WH Smith PLC

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Limited WH Smith provides only limited transparency on its climate-related lobbying. It identifies broad policy areas it engages on—citing work with the British Retail Consortium on “climate change, waste and food policy,” involvement in the “development of single-use plastics policy and deposit return schemes,” and responses to government consultations on HFSS in Scotland and Wales—but it does not name any specific bills, regulations or reforms, so readers cannot see precisely which climate measures the company tries to influence. The company does disclose some channels and targets of engagement, noting that it works with “government departments on specific initiatives,” participates in “BRC working groups,” engages with “DEFRA and the Scottish Government,” and liaises with “head office constituency MPs,” indicating at least two distinct mechanisms (industry forums and consultation responses) and identifiable policymaking bodies. However, it never spells out the concrete legislative changes or quantitative targets it wants those bodies to adopt; instead it offers only general aspirations such as transitioning to net-zero emissions or reducing single-use plastics, without specifying the policy outcomes it seeks. As a result, while WH Smith reveals a handful of engagement routes and thematic focus areas, the disclosure lacks the detail needed to understand which climate policies it is lobbying on and what positions it is advocating. 1
Lobbying Governance
Overall Assessment Comment Score
Moderate WH Smith PLC has implemented a formal process to align its climate-related policy engagement with its net-zero ambitions; “any policy engagement regarding energy and climate change needs to adhere to our policy position on the need to adopt a pathway to net zero emissions by 2050,” and “there is a requirement to involve the Director of Sustainability in any external dealings on energy and climate change.” Additionally, the company reports that “there is a regular agenda item on climate-change issues at the business risk committees,” where senior management reviews any requirements for external engagement. It also confirms a public commitment to “conduct your engagement activities in line with the goals of the Paris Agreement.” However, the company does not disclose oversight over indirect lobbying through trade associations, nor does it publish a dedicated audit or detailed review process for climate lobbying alignment beyond these coordination steps. 2