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BCPG PCL’s disclosures focus on sustainability and risk management oversight rather than any process for governing its lobbying activities. Its Corporate Governance and Sustainable Development Committee and Enterprise-wide Risk Management Committee, for example, “Review good corporate governance and sustainable development practices including climate change guideline using TCFD and making recommendations to the Board of Directors for continuous improvement,” while its Corporate Sustainability Committee “Review climate-related risks and opportunities management performance” and “Provide recommendations on sustainable development policies, further strategy or action plans, and targets of Carbon Neutrality by 2030 and Net Zero GHG emission by 2050.” The company also maintains Anti-Corruption Practice Guidelines that state “The Company is a politically neutral organization. It supports compliance with the law and democratic regime of government with the king as head of state and does not have any policy to support, directly or indirectly, any political party,” and that directors and employees “shall not undertake any political activities in the Company nor exploit any resources of the Company in undertaking such activities,” backed by a Disbursement Policy requiring that “disbursement requests must be supported by valid documentation with a view to prevent improper payment to support political activities and to ensure that any charitable donation is not a form of corruption in disguise.” However, we found no evidence of any policy or process that governs direct or indirect lobbying or any committee or individual tasked with reviewing or aligning lobbying with the company’s climate objectives, indicating that the company does not disclose any lobbying governance framework.
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