London Stock Exchange Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	London Stock Exchange Group PLC has established a defined governance process for climate-related policy engagement, anchored in its Sustainability Committee and complemented by its SFI Policy Working Group. As disclosed, "The Group Sustainability Committee coordinates activities across the Group, partnering with all business areas to ensure consistency of engagement and approach with both internal and external stakeholders" and "All Government Relations and policy initiatives involve the development of position papers which are submitted to the Sustainability Committee," ensuring that "topics with possible areas of overlap with sustainability and climate change issues" are consistent with the Group’s overall climate change strategy. Moreover, LSEG details that "to oversee the implementation of our engagement strategy, we have in place an SFI Policy Working Group ... [that] meets on a weekly basis" and that its "Sustainability Committee of senior leaders ... provides sign off on policy-related documents and papers where required." The company notes that "The LSEG Board has ultimate oversight of the organisation’s sustainability strategy, including its management of climate-related risks and opportunities" and that "Sustainability, including climate, is considered by the Board at least twice a year." It also maintains a "public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement." While these disclosures indicate clear responsibility and an ongoing review process for direct policy engagement, we found no evidence of a formal mechanism to align or monitor indirect lobbying through industry or trade associations. View Sources	C

Overall Assessment

Analysis

Score

Moderate

London Stock Exchange Group PLC has established a defined governance process for climate-related policy engagement, anchored in its Sustainability Committee and complemented by its SFI Policy Working Group. As disclosed, "The Group Sustainability Committee coordinates activities across the Group, partnering with all business areas to ensure consistency of engagement and approach with both internal and external stakeholders" and "All Government Relations and policy initiatives involve the development of position papers which are submitted to the Sustainability Committee," ensuring that "topics with possible areas of overlap with sustainability and climate change issues" are consistent with the Group’s overall climate change strategy. Moreover, LSEG details that "to oversee the implementation of our engagement strategy, we have in place an SFI Policy Working Group ... [that] meets on a weekly basis" and that its "Sustainability Committee of senior leaders ... provides sign off on policy-related documents and papers where required." The company notes that "The LSEG Board has ultimate oversight of the organisation’s sustainability strategy, including its management of climate-related risks and opportunities" and that "Sustainability, including climate, is considered by the Board at least twice a year." It also maintains a "public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement." While these disclosures indicate clear responsibility and an ongoing review process for direct policy engagement, we found no evidence of a formal mechanism to align or monitor indirect lobbying through industry or trade associations.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	London Stock Exchange Group PLC provides extensive and concrete information about its climate-policy lobbying. It names a wide range of specific measures it seeks to shape, including the “UK Sustainability Disclosure Requirements and Investment Labels,” the “EU Corporate Sustainability Reporting Directive,” the “EU Emissions Trading Scheme,” the “EU Taxonomy and Sustainable Finance Disclosure Regulation,” the “EU Climate Transition and Paris-Aligned Benchmarks,” and the UK Government’s “Transition Plan Taskforce Disclosure Framework.” The Group also details how it tries to influence these rules: it conducts “bilateral engagement with policymakers and regulators in key jurisdictions,” supplies experts to bodies such as the “EU Technical Expert Group on Sustainable Finance,” sits on advisory forums like the “Green Technical Advisory Group,” hosts policy launches at its London offices, responds to regulator consultations, and coordinates the activity through its Government Relations and Regulatory Strategy team. Finally, LSEG is explicit about the results it is pursuing—calling for “mandatory disclosure rules for companies which adopt or align with the ISSB standards by 2025,” publication of economy-wide transition plans, simplification of the EU Taxonomy, reforms to the SFDR to give greater prominence to transition finance, and improved Scope 3 requirements for CTB and PAB benchmarks. This level of specificity about the policies, the engagement channels, and the concrete regulatory changes sought demonstrates a comprehensive degree of transparency in the company’s climate-related lobbying.	A