AFRY AB

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	AFRY offers only limited transparency around its climate-policy lobbying. It refers to broad legislative packages—stating that “several sustainability initiatives and legislations such as the EU Green Deal, Fit for 55, REPowerEU and EU taxonomy will drive investments” and highlighting Sweden’s goal of a climate-neutral industry by 2045—but it does not make clear which of these measures it has actually sought to influence or provide identifying details for any bill or regulation. The company describes a handful of engagement channels, most concretely the appointment of its EVP and Head of Infrastructure to the Swedish Government’s “Innovation partnership programme Climate neutral industry” and its organisation of panels in the Swedish pavilion at COP28 “to demonstrate our support for ambitious and long-term climate policy,” yet it rarely specifies whether these involve meetings, written submissions, or other direct contacts, and it names only the Swedish Government and Parliament as explicit targets. Finally, AFRY outlines only general ambitions—supporting the halving of emissions by 2030 and eventual net-zero, showcasing low-carbon solutions and “policies promoting solutions aligned with the 1.5°C ambition”—without detailing the concrete policy changes or amendments it is pressing for. Taken together, the disclosures signal intent to engage on climate legislation but leave most of the substance, methods and desired outcomes unexplained.	1

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	AFRY AB has established a policy-driven framework that links its sustainability commitments to its external policy engagement, as its “sustainability policy guides the company in participating in engagement activities that are consistent with our climate commitment” and its “sustainability e-learning, which is mandatory for all employees, is the process in which we ensure that the organization’s engagement activities are consistent with the overall climate change strategy.” The company has also initiated “mapping on our trade and business associations on Group level for alignment with the 1.5 degree ambition” and holds a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” even noting that “By engaging directly with policy makers through high-level forums such as COP26, we challenge the way we work today.” These elements demonstrate a concrete policy and process to align both indirect and direct lobbying with the company’s climate strategy, but the company does not disclose any specific individual or formal body charged with overseeing or reviewing these lobbying activities, nor does it describe a structured approval, sign-off, or recurring audit process for its policy engagement beyond the initial mapping, and we found no evidence of regular monitoring mechanisms for climate lobbying alignment.	2