Mobile TeleSystems PJSC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Mobile TeleSystems PJSC discloses a board-level mechanism intended to keep its policy engagement in line with climate objectives, noting that “In order to ensure that all of MTS direct and indirect activities that influence policy are consistent with overall ESG and Climate Change strategy, in 2021 MTS established ESG Committee of the MTS Board of Directors.” The company states that this ESG Committee, chaired by an independent director and comprising other board members, is mandated “to develop a forward-looking ESG strategy… and to monitor implementation of sustainable development principles in MTS,” and that “The Committee reviews MTS 2022 CDP response.” These statements indicate a formal body with responsibility for checking whether advocacy activities align with the company’s ESG and climate strategy, which is stronger than a simple policy declaration. However, the disclosure remains high-level: while it refers to “direct and indirect activities that influence policy,” it does not describe any concrete procedures for tracking or evaluating specific lobbying positions, trade-association memberships, or escalation steps if misalignment is found, and no dedicated climate-lobbying audit or public alignment report is mentioned. Consequently, although the presence of a board-level committee overseeing the consistency of policy engagement shows a moderate degree of governance, the company does not disclose the detailed monitoring processes, alignment criteria, or outcomes that would evidence more robust governance of both direct and indirect lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Mobile TeleSystems PJSC discloses a board-level mechanism intended to keep its policy engagement in line with climate objectives, noting that “In order to ensure that all of MTS direct and indirect activities that influence policy are consistent with overall ESG and Climate Change strategy, in 2021 MTS established ESG Committee of the MTS Board of Directors.” The company states that this ESG Committee, chaired by an independent director and comprising other board members, is mandated “to develop a forward-looking ESG strategy… and to monitor implementation of sustainable development principles in MTS,” and that “The Committee reviews MTS 2022 CDP response.” These statements indicate a formal body with responsibility for checking whether advocacy activities align with the company’s ESG and climate strategy, which is stronger than a simple policy declaration. However, the disclosure remains high-level: while it refers to “direct and indirect activities that influence policy,” it does not describe any concrete procedures for tracking or evaluating specific lobbying positions, trade-association memberships, or escalation steps if misalignment is found, and no dedicated climate-lobbying audit or public alignment report is mentioned. Consequently, although the presence of a board-level committee overseeing the consistency of policy engagement shows a moderate degree of governance, the company does not disclose the detailed monitoring processes, alignment criteria, or outcomes that would evidence more robust governance of both direct and indirect lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E