NIKE Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	NIKE Inc. provides an unusually full picture of its climate-policy advocacy. It names multiple distinct measures it has engaged on, including the “U.S. Department of State Clean Energy Demand Initiative,” USAID’s “Vietnam Low Emission Energy Program (V-LEEP)” and the associated renewable-energy Direct Power Purchase Agreement pilot, the U.S. Department of Energy’s “Better Buildings Challenge,” and support for an Oregon carbon cap-and-trade bill, among others. The company is equally clear on how it seeks to influence these policies, citing direct meetings such as “At COP26, NIKE executives met with government officials,” collaborative work with “the U.S. Agency for International Development (USAID) Vietnam Low Emission Energy Program (V-LEEP),” coalition activity like “joining 330 companies in 2020 to call on the U.S. Congress to include long-term climate solutions in future economic recovery plans,” and ongoing engagement with specific agencies such as the Vietnam Ministry of Industry and Trade and the Electricity Regulatory Authority of Vietnam. NIKE also spells out the results it wants to achieve: finalisation of the Vietnamese DPPA so that it can “secure renewable electricity for nearly 100 % of our owned and operated spaces in Vietnam,” mechanisms to manage cost risk within that scheme, a U.S. economic-recovery package that contains “long-term climate solutions,” passage of competitive clean-energy market rules, and facility-level goals like a “reduce energy intensity by 20 % by 2025.” By linking these defined policy objectives to clearly identified lobbying channels and targets, the company demonstrates a high level of transparency across all facets of its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	NIKE’s disclosures indicate that its Board’s Corporate Responsibility, Sustainability & Governance Committee "oversees NIKE’s corporate governance, as well as the risks and opportunities associated with NIKE’s three Purpose pillars – People, Planet, and Play," and that NIKE "is sharpening its policy advocacy efforts to open up renewable energy procurement opportunities in our key sourcing markets" and that "we strive to progress our internal commitments on climate change and emissions reduction while influencing other businesses to make similar commitments." The company also affirms a public commitment to conduct its engagement activities in line with the goals of the Paris Agreement ("Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement? […] Yes"). However, we found no evidence of a specific climate lobbying alignment policy, a structured review or monitoring process for direct and indirect lobbying, or designation of a named individual or committee explicitly responsible for overseeing and aligning lobbying activities with NIKE’s climate strategy.	1