LPP SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	LPP SA’s disclosures emphasize its broader ESG oversight, noting that in December 2021 it “decided to create, within the structures directly reporting to me, the position of ESG director” who “reports directly to the president of the Management Board of LPP,” supported by an “ESG Committee” and with the “Supervisory Board obtain[ing] regular and comprehensive information” on ESG activities. However, we found no evidence of any internal mechanisms, approval or review steps specifically governing its lobbying or policy advocacy, nor any processes to align direct or indirect lobbying with its climate objectives. The only indication of a commitment to align policy engagement is its statement of having a “public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement,” but the company does not disclose how such engagement is monitored, managed or overseen within its lobbying framework. View Sources	D

Overall Assessment

Analysis

Score

Limited

LPP SA’s disclosures emphasize its broader ESG oversight, noting that in December 2021 it “decided to create, within the structures directly reporting to me, the position of ESG director” who “reports directly to the president of the Management Board of LPP,” supported by an “ESG Committee” and with the “Supervisory Board obtain[ing] regular and comprehensive information” on ESG activities. However, we found no evidence of any internal mechanisms, approval or review steps specifically governing its lobbying or policy advocacy, nor any processes to align direct or indirect lobbying with its climate objectives. The only indication of a commitment to align policy engagement is its statement of having a “public commitment or position statement to conduct [its] engagement activities in line with the goals of the Paris Agreement,” but the company does not disclose how such engagement is monitored, managed or overseen within its lobbying framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E