VGP NV – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	VGP NV discloses that “as outlined in our Political Activity Policy and Code of Conduct, VGP has a principal policy of no political engagement,” clarifying that “Employees may participate in political activities in their own free time and should in no way suggest VGP support,” with exceptions subject to group approval. Although the company affirms “Yes” to having “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” it does not articulate any structures or procedures to ensure that its climate-related engagement—conducted “predominantly through participation in government and trade associations” such as through “active dialogue with CRREM Management” or cooperation with DGNB—aligns with its climate goals. There is no disclosure of an oversight body or named individual responsible for reviewing lobbying positions, no described process for monitoring or managing these activities, and no criteria for assessing the stance of associations, which indicates only limited governance for its climate lobbying efforts. View Sources	D

Overall Assessment

Analysis

Score

Limited

VGP NV discloses that “as outlined in our Political Activity Policy and Code of Conduct, VGP has a principal policy of no political engagement,” clarifying that “Employees may participate in political activities in their own free time and should in no way suggest VGP support,” with exceptions subject to group approval. Although the company affirms “Yes” to having “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” it does not articulate any structures or procedures to ensure that its climate-related engagement—conducted “predominantly through participation in government and trade associations” such as through “active dialogue with CRREM Management” or cooperation with DGNB—aligns with its climate goals. There is no disclosure of an oversight body or named individual responsible for reviewing lobbying positions, no described process for monitoring or managing these activities, and no criteria for assessing the stance of associations, which indicates only limited governance for its climate lobbying efforts.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E