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China Modern Dairy’s disclosures focus on its internal climate risk management and dual-carbon planning rather than any lobbying governance processes; for example, it states “We have established a climate risk governance structure with the Board of Directors as the top leadership” and that “the CEO of Modern Dairy is responsible for the overall planning and promotion of the Company's dual-carbon efforts,” but we found no evidence of any mechanisms for overseeing or aligning the company’s direct or indirect lobbying activities with its climate or policy objectives. The disclosures describe departmental responsibilities for “carbon reduction, emissions reduction and climate risk defense” and regular reporting to the Board on these initiatives, yet the company does not disclose any policy, review process, oversight body, or named individual tasked with governing lobbying. This indicates that while China Modern Dairy has strong climate risk governance, it provides no transparency around lobbying governance or alignment.
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