Swedish Orphan Biovitrum AB

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Swedish Orphan Biovitrum AB provides very limited insight into how it governs its lobbying activities. The only disclosure that directly touches on climate-related advocacy is its acknowledgement that it has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement – Yes,” which signals an intention to align any policy engagement with climate goals but does not explain how this is implemented or overseen. Other governance descriptions – for example the “Corporate compliance committee, consisting of the CEO, CFO, General Counsel, and Chief Compliance Officer, [which] oversees compliance investigations” and the statement that the “Global Compliance Governance Charter ensures the management oversight of the compliance programme” – relate to general compliance, anti-corruption and whistle-blowing rather than to lobbying or trade-association engagement. The company does not disclose any mechanism for monitoring or approving its direct or indirect lobbying, does not identify a board or executive body charged with reviewing lobbying alignment, and does not report on trade-association positions or corrective actions. Accordingly, while a high-level commitment to Paris-aligned engagement is declared, the absence of any disclosed processes or oversight specific to lobbying indicates only limited governance in this area. View Sources	D

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Sobi provides only limited transparency around its climate-related – or, more accurately, health-sector – policy lobbying. It names just one identifiable initiative, the EU Pharmaceutical Strategy, while the rest of its disclosures refer only to broad “rare-disease innovation policies” and unspecified Swedish life-science legislation, leaving the specific bills or regulations engaged on unclear. The company says it “engag[es] with stakeholders such as the European Commission, European Parliament, payers, patient advocacy groups, and healthcare professionals” and that it influences policy indirectly through SwedenBIO, which “collects views and input from the industry when it comes to legislation affecting the life-science industry in Sweden,” yet it does not describe concrete mechanisms such as formal consultations, letters, or meetings. On outcomes, Sobi expresses a generic ambition for “a regulatory framework that fosters rare disease innovation in Europe” and notes that “The ability to speak with one strong voice towards the government benefits Sobi and all life-science companies operating in Sweden,” but it does not spell out the specific legislative changes, targets, or incentives it is seeking. Together, these disclosures offer only a high-level view of the company’s lobbying goals, mechanisms, and policy focus, without the detail needed to demonstrate robust transparency.	D