Holmen AB – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Holmen has established a basic framework for overseeing its advocacy, noting that “Holmen is active in promoting the growth of sustainable energy production, and bio-based and fossil-free activities, through dialogue, consultation responses, preparedness and advocacy work, on its own and together with industry organisations,” and that “strategic evaluation and prioritisation of issues that may affect Holmen in the longer term is carried out under the leadership of the CEO.” It further states that “Group Business Strategy and group wide Business Objectives are monitored and reported on by business unit managers in quarterly Business Reviews to group management,” and there is a confirmed public commitment to align engagement with the “goals of the Paris Agreement.” However, the company does not disclose any specific procedures for evaluating the alignment of its direct lobbying or its involvement in national and international industry organisations with its climate objectives, nor does it provide criteria for engaging with or exiting associations whose positions may conflict with its climate goals. We found no evidence of a formal review process dedicated to climate lobbying or a named committee beyond executive leadership that specifically oversees lobbying alignment, indicating that the governance framework remains at a high level without detailed monitoring mechanisms or clear indirect lobbying management. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Holmen has established a basic framework for overseeing its advocacy, noting that “Holmen is active in promoting the growth of sustainable energy production, and bio-based and fossil-free activities, through dialogue, consultation responses, preparedness and advocacy work, on its own and together with industry organisations,” and that “strategic evaluation and prioritisation of issues that may affect Holmen in the longer term is carried out under the leadership of the CEO.” It further states that “Group Business Strategy and group wide Business Objectives are monitored and reported on by business unit managers in quarterly Business Reviews to group management,” and there is a confirmed public commitment to align engagement with the “goals of the Paris Agreement.” However, the company does not disclose any specific procedures for evaluating the alignment of its direct lobbying or its involvement in national and international industry organisations with its climate objectives, nor does it provide criteria for engaging with or exiting associations whose positions may conflict with its climate goals. We found no evidence of a formal review process dedicated to climate lobbying or a named committee beyond executive leadership that specifically oversees lobbying alignment, indicating that the governance framework remains at a high level without detailed monitoring mechanisms or clear indirect lobbying management.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Holmen provides only a basic level of transparency about its climate-related lobbying. It identifies broad policy arenas—such as the EU Green Deal, Swedish forestry legislation and the FSC certification system—but does not list specific bills, regulatory proposals or dates, so readers cannot see exactly which measures the company tries to influence. The company describes its approach in general terms, noting that it carries out "advocacy work, on its own and together with industry organizations" and organises "consultation and information meetings," yet it does not spell out whether these take the form of written submissions, face-to-face meetings or public consultations with particular ministries or legislators. Likewise, while it signals an interest in reforming FSC Sweden’s standards and in advancing "sustainable energy production" and other "bio-based and fossil-free activities," it does not articulate precise policy outcomes, targets or amendments it is seeking. The result is a disclosure that acknowledges engagement but leaves the substance, methods and objectives of that engagement largely unstated.	D