Kellanova – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Kellanova integrates its lobbying and advocacy oversight within its broader ESG governance framework, with the Board’s Social Responsibility & Public Policy Committee explicitly stating that "the Committee reviews the Company's policies, programs and practices concerning public policy, government relations, philanthropic activities/charitable contributions, climate, sustainability and related topics" and confirming that "policies and strategies overseen by the SRPP Committee are also aligned with our lobbying, advocacy, and membership efforts." It further explains that "engagement on direct and indirect activities are further coordinated by our Chief Sustainability Officer, who interacts regularly with company leaders on our sustainability goals, including our Government Relations teams," reflecting formal oversight and some process integration. However, the company does not disclose a dedicated climate-lobbying review procedure, criteria for evaluating alignment of trade association memberships, or a documented mechanism to ensure all lobbying positions are consistent with its climate commitments. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Kellanova integrates its lobbying and advocacy oversight within its broader ESG governance framework, with the Board’s Social Responsibility & Public Policy Committee explicitly stating that "the Committee reviews the Company's policies, programs and practices concerning public policy, government relations, philanthropic activities/charitable contributions, climate, sustainability and related topics" and confirming that "policies and strategies overseen by the SRPP Committee are also aligned with our lobbying, advocacy, and membership efforts." It further explains that "engagement on direct and indirect activities are further coordinated by our Chief Sustainability Officer, who interacts regularly with company leaders on our sustainability goals, including our Government Relations teams," reflecting formal oversight and some process integration. However, the company does not disclose a dedicated climate-lobbying review procedure, criteria for evaluating alignment of trade association memberships, or a documented mechanism to ensure all lobbying positions are consistent with its climate commitments.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Kellanova demonstrates a high level of transparency in its climate lobbying activities. The company names specific legislation and regulations it has engaged, including the US Clean Power Plan, the 2016 Michigan Energy Bill, and the Growing Climate Solutions Act, as well as participation in COP21, COP22, and COP23 negotiations. It describes a range of direct and indirect mechanisms—membership in BICEP, advocacy days, signing letters to Congress through the American Business Act on Climate Pledge, Hill visits, panel discussions at global climate events, and workshops with government leaders—and identifies targets such as US policymakers, the US Environmental Protection Agency, and business leaders. The outcomes it seeks are clearly stated: scaling conservation practices on farmland, generating new income through carbon markets, promoting clean energy generation, and reducing carbon pollution. These disclosures collectively demonstrate a comprehensive transparency around its climate policy lobbying.	A