NKT A/S – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	NKT A/S provides some insight into how it governs climate-related advocacy by stating that it has "established a Public Affairs function that would be overall responsible of the ensuring the public engagements are aligned with NKT overall strategy and climate strategy in particular" and highlighting that "the cooperation with the group sustainability is also ensured." This disclosure indicates a designated internal body with responsibility for overseeing alignment between lobbying activities and the company’s climate strategy, which suggests an emerging governance process rather than a purely ad-hoc approach. The company also affirms a high-level commitment by answering "Yes" to having "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," demonstrating that climate objectives are intended to guide its external engagement. However, NKT does not disclose how this Public Affairs function actually monitors or reviews specific lobbying actions, provide any details on escalation or corrective steps, or discuss the oversight of indirect lobbying through industry associations; nor does it identify board-level involvement, regular audits, or reports on alignment outcomes. Overall, the evidence points to a developing governance framework with a responsible function and stated alignment intent, but the lack of granular processes, monitoring mechanisms and coverage of trade-association lobbying suggests only moderate transparency and strength. View Sources	C

Overall Assessment

Analysis

Score

Moderate

NKT A/S provides some insight into how it governs climate-related advocacy by stating that it has "established a Public Affairs function that would be overall responsible of the ensuring the public engagements are aligned with NKT overall strategy and climate strategy in particular" and highlighting that "the cooperation with the group sustainability is also ensured." This disclosure indicates a designated internal body with responsibility for overseeing alignment between lobbying activities and the company’s climate strategy, which suggests an emerging governance process rather than a purely ad-hoc approach. The company also affirms a high-level commitment by answering "Yes" to having "a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," demonstrating that climate objectives are intended to guide its external engagement. However, NKT does not disclose how this Public Affairs function actually monitors or reviews specific lobbying actions, provide any details on escalation or corrective steps, or discuss the oversight of indirect lobbying through industry associations; nor does it identify board-level involvement, regular audits, or reports on alignment outcomes. Overall, the evidence points to a developing governance framework with a responsible function and stated alignment intent, but the lack of granular processes, monitoring mechanisms and coverage of trade-association lobbying suggests only moderate transparency and strength.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	NKT A/S provides a comprehensive level of transparency around its climate policy lobbying activities. It details a variety of lobbying approaches, noting its use of “seminars, panel debates” and “meetings with civil servants at the Ministry for Foreign Affairs in Sweden and Denmark during the autumn of 2021 and spring of 2022,” alongside direct engagement with “Danish and Swedish Members of the EU Parliament and their staff,” the “Danish Representation to the EU in Brussels,” and participation in “formal and informal discussions” at COP27. The company clearly names the policies it has engaged on, including “renewable energy generation,” “electricity grid access for renewables,” and “introducing climate and environmental indicators as evaluation criteria in the tender processes,” under the framework of the European Green Deal. It also articulates the specific outcomes it seeks, advocating for “a faster and more predictable process to get faster planning and execution of renewable energy generation projects,” upgrading national grids to handle increased renewable power and electric vehicles, and measures to “introduce carbon footprint as an evaluation criteria for tenderers” and achieve “shorter permitting time.” These disclosures demonstrate a high level of detail on mechanisms, policy targets, and desired legislative outcomes.	A