Rolls-Royce Holdings PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Rolls-Royce Holdings PLC provides a highly detailed picture of its climate-policy lobbying. It names a broad slate of specific initiatives it has worked on, including the “EU Fit for 55 package”, the “EU SAF blending mandate”, the “EASA Environmental Labelling Programme”, the European Union’s “Clean Aviation Joint Undertaking”, its support for the ICAO long-term net-zero goal, and the UK-focused Hydrogen in Aviation alliance linked to the Jet Zero Strategy, demonstrating clear disclosure of the exact policies and legislative frameworks it seeks to influence. The company is equally explicit about how it lobbies and whom it targets: it reports “direct conversations with policy-makers from all EU Institutions (in person and written)”, “participation in stakeholder roundtables” and “official EU consultations”, “1-2-1 engagements with government ministers representing climate, transport, energy and environment”, representation on the Clean Aviation Governing Board, and work through the HIA alliance that will act “constructively with Government, local authorities, and the aviation and hydrogen sectors”. These statements identify both the mechanisms (meetings, written submissions, board membership, public-private partnerships) and the target bodies (European Commission, EU Institutions, UK Government and local authorities). Finally, Rolls-Royce spells out the policy outcomes it is pursuing: it supports “proposals on SAF mandates for aviation, consensus on emissions reduction pathways for maritime, more ambitious clean energy targets, and a more ambitious ETS, including the provision of maritime emissions for the first time”; it pushes for “a long-term net zero carbon goal for the aviation sector”, for “increasing SAF usage across the aviation industry”, and for the UK to focus on “supporting the delivery of the infrastructure needed for the UK to be a global leader” in hydrogen-powered flight. By clearly linking each engagement to a concrete objective and stating the reasons for its positions, the company demonstrates a comprehensive level of transparency across all aspects of its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Rolls-Royce has established a comprehensive framework to govern its climate-related policy engagement, requiring both direct advocacy with policymakers and indirect engagement through its trade association memberships to align with its decarbonisation strategy, but it does not identify a specific individual or committee charged with reviewing or approving these lobbying activities. According to the company, “We have a well established framework for our climate-related policy engagement, which includes a public position on the global policy principles we advocate for,” and it commits that “For each trade association or industry body engagement we look to align these principles, and our broader position on climate change, with those that we work with. This includes a review of their stated positions on climate change and commitments to net zero.” The process also sets out that “if we were unable to reconcile differences in our position on climate change we will ultimately look to cease relationships with that entity.” Rolls-Royce describes its direct lobbying as “engaging our government partners in our core geographies in support of the policy principles set out above,” and its indirect lobbying by “working with industry groups and trade associations to accelerate climate commitments in line with the Paris Climate Agreement goals.” While it notes that “Delivery of our sustainability approach ... is overseen by the Safety, Ethics & Sustainability Committee ... at Board level, and the environment & sustainability committee,” the company does not disclose that either body formally oversees or signs off on the alignment of its lobbying efforts with its climate commitments.	2