Below are details of our Climate Lobbying Transparency and Lobbying Governance methodologies. These methodological details outline the structure of our scoring system and the instructions provided to our AI models.
The steps taken to assess a company according to the transparency and governance scoring frameworks, described below, were as follows:
Data Collection:
We collected evidence from a range of sources, including web pages and PDF documents from company websites (e.g., annual reports, TCFD, CDP, Lobbying and ESG reports).
Document Filtering:
Natural Language Processing (NLP) techniques and keyword matching were used to filter documents to only those relevant to understanding the company's climate lobbying and related governance disclosures.
Scoring Framework Development:
We developed scoring frameworks to evaluate the quality and transparency of a company's disclosures on its climate lobbying activities and governance processes to ensure the management and alignment of its climate lobbying.
Evidence Analysis:
We utilised Large Language Models (LLMs), with fine-tuning, to employ these scoring frameworks to analyse and score each piece of evidence. Different models were used to identify discrepancies, which were then checked manually.
Aggregation of Scores:
After producing document-level scores and analysis, we aggregated and further analysed the evidence at the overall company level to produce scores for each company, ranging from 0 to 4 for both climate lobbying transparency and governance.
Objective:
Lobbying transparency is defined as the company's disclosure of deliberate efforts to influence climate-related policy, legislation or regulation.
We broke down the transparency of disclosures into three categories:
Policies Lobbied:
Assesses the extent to which a company discloses the specific climate policies, legislation, or regulations it has sought to influence.
Lobbying Mechanisms:
Evaluates how clearly a company explains how it lobbies (e.g., direct meetings, letters, consultation responses) and whom it targets (e.g., a legislative body, specific officials).
Outcomes Sought:
Evaluates whether the company discloses the policy outcomes it aims to achieve and explains why it pursued these ends (e.g., cost implications).
We combined the scores across these three categories to produce an overall transparency score for each company.
Scoring Categories and Criteria:
For each company, we evaluate three categories:
- Policies Lobbied (PL)
- Lobbying Mechanisms (LM)
- Outcomes Sought (OS)
Each category is scored independently from 0 to 3.
Definition:
How specifically the company identifies policies, legislation, or regulations it aims to influence.
Scoring Criteria:
Score 3:
The company is highly transparent, naming at least three specific climate policies it has lobbied, or providing enough detail to identify three policies even if not explicitly named. Alternatively, it can score a 3 by clearly explaining why it does not engage in climate lobbying.
Score 2:
The company references two identifiable climate policies, either by name or with sufficient detail. It may also score a 2 if it states non-engagement without explaining why.
Score 1:
The company either discusses engagement in general climate policy areas without naming specific policies or provides only broad categories of policies it has lobbied.
Example: “We are involved in shaping low-carbon development policies.”
Score 0:
The company refers to climate policy topics but gives no evidence of actual lobbying or provides details too vague to identify any specific climate-related policy.
Definition:
How explicitly the company describes the methods it uses to engage policymakers or regulatory bodies, and whether it names the specific policymaking target.
Scoring Criteria:
Score 3:
The company discloses at least three specific lobbying methods (e.g., letters, meetings) and clearly identifies specific targets of lobbying (e.g., named policymakers or government bodies), or it transparently explains why it does not engage in climate lobbying.
Score 2:
The company discloses at least two specific lobbying mechanisms and clearly identifies the specific targets of those efforts. It may also state non-engagement in climate lobbying without providing any justification.
Score 1:
The company either describes a specific lobbying mechanism without naming the policymaking target, or names the target (e.g., UK Parliament) without explaining how it engaged (e.g., through meetings or submissions).
Score 0:
The company makes vague references to lobbying (e.g., “key stakeholders” or “governments”) without specifying who or how, or it describes lobbying methods with no clear connection to climate policy or targets.
Definition:
How clearly the company states the outcomes it wants to achieve through lobbying.
Scoring Criteria:
Score 3:
The company clearly identifies all or at least three specific desired policy changes or outcomes it aims to achieve through supporting or opposing policy (e.g., amendments, new targets, or subsidies). Alternatively, it may state that it does not seek specific outcomes and explain why, showing transparency in its approach.
Score 2:
The company discloses at least two specific desired policy changes or outcomes it aimed to achieve through supporting or opposing policy. It may also earn this score by transparently stating non-engagement in climate lobbying without explaining its non-engagement.
Score 1:
The company expresses general support or opposition for climate policies but without detailing specific policy goals, proposals, or measurable changes. Any stated opposition lacks clarity about what the company supports instead.
Score 0:
The company acknowledges lobbying activity but does not explain what policy changes or outcomes it seeks, offering only vague engagement descriptions without a stated goal.
To determine a company’s overall score for climate lobbying transparency, the following approach is taken:
Addition of Scores:
The scores for each of the three disclosure categories (PL, LM, and OS) are added together to get a sum between 0 and 9.
Mapping to Overall Score:
This sum is then mapped to an overall score according to the following scale:
Sum 0: Overall Score 0 (“None”)
Sum 1–4: Overall Score 1 (“Limited”)
Sum 5–6: Overall Score 2 (“Moderate”)
Sum 7–8: Overall Score 3 (“Strong”)
Sum 9: Overall Score 4 (“Comprehensive”)
This final overall score reflects the transparency and clarity of a company’s climate policy lobbying disclosures.
Objective:
To evaluate the quality and transparency around the company’s governance processes for managing climate lobbying. A governance process is defined as the internal mechanisms, oversight structures, monitoring, and accountability measures the company uses to ensure climate lobbying alignment—not simply statements of lobbying stance, policy commitment, or expressions of support for climate goals.
Key Governance Elements:
Companies that achieve the highest governance score have:
- A clear policy and management process to review climate lobbying.
- Details on who (individuals or teams) are responsible for lobbying oversight and alignment.
- Evidence of action to align climate lobbying with values, such as lobbying audits or reviews of trade association lobbying
Scoring Scale and Criteria:
Score 4 (“Comprehensive”):
A company publishes (and plainly links to) a public, climate lobbying alignment
report or independent audit that covers both direct and indirect lobbying. It sets out a recurring process for monitoring and managing that alignment, and it names the specific individual(s) or committee – e.g., CEO, Board Sustainability Committee – holding ultimate oversight.
Score 3 (“Strong”):
All three of these points must be present: a clear policy and process (annual review, disclosure
cycle, etc.) for keeping climate lobbying on strategy; And evidence the company aligns both its own
advocacy and its trade association lobbying (engage, correct, or exit when necessary); And a named
owner (individual or committee) with responsibility for that alignment.
Score 2 (“Moderate”):
The company shows some climate lobbying governance, yet falls short of at least one
element required for a score of 3 (full monitoring detail, coverage of both channels, or a formal owner). It
must have (A) either a policy or a limited process that spells out one concrete mechanism for alignment
and (B) either a tangible lobbying alignment step or a named oversight body.
Score 1 (“Limited”):
Only some general lobbying governance is disclosed: a policy that mentions an oversight or
review step; or a generic promise to align lobbying with company climate goals; or naming a lobbying
oversight body.
Score 0 (“None”):
No evidence meets the bar for a score of 1. The company either says it has no climate lobbying
governance, or references only legal compliance/transparency registers / PAC data, or says nothing
about lobbying or lobbying governance at all.