DS Smith PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	DS Smith PLC provides a highly detailed account of its climate-policy lobbying. It lists multiple concrete legislative files it engages on, including the “Revision of the Packaging and Packaging Waste Directive,” the “EU Deforestation Regulation,” the “Revision of the Emissions Trading System Directive,” the “EU Carbon Border Adjustment Mechanism,” the “UK Packaging Waste Regulations (including UK EPR),” and the “Revision of the Renewable Energy Directive,” as well as proposals for both EU and UK Carbon Border Adjustment Mechanisms and other sector-specific rules such as “eco-design for e-commerce packaging.” The company is equally explicit about how and where it lobbies. It describes “participating in regular dialogue on packaging and waste policies,” holding “meetings with MPs about our local operations,” “responding to a range of government consultations,” publishing advocacy papers, and working indirectly through trade bodies such as FEFCO, CEPI, EUROPEN, 4evergreen, CPI and The Packaging Federation. Targets are named unambiguously: “European Commission and Parliament representatives,” “UK Government, Members of Parliament, ambassadors,” and “local government representatives, e.g. mayors, Councillors,” supported by a dedicated Government Affairs function that coordinates these interactions. DS Smith also spells out the specific policy outcomes it seeks. It calls for “increased support for lower carbon energy sources” and “clearer deployment timelines” to enable heat decarbonisation, urges that “EPR reforms [be used] as an opportunity to deliver long-term investment in recycling infrastructure,” wants “policy instruments that promote the use of packaging solutions that have lower environmental impact across their lifecycle,” and asks policymakers to “avoid using policy instruments that might favour fossil-based packaging over paper-based packaging.” These stated goals are tied to measurable objectives such as meeting the paper sector’s 2030 emission-reduction targets and raising recycling rates. Taken together, the breadth of policies named, the clear description of lobbying channels and targets, and the concrete outcomes pursued demonstrate a comprehensive level of transparency in the company’s climate-related lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	DS Smith PLC demonstrates a structured approach to climate lobbying governance by integrating its lobbying function into its broader sustainability framework: its “Group Government Affairs team leads our engagement with policy makers, trade associations and other organisations whose activities may influence policy, law, or regulation that may significantly impact the climate” and “sits under the Group Corporate Affairs Function, within the Government, Community Affairs and Sustainability team,” ensuring “engagement activities are consistent with our overall climate change strategy.” This governance forum is complemented by the Health, Safety, Environment and Sustainability Committee, which “meets on a monthly basis” and explicitly discusses “Government affairs and the policy environment” alongside its 1.5°C roadmaps and GHG forecasts, and supported by a “public commitment ... to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the company does not disclose a specific individual tasked with signing off or reviewing lobbying positions, nor does it outline detailed monitoring, audit procedures, or criteria for reassessing its indirect lobbying through trade associations where positions may diverge from its climate strategy.	2