Bunge Global SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Bunge provides only limited visibility into its climate-related lobbying. It identifies the broad policy areas it works on—principally “biofuel production, marketing, sustainability and trade,” as well as wider “carbon and climate-related policy”—and notes that, “Since 2020 Bunge has been participating in Fuels America, an organization that is promoting public policy that enables the growth of the biofuels, renewable diesel and sustainable aviation fuel industries.” However, it does not name the specific bills, regulations or jurisdictions involved, so readers cannot pinpoint which proposals the company is trying to shape. With respect to mechanisms, Bunge says it “aim[s] to advance our vision by engaging with policymakers, working through public policy-facing organizations, networks, and regulatory bodies,” and lists trade associations such as Fediol, Abiove, the National Oilseed Processors Association and Fuels America, but it does not describe concrete actions (e.g., meetings, submissions) or identify the government bodies it approaches. The company’s statements on desired outcomes remain general—seeking to “encourage the use of biofuel,” and asserting that “The shift from high carbon fossil-based fuel to lower carbon plant-based fuel will be an important way to reduce global CO2 emissions”—without spelling out the specific legislative changes, targets or subsidy levels it advocates. Taken together, these disclosures show some acknowledgement of climate lobbying but fall short of full transparency on the policies, tactics and ends pursued.	1

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Bunge’s governance framework provides moderate controls around its lobbying and public affairs activities, but lacks a specific, systematic process for aligning those activities with its climate goals. Political activities are subject to board-level oversight, as “Political activities are overseen at the Board level by the Corporate Governance and Nominations Committee,” and public affairs functions are managed by the “SVP Sustainability & Governmental Affairs” and a “Global Government Affairs committee” that “coordinates policies, positions and activities on an ongoing basis.” The company has publicly committed “to conduct your engagement activities in line with the goals of the Paris Agreement” and states that it “take[s] opportunities to advance pro-climate positions when feasible.” Indirect lobbying through trade associations is tracked in Bunge’s “quarterly LD-2 lobbying disclosure filings,” and when association positions conflict, the company “voice[s] the Bunge position” to advocate its views. However, Bunge does not disclose a formal climate-lobbying audit or a dedicated review process to assess alignment, nor does it specify criteria for evaluating and managing its direct lobbying activities against its Paris-aligned climate strategy.	2