PepsiCo Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	PepsiCo Inc has demonstrated a comprehensive level of transparency regarding its climate lobbying activities. The company has clearly disclosed its engagement with specific climate policies, such as the EU Green Deal, EU Climate Law, ETS, CBAM, LULUCF reforms, the Carbon Farming Initiative, and the Packaging and Packaging Waste Regulation. It has also provided details about its involvement in the 'Fit for 55' policy package and the carbon dividend framework proposed by the Climate Leadership Council (CLC). These disclosures include identifiable details about the policies engaged, demonstrating a high level of transparency. PepsiCo has outlined its lobbying mechanisms and targets in detail, including direct submissions to the European Commission, participation in public consultations, and engagement with U.S. federal lawmakers through events like Ceres' annual meetings. The company has also disclosed indirect lobbying efforts through trade associations such as FoodDrinkEurope and the Climate Leadership Council, as well as its registration in the EU Transparency Registry and compliance with the U.S. Lobbying Disclosure Act. Specific lobbying mechanisms, such as signing letters and declarations, engaging in conversations with the European Commission, and funding organizations like the World Resources Institute, are clearly outlined. Furthermore, PepsiCo has been transparent about the specific policy outcomes it aims to achieve, such as supporting the EU Climate Law's goal of climate neutrality by 2050, advocating for a carbon dividend framework in the U.S., and promoting subsidies on infrastructure. The company has articulated its alignment with the Paris Agreement and its own net-zero ambitions, stating that 'the vision of the EU Climate Law is aligned with our pledge for Business Ambition for 1.5 Degree C and a long-term net zero target.' These disclosures reflect a detailed and transparent articulation of desired policy outcomes, mechanisms, and targets, showcasing PepsiCo's comprehensive approach to climate lobbying transparency.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	PepsiCo demonstrates a strong governance process for ensuring its climate lobbying activities align with its broader climate strategy. The company has clearly delineated oversight led by its Corporate Affairs department, as illustrated by the statement, "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." This detailed description is further enhanced by evidence of monitoring and management practices, such as when the company notes that it "regularly reviews the climate change positions taken by our trade associations," and directs its trade associations in writing regarding the appropriate use of dues, thereby ensuring consistent alignment in its indirect lobbying efforts. In addition, the involvement of its Board of Directors, which "recognizes that the use of company resources in the political process is an important issue for shareholders and other stakeholders," and the leadership of the Corporate Senior Vice President, Public Policy and Government Affairs, underscore robust accountability and oversight. Although one source referenced PepsiCo's general sustainability governance without specific details on lobbying, the comprehensive disclosures about direct and indirect lobbying oversight decisively illustrate a well-defined process for ensuring that climate lobbying activities are consistently aligned with its stated climate objectives.	3