NCC AB

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	NCC AB provides a moderate level of transparency on its climate-related lobbying. It names two concrete policy areas it has engaged on—“New Swedish procurement requirements to reach the climate goals on national and local level” and engagement with “Norwegian authorities to increase the use of climate criteria in public tendering”—which allows readers to identify where the company is focusing its advocacy. The company also explains how and where it seeks to influence these policies, describing that it is “taking active part in cooperation with Sweden's procurement authority, responding to referrals and taking active part in workshops,” and identifies the specific targets of those efforts as “Sweden's procurement authority” and “Norwegian authorities,” thereby giving a clear picture of its lobbying mechanisms and audiences. However, it is considerably less specific about what it hopes to achieve beyond signalling general backing for the measures, merely stating “Support with no exceptions” without detailing any particular amendments, thresholds or timelines it is pressing for. As a result, while the mechanisms and policy arenas are well-described, the company’s desired policy outcomes remain largely undefined.	2

Lobbying Governance

Overall Assessment	Comment	Score
None	NCC AB does not disclose any processes for governing its lobbying activities. The only available text is simple navigational cues such as "Jump to main content", and there is no reference to oversight structures, monitoring or management procedures, explicit alignment policies for climate lobbying, or any named individual or committee responsible for reviewing lobbying efforts. We found no evidence of a lobbying-governance policy, no description of how direct or indirect lobbying is aligned with company goals, and no third-party audits or internal review processes addressing climate or other policy lobbying.	0