Drax Group PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Drax Group provides extensive, specific and consistent information about its climate-policy lobbying. It names a wide range of identifiable measures it engages on, including UK and EU Emissions Trading Scheme developments, the Carbon Border Adjustment Mechanism, the EU Renewable Energy Directive and LULUCF rules, consultations on a UK “transitional support mechanism for large-scale biomass generators,” the Power BECCS business-model consultation, the UK Government’s long-duration electricity storage framework, and U.S. Inflation Reduction Act provisions such as the 45Q tax credit. The company also discloses how and where it presses its views, citing “one-to-one meetings with officials in HMT, Department for Energy Security and Net Zero and the European Commission (ENVI, ITRE, AGRI, ENER),” “responses to public consultations (e.g. EU Taxonomy),” participation in All-Party Parliamentary Groups, public events in Westminster and Brussels, and indirect advocacy “through relevant European and UK trade associations,” thereby identifying multiple direct and indirect mechanisms and the precise government bodies and legislators targeted. Finally, Drax is explicit about what it wants those engagements to deliver: it is “advocating for a strong carbon price, encouraging investment in low-carbon generation technologies”; urging that “the UK ETS should link to the EU ETS”; seeking a two-part mechanism combining a power Contract for Difference with a carbon payment to support BECCS; promoting “legislative change to recognise the value of negative emissions”; and supporting a cap-and-floor regime to unlock investment in long-duration storage. By clearly describing the policies addressed, its channels of influence, and the specific changes it is seeking, the company demonstrates a comprehensive level of transparency around its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Drax discloses a structured process to keep its policy advocacy aligned with its climate strategy, noting that “An annual Group engagement strategy is formulated … This is presented and signed off by the Board and Executive Committee and then cascaded to business units,” which indicates both a recurring review mechanism and top-level oversight. The company adds that “We have a dedicated External Affairs team that is responsible for coordinating external messaging and engagement such that it is consistent with our climate change strategy,” showing an operational function charged with monitoring day-to-day lobbying activity. Material used for engagement is “reviewed regularly via internal working groups to ensure it is consistent with our climate change strategy,” providing evidence of an internal checkpoint that goes beyond one-off approvals. Responsibility is further anchored in the broader sustainability structure: “the Board is ultimately responsible for sustainability… The Chief Sustainability Officer is also a member of the Executive Committee, and has established an internal structure to ensure delivery of our sustainability aims,” underscoring named individuals and committees involved in oversight. However, the disclosure does not describe how Drax evaluates or manages its indirect lobbying through trade associations, nor does it mention conducting or publishing a formal climate-lobbying alignment review, so the governance currently appears focused on direct engagement and internal messaging rather than a comprehensive assessment of all lobbying channels.	2