J M Smucker Co/The – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	J M Smucker Co/The has implemented a structured approach to ensure its external engagement activities align with its climate strategy, centered around a cross-functional Sustainability Steering Committee and reporting lines to senior leadership and the Board. According to the company, “we have multiple processes in place to ensure that activities are coordinated across the Company in a coherent manner,” and this committee, “sponsored by the Vice President, ESG, Deputy General Counsel and Assistant Secretary and chaired by the Director, Sustainability,” meets quarterly to review “developments related to our participation in trade associations and research organizations” and ensure “our activities in these organizations are consistent with our overall climate change strategy.” The committee’s activities are reported to executive officers, including the CEO, and to the Board’s Nominating, Governance, and Corporate Responsibility Committee. Additionally, the company maintains a public commitment “to conduct your engagement activities in line with the goals of the Paris Agreement.” While this demonstrates clear processes for coordinating indirect lobbying through trade associations and defined accountability by naming the VP-ESG and the sustainability committee chair, the company does not disclose any specific mechanism for overseeing or reviewing direct lobbying efforts or an audit of lobbying alignment with its climate policy. View Sources	C

Overall Assessment

Analysis

Score

Moderate

J M Smucker Co/The has implemented a structured approach to ensure its external engagement activities align with its climate strategy, centered around a cross-functional Sustainability Steering Committee and reporting lines to senior leadership and the Board. According to the company, “we have multiple processes in place to ensure that activities are coordinated across the Company in a coherent manner,” and this committee, “sponsored by the Vice President, ESG, Deputy General Counsel and Assistant Secretary and chaired by the Director, Sustainability,” meets quarterly to review “developments related to our participation in trade associations and research organizations” and ensure “our activities in these organizations are consistent with our overall climate change strategy.” The committee’s activities are reported to executive officers, including the CEO, and to the Board’s Nominating, Governance, and Corporate Responsibility Committee. Additionally, the company maintains a public commitment “to conduct your engagement activities in line with the goals of the Paris Agreement.” While this demonstrates clear processes for coordinating indirect lobbying through trade associations and defined accountability by naming the VP-ESG and the sustainability committee chair, the company does not disclose any specific mechanism for overseeing or reviewing direct lobbying efforts or an audit of lobbying alignment with its climate policy.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E