General Mills Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	General Mills discloses its climate-policy lobbying in a highly granular way. It names numerous concrete measures it works on – the 2023 Farm Bill, the bipartisan Growing Climate Solutions Act, the EPA Clean Power Plan, the Soil Health and Income Protection Program, the Regional Conservation Partnership Program, the Recycling Infrastructure Accessibility Act, the Recycling and Composting Accountability Act and the Paris Climate Accord – leaving little doubt about the exact legislation and regulatory programs it seeks to influence. The company also explains how it engages: it testifies before congressional committees, submits written comments, joins coalition days on Capitol Hill, registers as a federal and state lobbyist, and meets directly with specific officials, stating for example that “we engaged senior officials at the USDA on how the government can support farmers who want to pursue regenerative practices.” It further works through industry bodies such as AMERIPEN, the Consumer Brands Association, the Organic Trade Association, Ceres, and the California Water Action Collaborative, identifying Congress, USDA, EPA, FDA and state departments of agriculture as its principal targets. Finally, General Mills is explicit about the policy changes it is pursuing, including adoption of “a comprehensive, national climate policy” with a price on carbon, keeping the United States in the Paris Agreement, advancing regenerative agriculture on one million acres by 2030, achieving no-deforestation in key commodities by 2025, strengthening organic standards, and expanding U.S. recycling infrastructure. By clearly outlining the policies, the mechanisms it uses, and the concrete outcomes it wants, the company demonstrates a comprehensive level of transparency around its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	General Mills discloses a governance structure that links climate strategy with its political engagement, indicating a moderate level of control over lobbying activities. The company states that "the Public Responsibility Committee of our board of directors is made up of outside directors and oversees all company political activity, including political expenditures, corporate political contributions, major trade association memberships and more," while the Global Impact Governance Committee, "led by our Chairman and CEO … is accountable for our sustainability and climate programs." Its policy requires that "use of Company funds for political contributions anywhere in the world requires approval in writing from the appropriate operating executive, the General Counsel and the Vice President, Government Relations," and that "all direct contributions to independent political expenditure campaigns must be approved by the Company’s Public Responsibility Committee," showing a defined sign-off mechanism. The company also confirms a climate-specific commitment, noting that it "believe[s] that advocating for policies that provide proportionate, clear guidance on mitigation and adaptation of climate change effects is essential" and in its CDP response states it has "a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement." These disclosures demonstrate a policy framework and identify the board-level body and senior executives responsible for reviewing both direct lobbying and trade-association involvement, which indicates meaningful governance. However, the evidence does not reveal any systematic review or published assessment of whether the positions of individual trade associations align with the company’s climate goals, nor does it document actions taken to correct or end misaligned lobbying; there is "no evidence" of a dedicated climate-lobbying audit, public alignment report, or examples of engagement outcomes. Consequently, while oversight structures are clear, the transparency around monitoring processes and the effectiveness of ensuring climate-aligned lobbying remains limited.	2