Lobbying Governance
| Overall Assessment | Analysis | Score |
|---|---|---|
| Limited |
Mandatum offers only limited insight into how it governs climate-related lobbying. The Responsible Investment Policy states that “specifically regarding the Paris Agreement on Climate Change, Mandatum monitors companies that lobby against climate action and have not been able to reduce their emissions” and confirms that its portfolio “did not include these types of companies in the reference period,” showing a commitment to review and screen investee companies’ lobbying behaviour. The policy further explains that if a breach is found, “the incident is investigated, and measures are taken on a case-by-case basis… direct dialogue with the investee company’s executive management… or, as a last resort, divestment,” indicating a procedural response to misaligned lobbying. However, we found no evidence describing how Mandatum oversees or reviews its own direct advocacy or its membership in trade associations, nor any mention of a board committee or named executive responsible for ensuring Mandatum’s lobbying aligns with its climate positions. The ESG team and Senior ESG Manager are presented as coordinating “responsible investment,” but there is no explicit reference to them monitoring or managing Mandatum’s lobbying activity. Consequently, while the company discloses a screening process for investee companies’ anti-climate lobbying, it does not publicly detail an internal governance framework for its own lobbying or policy engagement activities, indicating only limited lobbying-governance disclosure.
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D |