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Foresight Group’s disclosures focus extensively on risk management—"The Committee meets at least three times per year" and the Group operates a "three lines of defence (“3LOD”) model" with oversight by the Audit & Risk Committee—yet we found no evidence of any framework governing the company’s lobbying activities, whether direct or through industry associations. The company does not disclose a policy to align lobbying with its climate or broader public-policy goals, no process for reviewing or monitoring lobbying alignment, and no individual or formal body designated to oversee or review such engagement. Accordingly, there is no indication of a governance structure in place to manage or align its climate-related lobbying efforts.
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Foresight Group Holdings Ltd provides virtually no transparency around any climate-related lobbying. The disclosures merely describe policy areas such as the Woodland Carbon Code’s potential inclusion in the UK Emissions Trading Scheme and refer broadly to frameworks like RED III and the Inflation Reduction Act, but they do not state that the company tried to influence these measures. There is no description of meetings, correspondence, industry association activity, or any other mechanism directed at policymakers, nor are any target institutions or officials identified. Likewise, the company does not articulate what specific legislative or regulatory outcomes it supports or opposes. Overall, the materials review policies in an informational manner without revealing any actual lobbying activity or intentions, leaving no evidence of climate-policy lobbying transparency.
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