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”):
The company must publish an annual lobbying report or detailed study outlining its governance processes for both direct and indirect lobbying (including efforts through trade associations). The company must explicitly describe the policies and processes in place to monitor and manage its climate lobbying activities. Specific individuals or groups—such as the CEO or head of ESG—must be designated to oversee these efforts.
Score 3 (“Strong”):
The company must align its lobbying efforts, which includes both direct lobbying and lobbying through trade associations. This includes establishing a clear policy and management process to monitor and ensure the alignment of its climate lobbying activities. Specific individuals or groups (such as the CEO, head of ESG, or relevant working groups) should be designated to oversee these efforts.
Score 2 (“Moderate”):
The company must either mention how it aligns its lobbying efforts—including both direct lobbying and activities via trade associations—or describe a management process or policy for aligning its climate lobbying. Alternatively, the company can identify the specific individuals or groups (such as the CEO or a dedicated working group) responsible for overseeing this alignment.
Score 1 (“Limited”):
The company may provide only a general or limited mention of its climate lobbying governance or policy. It might offer a basic statement about efforts to ensure external lobbying alignment without robust details, or simply reference trade association lobbying alignment on climate issues.
Score 0 (“None”):
The company either explicitly states that it lacks a climate lobbying governance or alignment process or discusses ESG or climate governance without mentioning lobbying. It may also provide vague references to lobbying or policy influencing without outlining a proper governance structure or alignment measures, or only offer generic statements about compliance with lobbying regulations and transparency standards.