PepsiCo Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	PepsiCo discloses a structured approach to keeping its lobbying positions aligned with its climate strategy, indicating strong governance. The company states that “PepsiCo’s Corporate Affairs department has specific teams and individuals who are assigned responsibilities for developing corporate policy and regulatory positions as well as engaging with external stakeholders on regulatory policy that aligns with our climate strategy,” and that this group “works closely with the business units, Sustainability Office, and other functions to ensure that our external engagements are aligned with our overall strategy on climate action and advocacy,” demonstrating an internal process that covers its direct advocacy. Oversight is clearly assigned: the Board has created a “Sustainability, Diversity and Public Policy Committee” which, according to its Charter, “oversees this policy and is responsible for reviewing the Company’s key public policy trends, issues and regulatory matters, its engagement in the public policy process and the Company’s political activities and expenditures,” while the Sustainability Office “led by the company’s Chief Sustainability Officer” provides day-to-day coordination. For indirect lobbying, PepsiCo reports that it “annually reviews the benefits and challenges from membership in our major trade associations,” requires those associations to obtain “specific consent from PepsiCo to use PepsiCo’s dues or similar payments for the funding of exceptional political expenditures,” and “regularly reviews the climate change positions taken by our trade associations,” with public disclosure of those positions through its CDP submission. These elements show active alignment mechanisms for both direct and trade-association lobbying and identify a responsible Board-level body, indicating strong governance. However, the company does not disclose a dedicated, published climate-lobbying alignment report or any third-party audit of its lobbying positions, nor does it describe the specific criteria or outcomes of its trade-association reviews, so the transparency and depth of its monitoring remain limited. View Sources	B

Overall Assessment

Analysis

Score

Strong

PepsiCo discloses a structured approach to keeping its lobbying positions aligned with its climate strategy, indicating strong governance. The company states that “PepsiCo’s Corporate Affairs department has specific teams and individuals who are assigned responsibilities for developing corporate policy and regulatory positions as well as engaging with external stakeholders on regulatory policy that aligns with our climate strategy,” and that this group “works closely with the business units, Sustainability Office, and other functions to ensure that our external engagements are aligned with our overall strategy on climate action and advocacy,” demonstrating an internal process that covers its direct advocacy. Oversight is clearly assigned: the Board has created a “Sustainability, Diversity and Public Policy Committee” which, according to its Charter, “oversees this policy and is responsible for reviewing the Company’s key public policy trends, issues and regulatory matters, its engagement in the public policy process and the Company’s political activities and expenditures,” while the Sustainability Office “led by the company’s Chief Sustainability Officer” provides day-to-day coordination. For indirect lobbying, PepsiCo reports that it “annually reviews the benefits and challenges from membership in our major trade associations,” requires those associations to obtain “specific consent from PepsiCo to use PepsiCo’s dues or similar payments for the funding of exceptional political expenditures,” and “regularly reviews the climate change positions taken by our trade associations,” with public disclosure of those positions through its CDP submission. These elements show active alignment mechanisms for both direct and trade-association lobbying and identify a responsible Board-level body, indicating strong governance. However, the company does not disclose a dedicated, published climate-lobbying alignment report or any third-party audit of its lobbying positions, nor does it describe the specific criteria or outcomes of its trade-association reviews, so the transparency and depth of its monitoring remain limited.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	PepsiCo provides a highly transparent picture of its climate-policy lobbying. It names a wide range of identifiable measures it has engaged on, including the EU Green Deal and associated Climate Law, the “Fit for 55” package (ETS, CBAM and LULUCF reforms), the European Commission’s proposed Carbon Farming Initiative and carbon removals framework, consultations on a carbon border tax, the U.S. federal carbon-dividend proposal promoted by the Climate Leadership Council, the California Low Carbon Fuel Standard, the U.S. Farm Bill, and the EU Packaging and Packaging Waste Regulation. The company also discloses how and where it lobbies: direct submissions and “conversations with the European Commission,” participation in formal public consultations, “meetings with several Capitol Hill members and staff,” quarterly filings under the U.S. Lobbying Disclosure Act, registration in the EU Transparency Register, and indirect engagement through trade associations such as FoodDrinkEurope and the Climate Leadership Council, as well as joint sign-on letters and coalition statements. Finally, PepsiCo is explicit about the outcomes it seeks, backing a “gradually rising and revenue-neutral carbon fee” with dividends, supporting the EU objective for climate-neutrality by 2050 because “the vision of the EU Climate Law is aligned with our pledge for Business Ambition for 1.5 °C,” calling for a CBAM that it “supports with minor exceptions,” urging that any revision of the Packaging and Packaging Waste Regulation ensure that “packaging circularity and reusability also entails GHG emissions reduction,” and promoting policies that “spur clean electricity, expand programs for farmers to adopt regenerative practices, accelerate investment in electric vehicles and infrastructure, and help finance closed-loop recycling systems.” This level of detail on the policies addressed, the mechanisms employed, and the specific legislative outcomes sought demonstrates comprehensive transparency in the company’s climate-related lobbying disclosures.	A