Walt Disney Co/The – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Walt Disney Co/The articulates a policy and process to align its direct lobbying with its climate strategy by stating that "Our Global Public Policy team collaborates closely with our Government Affairs teams to ensure consistency between our lobbying positions and our stated environmental goals" and affirming a "public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." It further notes that "we closely monitor regulatory changes, progress made among corporate peers, and expectations of our guests and employees," indicating active vigilance over external developments. However, the company does not disclose any formal review or audit of its climate lobbying, and there is no specific individual or committee identified to oversee or enforce alignment. Although the Governance and Nominating Committee "reviews the Company’s political contributions activity and policy," the company does not provide equivalent transparency about its lobbying governance processes or any mechanisms by which it assesses the positions of trade associations or takes corrective action where conflicts arise. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Walt Disney Co/The articulates a policy and process to align its direct lobbying with its climate strategy by stating that "Our Global Public Policy team collaborates closely with our Government Affairs teams to ensure consistency between our lobbying positions and our stated environmental goals" and affirming a "public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." It further notes that "we closely monitor regulatory changes, progress made among corporate peers, and expectations of our guests and employees," indicating active vigilance over external developments. However, the company does not disclose any formal review or audit of its climate lobbying, and there is no specific individual or committee identified to oversee or enforce alignment. Although the Governance and Nominating Committee "reviews the Company’s political contributions activity and policy," the company does not provide equivalent transparency about its lobbying governance processes or any mechanisms by which it assesses the positions of trade associations or takes corrective action where conflicts arise.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E