Smurfit Kappa Group PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Smurfit Kappa is reasonably forthcoming about the climate-related policy files it tries to shape, explicitly naming the EU Packaging and Packaging Waste Regulation (PPWR), the EU Deforestation Regulation (EUDR) and the broader EU Green Deal framework, and noting its engagement with emissions-trading discussions through the Confederation of European Paper Industries. By contrast, it is much less specific about how it exerts influence: the company mainly points to its membership of trade associations such as CEPI, FEFCO and the European Round Table of Industrialists and says it takes part in “committees and round-table discussions,” but it does not spell out concrete tactics such as letters, formal consultations or direct meetings with identified officials, nor does it name the individual institutions or lawmakers it approaches. The firm is explicit, however, about the changes it wants to see. It argues that “cardboard packaging is already 100 percent recyclable and biodegradable” and should therefore be prioritised over plastic within the PPWR, warns that proposed mandatory reuse rules for transport packaging “would pull the rug out from under the world’s best recycling system,” and supports emissions-trading rules that “prevent carbon leakage and promote added-value approaches to wood raw materials.” These clear statements of preferred outcomes, together with the identification of multiple concrete policy dossiers, show a high level of transparency on what the company wants from policymakers, even though the channels it uses to pursue those outcomes remain only partially described.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Smurfit Kappa discloses that it seeks to keep its external engagement aligned with its sustainability goals, stating that it is "involved with selected trade bodies to influence understanding and share knowledge about embedding sustainability throughout operations" and that it "upholds standards on a variety of matters material to our business, representing them to the parties concerned, either directly or through industry bodies." The company also confirms that it has "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement." These statements indicate an intention to align both direct and trade-association engagement with its climate strategy, which suggests some awareness of lobbying alignment; however, the disclosure does not explain how this alignment is ensured—there is no mention of an internal review mechanism, no description of monitoring procedures or audits, and no identification of a specific executive or board committee responsible for overseeing lobbying activities. We found no evidence of a structured process for evaluating trade-association positions, corrective actions for misalignment, or regular reporting on lobbying alignment, so the governance appears limited and largely aspirational rather than systematically governed.	1