Marks & Spencer Group PLC

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Marks & Spencer provides a highly transparent picture of its climate-policy lobbying. It names multiple concrete policy files it has worked on, including the Government’s plans to reform “Extended Producer Responsibility,” the “Environmental Land Management Scheme (ELMS),” and its submission to the “Skidmore Review on Net Zero Legislation,” each described with clear thematic and geographic context. The company is equally specific about how and to whom it lobbies: it “provided written evidence to the Skidmore Review into Net Zero,” followed up with “oral evidence at a roundtable event with Chris Skidmore,” has “engaged with policy-makers at Defra and the devolved administrations, including officials, ministers and special advisers,” and has “signed a joint letter to the Environment Secretary,” demonstrating a mix of direct testimony, ministerial meetings and coalition letters aimed at clearly identified targets. Finally, M&S spells out the changes it is seeking: for EPR it wants measures that “drive behaviour change not only from business but also from local authorities,” including “increased onshoring of recycling services, more recycling of hard to recycle items and a focus on making it easier to recycle on the go packaging,” funded through a “hypothecated charge”; for ELMS it calls for “clarity and speedy delivery of the roll-out,” and in the Skidmore Review it backed outcomes such as “low impact farming, green skills, reducing packaging [and] electrification of truck fleets.” By clearly identifying the policies, the engagement channels and the concrete outcomes it advocates, M&S demonstrates comprehensive transparency around its climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Strong Marks & Spencer Group PLC has implemented a defined review process for its lobbying activities, stating that “M&S Company contributions and submissions are reviewed and approved by a joint Government Affairs and Sustainability sign-off group before being made,” which provides structured oversight of its direct engagement with policymakers. It also exercises oversight of its indirect lobbying through industry bodies, noting that “where we do not believe that a submission on an important issue from our two key UK trade bodies (Confederation of British Industry and British Retail Consortium) adequately reflects our position – we will make an individual submission,” thereby ensuring its policy positions remain aligned with its objectives. The company further affirms that it has a public commitment “to conduct [its] engagement activities in line with the goals of the Paris Agreement,” underlining its climate-focused stance. However, the company does not disclose a dedicated climate-lobbying audit or report, nor a third-party assessment of lobbying alignment, and we found no evidence of a formal board-level sign-off or a named executive with sole responsibility for overseeing the alignment of its lobbying with its climate strategy, indicating that the process lacks a detailed monitoring framework and explicit accountability structures for climate-related lobbying efforts. 3