Billerud Aktiebolag – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Billerud has established a structured framework for its public affairs engagements that ties its policy influence to its climate commitments, anchored in the Sustainability & Public Affairs function led by the EVP Sustainability & Public Affairs and overseen by the Public Affairs Director, who “is the most senior level in the organization accountable for implementation of the directive.” The company’s “Public Affairs Directive sets out the high-level principles and minimum requirements that comprise Billerud’s general commitment to a responsible public affairs engagement,” and it confirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” by answering “Yes.” Billerud explains that “positions and strategies for policy influence are coordinated and decided within this function” and that “policy topics discussed in our major trade organizations are aligned” through an industry organization network, demonstrating active alignment of both direct engagement and indirect lobbying via trade associations. Furthermore, the fact that “the executive management team is briefed regularly regarding positions and strategies for policy influence for significant topics” indicates recurring oversight. However, we found no evidence of a dedicated climate lobbying audit or review process specific to climate-related advocacy, nor of specific criteria for disengaging from associations whose positions conflict with Billerud’s climate goals. View Sources	B

Overall Assessment

Analysis

Score

Strong

Billerud has established a structured framework for its public affairs engagements that ties its policy influence to its climate commitments, anchored in the Sustainability & Public Affairs function led by the EVP Sustainability & Public Affairs and overseen by the Public Affairs Director, who “is the most senior level in the organization accountable for implementation of the directive.” The company’s “Public Affairs Directive sets out the high-level principles and minimum requirements that comprise Billerud’s general commitment to a responsible public affairs engagement,” and it confirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” by answering “Yes.” Billerud explains that “positions and strategies for policy influence are coordinated and decided within this function” and that “policy topics discussed in our major trade organizations are aligned” through an industry organization network, demonstrating active alignment of both direct engagement and indirect lobbying via trade associations. Furthermore, the fact that “the executive management team is briefed regularly regarding positions and strategies for policy influence for significant topics” indicates recurring oversight. However, we found no evidence of a dedicated climate lobbying audit or review process specific to climate-related advocacy, nor of specific criteria for disengaging from associations whose positions conflict with Billerud’s climate goals.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Billerud provides only limited visibility into its climate-related lobbying. It says that its Sustainability and Public Affairs team “monitors political and legislative developments” in areas such as forestry, environmental, energy, trade and recycling policy and that it engages in dialogue with decision-makers, mainly through industry bodies like the Swedish Forest Industries Federation, CEPI and ACE, but it does not name any specific laws, regulations or consultations it has tried to influence. The company explains that it lobbies indirectly via those associations and through participation in networks such as GRACE, EXTR:ACT and 4Evergreen, yet it does not identify the government institutions or individual policymakers targeted, nor does it describe the format of those dialogues in detail. Likewise, the disclosure cites broad ambitions—accelerating sustainable and circular fibre-based packaging and responding to “legislative measures driven by sustainability and climate awareness”—without spelling out the concrete policy changes, amendments or quantitative goals it is advocating. Taken together, the information demonstrates that the company acknowledges some lobbying activity but offers only high-level descriptions, leaving most specifics about policies, mechanisms and desired outcomes undisclosed.	D