Dollarama Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Dollarama Inc. demonstrates a robust ESG governance framework, with multiple oversight bodies such as the Board of Directors, Audit Committee, and ESG Steering Committee supervising ESG and climate matters. For example, “The Audit Committee has been delegated the primary risk oversight responsibility, including with respect to cybersecurity, ESG risk oversight, and reports periodically to the Board of Directors on its findings,” and the CFO “leads the Corporation’s ESG and climate strategy, including reporting progress to the Audit Committee.” Despite this comprehensive governance structure for ESG and climate-related risks, we found no evidence of any dedicated processes, policies, or oversight mechanisms to govern direct or indirect lobbying activities or to ensure alignment of lobbying positions with the company’s climate or ESG objectives. The company does not disclose any policy requiring review or sign-off of lobbying engagements, does not identify who is responsible for lobbying alignment, and does not describe any procedure to manage or monitor lobbying through trade associations, indicating an absence of lobbying governance disclosures in its public filings. View Sources	E

Overall Assessment

Analysis

Score

None

Dollarama Inc. demonstrates a robust ESG governance framework, with multiple oversight bodies such as the Board of Directors, Audit Committee, and ESG Steering Committee supervising ESG and climate matters. For example, “The Audit Committee has been delegated the primary risk oversight responsibility, including with respect to cybersecurity, ESG risk oversight, and reports periodically to the Board of Directors on its findings,” and the CFO “leads the Corporation’s ESG and climate strategy, including reporting progress to the Audit Committee.” Despite this comprehensive governance structure for ESG and climate-related risks, we found no evidence of any dedicated processes, policies, or oversight mechanisms to govern direct or indirect lobbying activities or to ensure alignment of lobbying positions with the company’s climate or ESG objectives. The company does not disclose any policy requiring review or sign-off of lobbying engagements, does not identify who is responsible for lobbying alignment, and does not describe any procedure to manage or monitor lobbying through trade associations, indicating an absence of lobbying governance disclosures in its public filings.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	Dollarama provides clarity on its limited approach to lobbying by stating that it “does not engage in public policy lobbying at scale” and has “no specific issues of focus.” The company explains that it “may, at times, communicate with government officials and legislators” while ensuring “formal registration prior to engaging in lobbying.” Furthermore, it underscores its stance by stating that it “does not make any political contributions, in kind or in cash, whether directly or indirectly,” and prohibits employees from doing so on its behalf. Overall, while these disclosures demonstrate transparency about non-engagement with public policy, we found no evidence of any engagement specifically related to climate policy.	E