Responsible Lobbying & Public Policy Engagement Policy

Purpose

Sensiba engages in public policy issues that impact our clients, our communities, and the accounting profession. This policy outlines how Sensiba approaches lobbying and public policy engagement in a responsible, transparent, and ethical manner.

We are committed to ensuring that any engagement with policymakers supports positive societal impact, upholds our professional integrity, and reflects our values as a purpose-driven firm.

Scope

This policy applies to all Sensiba partners, employees, contractors, and representatives who may participate in public policy activities on behalf of the firm.

Our Principles for Responsible Public Policy Engagement

Sensiba commits to the following principles in all activities relating to public policy or regulatory engagement:

Transparency

  • We clearly disclose our role, interests, and expertise when engaging with policymakers or regulatory bodies.
  • We communicate honestly, accurately, and without exaggeration or omission, consistent with professional and ethical standards.

Integrity

  • We do not engage in activities that could compromise our independence as an accounting and advisory firm.
  • We follow all applicable CPA independence and professional ethics rules.

Non-Partisanship

  • Sensiba does not endorse political candidates or parties.
  • Our engagement focuses on issues, not partisan positions.

Accountability to Stakeholders

  • Our public policy engagement aims to create positive impact for stakeholders including workers, clients, the community, and the broader environment.
  • We prioritize long-term societal benefit over short-term organizational gain.

What We Consider “Lobbying”

Consistent with standard definitions, lobbying includes any attempt to influence legislation, rulemaking, or government decision-making through:

  • Advocating for or against specific bills, regulatory language, or government actions.
  • Meeting with policymakers to persuasion them on an outcome.
  • Drafting or reviewing language intended to influence legislative or regulatory decisions.

What Is Not Lobbying

Sensiba frequently provides comments, analysis, and subject-matter expertise to regulatory bodies. These activities are not considered lobbying when they are:

  • Technical, educational, or descriptive in nature.
  • Provided in response to a formal request for comment.
  • Neutral analyses of operational, financial, or practical implications.
  • Aimed at helping regulators understand how proposed rules may affect businesses, without advocating for a specific legislative outcome.

These actions align with our duty as professionals and serve the public interest.

Sensiba’s Lobbying Commitments

No Financial or In-Kind Political Contributions

Sensiba strictly prohibits the following:

  • Monetary contributions to political candidates, parties, PACs, or ballot measure campaigns.
  • In-kind support such as free services, discounted services, event hosting, or staff time used for political campaigns.

This applies firmwide, except where legally required (e.g., regulatory filing fees).

Issue-Focused, Not Candidate-Focused

Our engagement is limited to issues that affect:

  • The accounting profession
  • Sustainability and ESG standards
  • Tax, regulatory, or compliance requirements
  • Ethical business practices
  • Community and economic resilience

We do not participate in partisan activities.

Alignment with Firm Values

Our public policy positions will:

  • Support responsible business practices
  • Advance transparency, equity, sustainability, and stakeholder governance
  • Reflect Sensiba’s Purpose and Values

We will not engage in advocacy that contradicts these principles.

Internal Roles & Responsibilities

Executive Oversight

The Managing Partner and Executive Team oversee:

  • Approval of public policy positions
  • Review of potential lobbying activities for compliance with this policy
  • Annual evaluation of alignment with our values

ESG & Sustainability Team

  • Advises on alignment with responsible business and sustainability principles
  • Coordinates responses to public comment requests
  • Ensures transparency and documentation of public policy engagement

All Partners and Employees

  • Must comply with this policy and avoid unauthorized lobbying
  • Must disclose potential activities that could be perceived as lobbying
  • Must refrain from representing personal political opinions as firm positions

Engagement Mechanisms

Sensiba may responsibly engage in public policy through:

  • Written comment letters on proposed regulations
  • Participation in working groups or industry associations
  • Providing technical expertise and educational briefings
  • Supporting coalitions advocating for responsible business and sustainability standards
  • Publishing thought leadership on emerging regulatory issues

All engagements must follow the principles outlined in the above policy.

Transparency and Reporting

Sensiba will:

  • Maintain internal documentation of all formal public policy engagements
  • Report annually on our responsible lobbying and public policy activities in our Annual Impact Report
  • Disclose alignment with a third-party sustainability certification and recertification processes

Policy Violations

Any breach of this policy may result in corrective action, up to and including prohibition from representing the firm in public policy activities.

Policy Review

This policy will be reviewed at least annually and updated as needed to maintain alignment with:

  • Professional ethics rules
  • Regulatory requirements
  • Stakeholder expectations
  • Sustainability standards