Grafton Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Grafton Group PLC acknowledges that it “work[s] with our industry/trade bodies to directly and positively influence policy, law, or regulation that may impact the climate” and asserts that “our participation in this is consistent with our sustainability strategy,” which suggests the company considers the alignment of its indirect lobbying with its climate ambitions. It further explains that “climate change governance follows the sustainability governance process set out on page 109,” under which “the Board has ultimate strategic responsibility and delegates day to day delivery and oversight to the CEO and Executive Sustainability Committee,” and that climate risks and opportunities are captured in the corporate risk register and reviewed by the Group Risk Committee. However, the company does not disclose any specific lobbying-governance policy or procedure, nor does it identify a dedicated body or individual responsible for reviewing or approving its engagement activities. We found no evidence of a formal sign-off process, monitoring mechanism, or audit to ensure that both its direct and indirect lobbying efforts remain fully aligned with its overall climate-change objectives. View Sources	D

Overall Assessment

Analysis

Score

Limited

Grafton Group PLC acknowledges that it “work[s] with our industry/trade bodies to directly and positively influence policy, law, or regulation that may impact the climate” and asserts that “our participation in this is consistent with our sustainability strategy,” which suggests the company considers the alignment of its indirect lobbying with its climate ambitions. It further explains that “climate change governance follows the sustainability governance process set out on page 109,” under which “the Board has ultimate strategic responsibility and delegates day to day delivery and oversight to the CEO and Executive Sustainability Committee,” and that climate risks and opportunities are captured in the corporate risk register and reviewed by the Group Risk Committee. However, the company does not disclose any specific lobbying-governance policy or procedure, nor does it identify a dedicated body or individual responsible for reviewing or approving its engagement activities. We found no evidence of a formal sign-off process, monitoring mechanism, or audit to ensure that both its direct and indirect lobbying efforts remain fully aligned with its overall climate-change objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E