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| Overall Assessment |
Comment |
Score |
| Comprehensive |
Swire Pacific, primarily through Cathay Pacific Airways, provides highly granular insight into its climate-related lobbying. It names several distinct policies it has tried to influence, including the European Union Emissions Trading Scheme, the development of a "global market-based measure addressing emissions from international aviation" under ICAO, Hong Kong Exchanges and Clearing’s rule mandating ESG disclosures, and the Environmental Impact Assessment for the third-runway expansion at Hong Kong International Airport, as well as the Hong Kong Government’s emerging Sustainable Aviation Fuel framework. The company also explains how it engages: it "provided past emissions/engine performance, air traffic data and future forecast plans to AAHK", took part in "EIA technical briefing groups", and works through industry bodies such as IATA’s Climate Change Task Force, the Global Market-Based Measures Task Force and the Aviation Global Deal partnership to submit consultation responses and develop policy proposals. Targets of these efforts are clearly identified—ICAO, IATA, the Airport Authority Hong Kong, HKEx and relevant Hong Kong Government departments. Swire Pacific is equally explicit about the outcomes it is seeking: it advocates that aviation emissions be regulated by a single global scheme rather than regional systems, opposes extension of the EU ETS to non-European carriers because of "market distortion" concerns, supports HKEx’s move to make ESG reporting mandatory, backs "airlines’ commitment to carbon neutral growth… for 2020", and expects the third-runway project to adopt rigorous mitigation measures. This combination of clearly named policies, detailed engagement channels and well-articulated policy positions demonstrates a very high level of transparency around the group’s climate-policy lobbying.
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4
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| Overall Assessment |
Comment |
Score |
| Moderate |
Swire Pacific discloses some structures and commitments that point to a governance process for aligning its policy engagement with its climate strategy. The company states that “Swire Pacific, as a normal business activity, will lobby government entities either directly or through trade associations to promote policies that encourage business and achieve workable legislation. All our public policy work must meet the ethical standards set out in our Code of Conduct and (where relevant) reflect our public sustainability commitments”, signalling an explicit requirement that lobbying accords with its sustainability goals. In its CDP response it explains that “The Board is ultimately accountable for sustainable development strategy and performance at Cathay Pacific. It is supported in its duties by three governance bodies… the Climate Actions Steering Group (CASG)… is tasked with ensuring that the Group’s approved climate change strategy, targets, and commitment are executed as planned”, which was provided as the process “to ensure that your engagement activities are consistent with your overall climate change strategy.” The company further confirms that it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” Together these disclosures show that there is a formal body with board-level accountability and a stated policy principle intended to keep lobbying consistent with climate objectives. However, the company does not disclose concrete monitoring procedures (e.g., systematic reviews, sign-off protocols, or audits), nor does it describe how it manages or evaluates the positions of trade associations or publishes any alignment reports, so the depth and transparency of its lobbying governance remain limited.
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2
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