Mars Group Holdings Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Mars Group Holdings Corp provides thorough and specific disclosure of its climate-related lobbying. It identifies multiple concrete policies it has worked on, including the EU “Green Claims proposal / Empowering Consumers for the Green Transition,” the “EU Deforestation Regulation,” the “EU Carbon Removal Certification Framework,” the U.S. “Farm Bill,” the “Inflation Reduction Act,” and the “U.S. Department of State RFI on policies to combat international deforestation,” demonstrating clear transparency about the legislation it seeks to influence. The company also explains how and where it lobbies, describing direct methods such as “Capitol Hill meetings,” advocacy “with the Parliament and the Council,” and attendance at “stakeholder meetings convened by the Department of State,” as well as indirect routes through AIM, the Cocoa Coalition, the Sustainable Food Policy Alliance, and other trade bodies. Each mechanism is matched with a named target, for example “MEPs,” the “U.S. House Agriculture Committee,” and “representatives from the US State Department and White House,” giving readers a precise picture of its engagement channels and audiences. Finally, Mars sets out the concrete outcomes it is pursuing. It has advocated that carbon-neutral claims be permitted “at the brand level,” pressed for a framework with “penalties, access to justice, [and] regular checks by competent authorities” under the EU deforestation law, called for “carbon farming certificates to be accounted for as part of scope 1, 2 and 3” but not traded outside the agri-food chain, supported climate-focused practices in the Farm Bill’s Conservation Title, and backed inclusion of climate investments and clean-energy incentives in the IRA. These positions reveal not just general support but detailed, measurable objectives. Taken together, the company’s disclosures demonstrate a comprehensive level of transparency across the specific policies lobbied, the mechanisms and targets of engagement, and the concrete policy outcomes it seeks.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Mars discloses a structured approach for keeping its climate-related lobbying aligned with its wider climate strategy: it 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," covering its own advocacy as well as work "with many trade associations around the world." Oversight is explicitly assigned, as "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," signalling that a named internal body reviews and approves both direct and indirect engagements. Governance measures include participation in the engagements themselves to influence positions and the readiness that "on the rare occasions we cannot reach a compromise, we are willing to advocate independently or adopt internal policies to govern our activities," which indicates an active mechanism for addressing misalignment. The company adds that “in all external engagements, we follow the policies in the Mars Guide to Global Standards, Policies and Practices,” suggesting a common set of rules that must be followed across markets. Taken together, this shows clear policies, oversight structures and a stated process to monitor and correct lobbying alignment, although Mars does not disclose a public lobbying-alignment audit and does not reference board-level supervision, which slightly limits transparency.	3