility to participate in public policy processes.

Reasons to Engage in Deliberative Lobbying

Organizations should engage in deliberative lobbying for a variety of reasons. First, firms may fulfill their political responsibilities, but in a deliberative way. Second, both CSR and CPA strategies become more effective when strategically aligned, which saves resources. Third, CSR activities, as self-regulation and multistakeholder initiatives, are not threatened through CPA and may thus establish and maintain credibility. Fourth, CPA may be based on a broader political basis; fifth, synergies between CSR and CPA emerge; sixth, reputation is enhanced (Den Hond et al., 2014). Seventh, stakeholder relationships may be built in a mutually trustful way, which strengthens legitimacy. In brief, firms that align CSR and CPA through deliberative lobbying and thereby help solve public issues contribute to a fully functioning society (Heath et al., 2013), which renders Moodie et al.’s call for exclusion obsolete.

Taking an external focus, public policy processes often appear to have corporations on one side and institutions on the other. However, this dichotomy is not that easy to cut. In the EU even more than in the United States, a multitude of government levels exist in which political activities take place. Access to these forms of politics has opened up to outsiders through modern communication technologies. Often, multiple actors such as nongovernmental organizations (NGOs) or quasi-governmental organizations or ordinary citizens enter the arena at the same time. Deliberative lobbying is a viable solution for addressing the heterogeneity of actors involved in constituting public policy outcomes. It is the only type of lobbying that allows for multistakeholder dialogue where all voices may be heard, a normative ideal of deliberative democracy (Habermas, 1996). However, political institutions also have to open up and allow for more deliberation in their processes, for instance, by implementing freedom of information laws and rendering policy processes more transparent and interactive.

Strategies of Deliberative Lobbying

Our case illustrations have highlighted the different strategies that food producers have employed to influence public policy, some of which had already been criticized by Moodie et al. (2013): sponsoring favorable research “under cover,” shifting responsibility from the company to the individual, providing biased information to policy makers, advocating the status quo as the best solution, and engaging in voluntary initiatives to counter legislation (pp. 671-674).

Thus, we argue that existing lobbying strategies should be applied under the normative premises of political CSR (discourse, transparency, and accountability), which, in Habermasian terms, implies a shift from strategic to communicative action (see Table 2).

Table 2.

Toward Deliberative Lobbying: Strategies.

Company	Example	Official CSR strategy	Instrumental lobbying strategy	Toward deliberative lobbying strategy
PepsiCo	Soda tax	Reducing the average amount of added sugar	Sponsor favorable research “under cover”	Sponsor independent research openly
			Shift responsibility from company to consumer	Encourage/enable consumers to drink/eat responsibly (according to CSR strategy)
Coca Cola and Cadbury	Food traffic light	Coca Cola: Fight obesity Cadbury: Educate people to make informed decisions	Provide biased information to policy makers Voluntary initiatives to counter legislation Sponsor favorable research “under cover”	Step into open dialogue with policy makers and present expert information
				Support regulation with expert insights

Miller Coors/Miller Brewing Company	Responsible alcohol consumption	Drunk driving and underage access prevention	Shift responsibility from company to consumer Advocate the status quo	Engage in discourse with policy makers and other stakeholders to find the best solution for all societal players

Note. CSR = corporate social responsibility.

As is apparent from the case of PepsiCo, sponsoring biased research and shifting the blame to the consumer conflicts with the declared social responsibility to reduce the amount of sugar in beverages. Deliberative lobbying can prevent such a strategic misalignment as the corporate political and social strategies would be based on the same normative foundations of deliberation. In practice, PepsiCo, as a member of the American Beverage Association, could still fund research in the field of obesity and physical activity. However, due to the claims of transparency and accountability, such studies would have to state clearly the name of the funding organization. Hence, EUFIC’s affiliation with the food and beverage industry would have to be made visible under this approach. Furthermore, the researchers would be free to transparently present their research results without omitting findings that may be unfavorable to the funding organization. That way, CPA and CSR goals can be aligned to fight obesity as one of the most harmful NCDs.

In contrast, shifting the blame strategies and imposing the responsibility entirely on the consumer when it comes to food and beverage intake is not a deliberative lobbying tactic, but an information provision that is biased as it presents only one side of the coin, the responsibility of the consumer. This does not fulfill the principles of ethical discourse and it violates the premise of transparency as not all relevant information is introduced into the discourse. Corporations may provide policy makers with valuable expert information on various public policy issues. That is why such political processes should be transparent and open for stakeholder voices to enter. Presenting individual responsibility as one of the most effective strategies to prevent the harmful consequences of alcohol, as pursued by Miller Brewing Company, is not only a “shifting the blame” tactic, but also a one-sided presentation of facts. Such biased suggestions might be more deliberatively discussed if the information provided by companies to policy makers was made accessible to interested stakeholders and if marginalized voices could step into a dialogue in this process. Public issues such as drunk driving or underage access to alcohol can be discussed deliberatively to find solutions for this problem that fit society’s needs and firms’ ends.

The same is true when corporations advocate for the status quo as the best solution. Opening a discourse with a predefined outcome does not adhere to ethical discourse in a Habermasian sense. Here, dialogue is oriented toward consent and agreement and participants reach the “truth” through deliberation. However, when Miller Brewing Company lobbies states not to introduce a minimum drinking age, it aims at the best solution for the firm, not for society, and therefore violates the demand of ethical discourse that leads to consensus. By aligning both CSR and CPA strategies in a deliberative way, new paths to responsible alcohol consumption may be pursued.

Last, engaging in voluntary self-regulation as a means to counter legislation is like “having burglars install your locks” (Oswald, 2013). By introducing the GDA, firms such as Coca Cola and Cadbury aim to promulgate an image of corporate accountability with regard to consumer information. However, it is an exact example of not being accountable if companies attempt to circumvent legislation by referring to voluntary self-regulation initiatives. With such kind of soft laws, corporations cannot be held accountable or controlled and sanctioned (May 2005) by stakeholders. Thus, voluntary self-regulation that is developed to counter legislative proposals does not correspond with the premises of deliberative lobbying. Instead, the fight against obesity and consumer education might become strategic goals for the CSR as well as the lobby-ing strategy to ultimately solve these public issues with corporations acting as experts in political deliberation processes.

Conditions in Favor and Against Deliberative Lobbying

Although there are good reasons for organizations to engage in deliberative lobbying, certain external and internal conditions may favor or impede its pursuit. Internal conditions are addressed in the section below. The following external conditions are discussed as potentially favoring or impeding deliberative lobbying.

One might argue that companies will not engage in deliberative lobbying under the premise of fierce competition. However, corporations may only take part in economic competition if society accepts and grants their license to operate (Donaldson & Dunfee, 1999). As argued above, instrumental lobbying in concert with CSR undermines legitimacy and therefore society might revoke the license to operate for companies that do not change their political activities. This is reflected in Moodie et al.’s (2013) call for exclusion of companies from one sphere of action, public policy: “[U]nhealthy commodity industries should have no role in the formation of national or international NCD policy” (p. 1). Thus, also from a normative perspective, companies should engage in this novel form of lobbying to safeguard their spot in public policy processes.

Another impediment to deliberative lobbying could be the difficulty of including heterogeneous actors. The “polyphony of voices” (Schultz, Castelló, & Morsing, 2013) that surrounds CSR issues is equally polyphonic in CPA. However, in the tradition of deliberative democracy theory (Habermas, 1996), participation in a deliberative lobbying initiative is a right, not a duty. The difficulty for the lobbying organization then lies in the inclusion of the relevant parties. As Mena and Palazzo (2012) suggest with regard to multistakeholder initiatives, input legitimacy is established if all relevant stakeholders take part, procedural fairness is guaranteed, the process is oriented toward a consensus, and it is transparent. Thus, when it comes to deliberative lobbying, including the most relevant, that is, the most affected stakeholders is the basis for this process’s legitimacy.

Another factor that might impede organizations to pursue deliberative lobbying is the associated costs. This form of lobbying may potentially take up more time than a classical lobbying campaign because a multitude of actors has to be coordinated to be brought together at a round table. However, it should also be cautioned that lobbying is not a fast-moving business but relies on long-term relationship-building and influence, as the illustrative cases show. Nevertheless, we can reasonably assume that deliberative lobbying bears additional costs of coordination and transaction and its open ending renders expenses hard to calculate. However, the costs of (perceived) unethical behavior and its consequences is almost never thoroughly accounted for. As the recent Volkswagen emission manipulation scandal shows (Hotten, 2015), unethical behavior of organizations almost never undergoes a sound risk calculation. The managers responsible for the manipulations at Volkswagen had most probably not calculated the loss of reputational capital and the crash of the stock price at the time of their decision. Although lobbying per se is not unethical, the tactics employed are often used in an unethical manner, as claimed by Moodie et al. (2013) and illustrated in the lobbying cases from the food and beverage industry. Thus, also unsound practices of lobbying would have to undergo a risk calculation procedure incorporating reputational and monetary risks, which would increase the price of such behavior.

Institutions play a major role in favoring deliberative lobbying in various ways by changing the rules of the game. Political institutions can be impediments or promoters of deliberative lobbying. The degree of power of organizations, for instance, can be moderated in the case of lobbying by access restrictions to legislators. To access the European Parliament, lobbyists must enroll in a transparency register (European Parliament, 2015). To level the playing field between organizations that (can) spend vast amounts of money on political activities and those that do not have similar resources, the number of lobbyists per organization could be limited. This way also the participation of civil society actors such as NGOs could be encouraged such that they may be enabled to fulfill their role as watchdogs of corporate players.

In this vein, political institutions could sanction organizations and politicians who engage in illegal or unethical lobbying behavior. Strict access restrictions to political institutions for lobbyists that do not comply with the law or with codes of conduct could be a means to sanction unlawful and unethical lobbying practices. Politicians and bureaucrats who bend to lobbying pressure could also be sanctioned more strictly, for instance, by excluding them from relevant decision committees. This would foster and, in consequence, give more rise to ethical CPAs such as deliberative lobbying because the costs of unethical and unlawful behavior increases.

Another way to change the rules of the game could be to regulate donations to political parties. By instituting and enabling a solid system of party financing, for instance, through taxation, direct donations to political parties could be rendered obsolete. Alternatively, the institution of a stock for political donations, where all donations from the private and civil society sectors are collected and distributed relative to the votes a party won during an election, could rule out the dependency of politicians from big donors.

Deliberative Lobbying Within the Firm

From a micro-level perspective, the call for alignment of CSR and CPA also comes with structural and procedural changes. Management’s functions are often referred to as planning, organizing, commanding, coordinating, controlling, and representing (Demeester, De Meyerb, & Grahovac, 2014; Diefenbach, 2013; Diefenbach & Sillince, 2011; Drucker, 2012; Fayol, 1949; Mahoney, Jerdee, & Carroll, 1965). The sixth function is particularly crucial for lobbying, as representation to the outside is the core of this public affairs strategy. Table 3 illustrates the differences between instrumental and deliberative lobbying regarding these six functions of management.

Table 3.

Instrumental Versus Deliberative Lobbying and Managerial Functions.

Managerial functions	Form of lobbying
Managerial functions	Instrumental lobbying	Toward deliberative lobbying
Plan	CPA and CSR strategies planned separately	CPA and CSR strategies discursively planned to reach noncontradiction
Organize	CPA and CSR in single departments as “islands”	CPA/CSR steering committee governs noncontradiction in strategies
Command	Head of CPA team versus head of CSR team	By head of CSR and CPA separately, but coordinated
Coordinate	Little to no coordination between CPA and CSR	High level of coordination between the teams, open discourse about goals, transparent strategies
Control	CPA and CSR controlled by board, but based on different standards and economic indicators	CPA and CSR controlled by steering committee and board, along the standard of (moral) legitimacy; the whole team is accountable for the activities in the CSR and CPA realms
Represent	CPA and CSR team approach stakeholders separately	Stakeholders are managed in a coordinated way by both teams

Note. CPA = corporate political activity; CSR = corporate social responsibility.

If a company pursues an instrumental lobbying strategy, it is likely that it has separate strategies for CPA and CSR. As became evident from the example described above, PepsiCo on one hand proclaimed to reduce the average amount of added sugar in its CSR strategy, whereas on the other hand it opposed the soda tax regulation through fierce lobbying. The same conflict surfaced when the Miller Brewing Company advocated sober driving and at the same time lobbied to maintain elevated blood alcohol levels for drivers. A shift toward deliberative lobbying would entail that the CSR and CPA teams jointly discuss which single strategy to pursue.

In the status quo where CSR and CPA are not aligned, CSR and CPA are also physically separate from each other and from the rest of the firm (Anastasiadis, 2014). Having these departments organized as “islands” does not foster alignment. In fact, organizational separation leads to communication barriers. However, communication is central when it comes to CSR (Schultz et al., 2013; Seele & Lock, 2015) and CPA (Harris & Moss, 2001). Structural integration of two departments such as CPA and CSR will only work with the help of communication. Complementary goals of CSR and CPA may be reached through communication, which is best assured by merging both teams into one organizational unit. Hence, integrating organizational structures is not only a solution for integrating paradox strategies (Scherer, Palazzo, & Seidl, 2013), but even more so to trigger aligned CSR and CPA strategies.

Following from the organizational separation of CPA and CSR (PepsiCo, for instance, employs a public policy/government affairs team and a sustainability task force; PepsiCo, 2015), the leadership of these separate entities is also split. An organization pursuing deliberative lobbying, instead, would benefit from joint leadership. Such a co-led CSR/CPA team needs much communication between the two heads that share equal decision-making power. Particularly in phases of change from two separate to one joint organizational unit, such a co-headed structure will be helpful for team members in adapting and learning. When the new organizational structure has developed its routines, a single head for CSR and CPA may be an option, depending on the expertise of the person in both fields.

As Coca Cola’s fight against obesity shows, contrary to its public affairs strategy to oppose a food-labeling system, there is (deliberately or not) little to no coordination between the CSR and CPA teams and strategies. However, if CSR and CPA are aligned, a high level of coordination among the team members and heads is necessary. Joint objectives are discussed deliberatively and strategic choices are made transparent to inside and outside stakeholders. In the case of Coca Cola, for instance, instead of opposing a food-labeling system, the company would step into an open dialogue with political decision makers and present expert information on the issue of food-labeling systems and obesity prevention.

PepsiCo’s sustainability task force is chaired by the company’s president; the public policy/government affairs team is overseen by the board of directors, which has a specific vice president for government affairs. Given the conflicting goals that PepsiCo pursued in the case of soda tax, the controlling standards and indicators for both units, CSR and CPA, might very likely have differed. Research into that specific topic is still lacking, to our knowledge, and impossible to discover without company access. If a company gets involved in deliberative lobbying, the control of the function would still be at the top of the firm, that is, with the board. However, the controlling mechanisms and indicators would be based on the same standards of moral legitimacy and deliberation, such as open discourse, transparency, and accountability.

CPA and CSR both have high visibility from the outside. Thus, representation is a key managerial function. Deliberative lobbying allows the firm to provide a consistent image to the outside and to approach stakeholders with one voice. Often, stakeholders in the realms of CPA and CSR are the same. For Cadbury, for instance, the WHO is not only a CPA stakeholder but also an institution that watches global health, which is important for Cadbury’s CSR. NGOs such as Foodwatch are prominent stakeholders for beverage companies, too, not only as opponents in public policy negotiations but also as partners in CSR programs. Thus, addressing a company’s stakeholders through one department lessens coordination costs and fosters relationship-building with opposing groups.

Summing up, deliberative lobbying presents an alternative to instrumental lobbying approaches under the three normative demands: discourse, transparency, and accountability. The legitimate role and importance of lobbying and self-regulation in open democratic societies remain therefore supported. Deliberative lobbying, as proposed here, adheres to this notion of deliberative noninstrumental, nonopportunistic democracy.

Conclusion

This article set out to answer the pending questions regarding how corporations can engage in CPA to solve public issues and how they can align their CSR and political strategies to foster their legitimacy in society. We proposed a novel type of deliberative lobbying that rests on the normative demands of political CSR theory and Habermasian deliberative democracy but is understood as a minimal standard to vanguard noncontradiction of CPA and CSR.

Unlike instrumental lobbying that determines CSR activities and vice versa and ethical/responsible lobbying that determines CPA, we argue that a minimal standard referred to here as deliberative lobbying allows for both CSR and CPA to develop in their own right without compromising the other. Thereby, we contribute to three streams of literature demarcating deliberative lobbying from existing types of lobbying. First, the literature on CPA has so far presented predominantly approaches that are instrumental and focused on the firm’s benefits. With this article, we shifted the focus to ethical considerations and CPA’s application in other corporate fields such as CSR. Although notions of ethical (Gao, 2008) and responsible lobbying (AccountAbility & United Nations Global Compact, 2012) exist, they propose mere ethical or compliance-based guidelines of behavior for lobbyists that still rely on an instrumental paradigm. Furthermore, ethical lobbying frameworks do not seem to reach far enough on a managerial level (Oberman, 2004). With our take, we follow Lawton, McGuire, and Rajwani (2013), who hold that “CPA scholars need to pay more attention to the ethical aspects of their subject” (p. 100).

Second, we expand the literature on the managerial application of political CSR theory. So far, the toolbox of political CSR consists of self-regulation and multistakeholder initiatives (e.g., Mena & Palazzo, 2012; Rasche, 2010). We add to this toolbox by presenting a form of lobbying that relies on the same theoretical backbone (viz., Habermasian deliberative democracy theory and discourse ethics) and that is in line with this global theory.

Third, a growing amount of recent literature examines the relationship of CSR and CPA (Anastasiadis, 2014; Den Hond et al., 2014). This article not only contributes to this novel stream by introducing a new concept that shows overlap between the two, but also engages in the discussion of how both streams may be aligned without compromising each other.

This article is a first step in thinking toward a new form of CPA on a normative level. We are aware that proposing a novel concept also bears some limitations. However, these might also open up avenues for future research that will render deliberative lobbying a sounder approach.

Nonmarket Activities Beyond Lobbying

Nonmarket activities other than lobbying merit further consideration. Coalition building, testimony, public advocacy, corporate political advocacy, and judicial actions are other strategies that corporations apply in the public policy arena (Baron, 2013). Like lobbying, these strategies also suffer from public criticism and might not be consistent with the notion of political CSR. Future research might test whether these nonmarket strategies comply with the normative demands of political CSR: discourse, transparency (Scherer & Palazzo, 2007), and accountability (Scherer & Palazzo, 2007).

Intraorganizational Perspective

Although we have argued that an alignment of CSR and lobbying strategies within a corporation fosters legitimacy and reputation, we did not investigate the micro-level perspective of such a claim. From the outside, we regard corporations as monolithic structures; however, internally they appear to be complex bodies that must address sometimes conflicting demands at the same time (Scherer, Palazzo, & Seidl, 2013). Future research might engage in a theoretical as well as empirical endeavor to more closely analyze which implications this claim for aligning CPA and CSR strategies might have for day-to-day intraorganizational management practices.

Deliberative Lobbying and Actors

In this article, we have focused on the contradiction between nonmarket strategy and political CSR in corporations and introduced the new notion of deliberative lobbying, applying a company perspective. However, deliberative democracy (Fung, 2005; Habermas, 1996; Young, 2004) and the theory of communicative action (Habermas, 1984) agree that not only does the sender (here the lobbyist) have to communicate ethically (according to the validity claims) but also the recipient must communicate ethically. Hence, deliberative lobbying might be a successful concept for companies to apply to avoid strategic misalignments and to comply with the demands of deliberative democracy. However, this will only work if the lobbyists’ counterparts apply these rules as well. That is why the role of governments and public policy bodies in general might be a subject of interest to researchers. Furthermore, the communicative activities of civil society groups such as NGOs can be analyzed with regard to their commitment to deliberative democracy and rational speech.

The Limits of Voluntariness

Voluntariness is the foundation of commitment in deliberative democracy (Habermas, 1996) and, in consequence, also of political CSR, which names self-regulation and multistakeholder initiatives as its core activities (Scherer & Palazzo, 2011). Voluntary activities that lead to soft law standards are thus the key to bridging global governance gaps. However, this engagement in voluntary self-regulation may not be pursued in a deliberative, but an instrumental way, as The Lancet study claims with regard to the ultra-processed food industry (Moodie et al., 2013). It may be that a rationalization of the limits of voluntariness when it comes to corporations and self-regulation is necessary. The authors of the study claim that “there is little evidence that self-regulatory approaches are effective” (Moodie et al., 2013, p. 676) in the ultra-processed food industry; however, further research in this area might shed light on the issue of voluntariness.

CSR as a Tool of Lobbying

As the example of the ultra-processed food industry shows, companies “promote actions outside their areas of expertise,” usually via their CSR strategy, “to deflect criticism” (Moodie et al., 2013, p. 674) of their nonmarket strategies. Taking this one step further, one can also argue that CSR activities can be used by public affairs departments in their nonmarket strategies to paint a different, more responsible picture of the company. The misuse of CSR for lobbying is an interesting topic for researchers with regard to its implications for reputation.

Footnotes

Declaration of Conflicting Interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) received no financial support for the research, authorship, and/or publication of this article.

Author Biographies

Irina Lock is postdoc researcher in the Institute of Marketing and Communication Management at Università della Svizzera italiana. Her research focuses on corporate social responsibility, corporate communication, and public affairs.

Peter Seele is associate professor of corporate social responsibility and business ethics in the Institute of Marketing and Communication Management at Università della Svizzera italiana. His research focuses on business ethics, corporate social responsibility, CSR reporting, and public affairs.

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