Cromwell Property Group – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Cromwell Property Group states that “all engagement activities must be consistent with our Sustainability Framework and climate change policy,” and that “engagement is reviewed and approved by management,” which indicates a policy and oversight step intended to align its advocacy activities with its climate strategy. The company further affirms a public commitment to conduct engagement in line with the “goals of the Paris Agreement.” However, we found no evidence of differentiated processes for direct lobbying and its “active corporate participation in industry associations,” no criteria for assessing or influencing association positions that may conflict with its climate policy, and the company does not disclose any specific individual or formal body responsible for overseeing or reviewing its lobbying or policy engagement activities. View Sources	D

Overall Assessment

Analysis

Score

Limited

Cromwell Property Group states that “all engagement activities must be consistent with our Sustainability Framework and climate change policy,” and that “engagement is reviewed and approved by management,” which indicates a policy and oversight step intended to align its advocacy activities with its climate strategy. The company further affirms a public commitment to conduct engagement in line with the “goals of the Paris Agreement.” However, we found no evidence of differentiated processes for direct lobbying and its “active corporate participation in industry associations,” no criteria for assessing or influencing association positions that may conflict with its climate policy, and the company does not disclose any specific individual or formal body responsible for overseeing or reviewing its lobbying or policy engagement activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E