Energizer Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Energizer Holdings discloses that its “global Government Affairs team,” “reporting up through the general counsel and working with the business units,” “leads our participation in the public policy-making process at the national, state and local levels, as well as internationally” and that it “maintains an internal policy to help ensure the company and its colleagues adhere to our political involvement guidelines.” The company also states that it “complies with all applicable laws that require reporting on lobbying and related activities” and “participates in a number of state and national trade associations” where its colleagues “serve in a leadership capacity.” However, beyond noting oversight of its Supplier Code of Conduct—where “the Head of Sustainability is responsible for the day-to-day application of the policy” and “the Board through its Human Capital Committee is responsible overseeing the Policy’s implementation”—there is no evidence of any Board or executive-level oversight specific to lobbying, no described process for reviewing or aligning direct or indirect climate lobbying activities, and no indication of a dedicated review or audit of climate-related lobbying or associations’ positions. View Sources	D

Overall Assessment

Analysis

Score

Limited

Energizer Holdings discloses that its “global Government Affairs team,” “reporting up through the general counsel and working with the business units,” “leads our participation in the public policy-making process at the national, state and local levels, as well as internationally” and that it “maintains an internal policy to help ensure the company and its colleagues adhere to our political involvement guidelines.” The company also states that it “complies with all applicable laws that require reporting on lobbying and related activities” and “participates in a number of state and national trade associations” where its colleagues “serve in a leadership capacity.” However, beyond noting oversight of its Supplier Code of Conduct—where “the Head of Sustainability is responsible for the day-to-day application of the policy” and “the Board through its Human Capital Committee is responsible overseeing the Policy’s implementation”—there is no evidence of any Board or executive-level oversight specific to lobbying, no described process for reviewing or aligning direct or indirect climate lobbying activities, and no indication of a dedicated review or audit of climate-related lobbying or associations’ positions.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Energizer Holdings offers only limited transparency on its climate-related lobbying. It discloses that it spent $381,600 on lobbying in 2022 and notes that a global Government Affairs team coordinates engagement largely through trade associations, but it does not name any specific climate policies or legislation it seeks to influence, nor does it identify the government bodies or policymakers targeted by these associations. The company also fails to explain the policy positions it supports or opposes, or the concrete regulatory outcomes it aims to achieve. Consequently, its disclosure is restricted to a general statement of spending and organisational involvement, without meaningful detail on the focus, channels, or objectives of its climate lobbying activities.	D