Intermediate Capital Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Intermediate Capital Group PLC discloses a limited but defined process for keeping its policy-engagement activities in line with its climate strategy. It states that “new engagement initiatives through industry bodies or trade associations (such as Invest Europe or BVCA); are discussed and approved by the Executive Directors of ICG to ensure alignment to our climate change approach,” and adds that “the ESG team, who develops and implements the climate change approach, is involved in such engagement initiatives to ensure alignment.” This demonstrates a concrete mechanism for screening indirect lobbying via trade associations and identifies the Executive Directors and the ESG team as the parties responsible for sign-off and implementation. The company also makes “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement,” indicating an explicit policy objective against which alignment is judged. However, we found no evidence of a systematic, published review of all trade-association positions, no disclosures on how the company governs its own direct lobbying activities, and no description of any board committee specifically overseeing lobbying or receiving regular lobbying-alignment reports; oversight references centre on broader ESG and investment processes rather than political advocacy. Therefore, while the company shows some governance by requiring executive approval and ESG team involvement for climate-related engagements, the disclosure lacks detail on monitoring, auditing, or corrective actions and does not cover direct lobbying, indicating only a moderate level of lobbying-governance transparency. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Intermediate Capital Group PLC discloses a limited but defined process for keeping its policy-engagement activities in line with its climate strategy. It states that “new engagement initiatives through industry bodies or trade associations (such as Invest Europe or BVCA); are discussed and approved by the Executive Directors of ICG to ensure alignment to our climate change approach,” and adds that “the ESG team, who develops and implements the climate change approach, is involved in such engagement initiatives to ensure alignment.” This demonstrates a concrete mechanism for screening indirect lobbying via trade associations and identifies the Executive Directors and the ESG team as the parties responsible for sign-off and implementation. The company also makes “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement,” indicating an explicit policy objective against which alignment is judged. However, we found no evidence of a systematic, published review of all trade-association positions, no disclosures on how the company governs its own direct lobbying activities, and no description of any board committee specifically overseeing lobbying or receiving regular lobbying-alignment reports; oversight references centre on broader ESG and investment processes rather than political advocacy. Therefore, while the company shows some governance by requiring executive approval and ESG team involvement for climate-related engagements, the disclosure lacks detail on monitoring, auditing, or corrective actions and does not cover direct lobbying, indicating only a moderate level of lobbying-governance transparency.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Intermediate Capital Group PLC is fully transparent about its position on climate-related lobbying. The company makes a clear, unambiguous declaration that "It is ICG’s policy not to make any political contributions or lobby policy makers. No contributions were made during the 18 months to 30 September 2022 for political purposes," and reiterates that it does not engage in climate lobbying. By explicitly stating that it undertakes no direct or indirect attempts to influence specific legislation, naming no policies, and explaining its rationale for abstaining, ICG provides complete disclosure on the policies it lobbies (none), the mechanisms it uses (none), and the outcomes it seeks (none). This forthright explanation gives readers certainty about the absence of lobbying activity and demonstrates a high level of transparency.	A