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| Overall Assessment |
Comment |
Score |
| Limited |
Associated British Foods provides only limited detail on its climate-policy lobbying. It names one identifiable policy arena—“Adaptation to Climate Change” under the UK Climate Change Act 2008—and notes its participation in the UK Parliament’s inquiry on the sustainability of the fashion industry, but otherwise refers only to broad themes such as waste management and voluntary initiatives, giving little clarity on the full range of policies it seeks to influence. The company does disclose two concrete mechanisms and their targets: it states that “ABF’s Director of Company Secretariat is a member of the Committee on Climate Change’s Adaptation Committee,” which advises “the UK Government and Devolved Administrations,” and that “Primark’s head of ethical trade and environmental sustainability responded to the request to submit evidence” to the House of Commons Environmental Audit Committee. Beyond those examples, its lobbying activities are described only in generic terms such as participation in trade associations or multi-stakeholder charters, with no explanation of how those groups lobby policymakers. The outcomes the company says it is pursuing are expressed as broad aspirations—cutting food-sector emissions or aligning with the UNFCCC Fashion Charter’s net-zero ambition—without specifying the legislative changes, amendments, or targets it is asking governments to adopt. Taken together, these disclosures reveal some engagement but fall short of a detailed, transparent account of the policies, mechanisms, and concrete outcomes the company is lobbying for.
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1
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| Overall Assessment |
Comment |
Score |
| Moderate |
Associated British Foods PLC has established a governance process requiring that “any public policy engagement conducted by the businesses must be approved at a senior level,” overseen by the Director of Legal Services and Company Secretary, who “acts as the focal point for communications to the Board and with shareholders on corporate responsibility matters,” supported by the Group Corporate Responsibility Director, who “is responsible for monitoring climate-related activities across the Group.” The company also “liaise[s] with Public Relations and other advocacy-related roles within the businesses to ensure alignment on key environmental topics” and has set up “a steering committee to oversee the governance of our TCFD programme.” Engagement activities are subject to “a formal annual reporting process whereby the businesses provide information on their internal activities, work with their value chain and any public policy activities related to a range of corporate responsibility issues including climate change,” and these activities “are reviewed at least annually to ensure alignment with group strategy and the policy landscape.” While this indicates senior-level accountability and a recurring review mechanism that incorporates climate considerations into public policy engagement, the company does not disclose any dedicated framework for aligning its direct and indirect lobbying with its climate policy, nor does it publish an audit or report specifically evaluating the alignment of lobbying activities with its climate-related goals.
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2
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