OX2 AB – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	OX2 AB’s disclosures focus extensively on sustainability governance, with the Board issuing a Code of Conduct that “forms the basis for other policies” and requiring that “Significant departures from the Code of Conduct and policies are reported directly to the Board,” and a sustainability team led by the Head of Sustainability and overseen by the CEO—who “reports on the achievement of selected sustainability goals to the Board on a quarterly basis.” The sustainability framework is supported by an Audit Committee–approved internal control process and clearly defined roles, with the sustainability team convening a council “to drive the sustainability agenda and coordinate sustainability matters.” However, we found no evidence of any governance processes, policies, oversight bodies, or named individuals specifically tasked with overseeing or aligning the company’s direct or indirect lobbying activities (including climate-related lobbying) with its sustainability or climate objectives. View Sources	E

Overall Assessment

Analysis

Score

None

OX2 AB’s disclosures focus extensively on sustainability governance, with the Board issuing a Code of Conduct that “forms the basis for other policies” and requiring that “Significant departures from the Code of Conduct and policies are reported directly to the Board,” and a sustainability team led by the Head of Sustainability and overseen by the CEO—who “reports on the achievement of selected sustainability goals to the Board on a quarterly basis.” The sustainability framework is supported by an Audit Committee–approved internal control process and clearly defined roles, with the sustainability team convening a council “to drive the sustainability agenda and coordinate sustainability matters.” However, we found no evidence of any governance processes, policies, oversight bodies, or named individuals specifically tasked with overseeing or aligning the company’s direct or indirect lobbying activities (including climate-related lobbying) with its sustainability or climate objectives.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E