Mars Group Holdings Corp

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Mars Group Holdings Corp has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly named multiple specific climate policies it engaged with, including the "U.S. Department of State RFI for public comment on policies needed to combat international deforestation," the "Inflation Reduction Act (IRA)," the "EU Deforestation Regulation," the "Farm Bill," the "Green Claims proposal / Empowering Consumers for the Green Transition," and the "EU Carbon Removal Certification Framework." These disclosures include detailed information about the focus areas, such as climate transition plans, carbon reduction incentives, and climate change mitigation, as well as the geographical scope of engagement. The company has also provided detailed information about its lobbying mechanisms, such as attending "stakeholder meetings convened by the Department of State," leading "the submission of comments through both the Sustainable Food Policy Alliance (SFPA) and the National Confectioners Association (NCA)," and participating in "a US Private Sector Dialogue on Commodity Driven Deforestation hosted by the We Mean Business Coalition, Ceres, and the Tropical Forest Alliance." It has identified clear targets, including "representatives from the US State Department and White House," "policymakers and NGOs on deforestation legislation," and "MEPs through our Trade Associations (in particular through AIM – the European Brands Association)." This level of detail enhances the clarity of its lobbying efforts. Furthermore, Mars Group Holdings Corp has been transparent about the specific outcomes it seeks, such as advocating for "a policy with a high level of ambition and inclusion of key levers for enforcement (penalties, access to justice, regular checks by competent authorities)," supporting climate-related practices in the Conservation Title of the Farm Bill, and ensuring "carbon farming certificates to be accounted for as part of scope 1, 2 and 3 for relevant stakeholders." The company has also clarified its positions, such as supporting the climate-related elements of the IRA and advocating for stricter frameworks around carbon neutral claims to avoid greenwashing. These disclosures reflect a clear articulation of its lobbying goals and alignment with the Paris Agreement, demonstrating a high level of transparency in its climate lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Strong Mars has disclosed a defined governance process to ensure alignment of its climate lobbying activities, including monitoring details and responsible parties. The company states that "Mars participates in all policy engagement and research that we support, enabling us to ensure these activities remain consistent with our climate change strategy." This indicates a process for monitoring alignment. Furthermore, Mars mentions that "The selection of the organizations and policy initiatives we support is managed by our internal Sustainability Working Group and overseen by our Sustainability Leadership Team," which identifies the responsible parties for overseeing climate lobbying alignment. Additionally, Mars describes its approach to indirect lobbying through trade associations, noting that "As paying members of the organizations we support, we can influence their positions, policies and research objectives," and that "On the rare occasions we cannot reach a compromise, we are willing to advocate independently or adopt internal policies to govern our activities." This demonstrates a policy to ensure alignment of climate lobbying activities. While the evidence does not mention a detailed lobbying audit or comprehensive review, the governance process described is robust and includes oversight structures, monitoring mechanisms, and accountability measures. 3