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| Overall Assessment |
Comment |
Score |
| Strong |
Mondelez International provides a high level of clarity on the climate-related policy areas it engages with, naming several identifiable measures such as “Extended Producer Responsibility (EPR) schemes for packaging,” “supply chain due diligence requirements,” “climate-related financial disclosure requirements,” and participation in the “Ghana Cocoa Forest REDD+ Program.” The company also discloses the results it wants from these engagements, for example stating that it “support[s] well-designed EPR schemes that fund recycling infrastructure for flexible plastic packaging,” wants due-diligence rules that are “effective in addressing the shared goal without creating unintended negative effects,” and backs “enhanced reporting requirements … on climate-related risk material to investor decisions” with convergence of standards across jurisdictions. However, the description of how it seeks to influence policymakers is much less detailed: references to indirect channels such as membership in the U.S. Chamber of Commerce, co-chairing the Consumer Goods Forum palm-oil group, or “working with governments on the details” do not spell out specific tools (e.g., meetings, submissions or letters) or consistently name the governmental bodies addressed. Overall, the company is transparent about what climate policies it lobbies and the outcomes it seeks, but offers only limited insight into the concrete mechanisms and targets of its lobbying activity.
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| Overall Assessment |
Comment |
Score |
| Strong |
Mondelez International describes a defined governance structure that seeks to keep both its direct and indirect lobbying consistent with its climate objectives. It states that "our Governance, Membership and Sustainability Committee also annually receives a report on our government relations strategies, lobbying activities, and political contributions, and at least annually, we give a similar report to the full Board of Directors," showing regular board-level oversight. Operational control is supported by “internal compliance policies [that] require advance business and legal approval of all lobbying activities and political contributions … with final approval by the Director of Government Affairs,” indicating a clear sign-off chain for direct engagement. On climate alignment, the company explains that “Close coordination between our Corporate and Government Affairs and Impact teams ensures that our external representations to governments reflect the company's sustainability goals,” and publicly confirms that its engagement is “in line with the goals of the Paris Agreement.” For indirect lobbying, Mondelez discloses that it “has memberships in many trade associations, and we do not always agree with all of their policy positions, which we regularly review,” adding that “In instances where the Company does not share certain views of its associations, the Company makes those positions known through the Company’s representatives within those associations,” and that it “instruct[s] trade associations that they cannot use our dues to support or oppose candidates and regularly monitor whether association positions are consistent with the Company’s interests.” These statements demonstrate that the company monitors and seeks to influence associations whose policy stances differ from its own climate position. However, the disclosure does not mention a dedicated public climate-lobbying alignment report, an external audit, or the criteria and outcomes of its trade-association reviews, and it does not describe any cases of exiting or suspending memberships. Overall, the evidence indicates strong internal processes and board oversight for aligning lobbying with climate strategy, but the depth of monitoring and transparency falls short of a comprehensive, publicly reported climate-lobbying audit.
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