Ayala Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Ayala Corporation provides a rich and detailed picture of its climate-policy advocacy. It names a wide range of specific measures it has worked on, including the "Amendment of the Philippine Clean Air Act of 1999 (RA 8749)," the country’s "Nationally Determined Contribution, Communicated to the UNFCCC on 15 April 2021," the "SEC Memorandum Circular No. 4 on Sustainability Reporting Guidelines for Publicly Listed Companies," the "BSP Sustainable Financing Framework," the "Amendment of the Water Code of the Philippines (PD1067)," and the "adoption of a national land-use policy." It also discloses how it seeks to influence these proposals, citing "Attendance in legislative hearings," "submission of inputs/comments to proposed bill," and "regular discussions with the Philippine Climate Change Commission," supported by a "memorandum of agreement with the agency" to embed climate strategies in government plans. Finally, the company is explicit about the results it pursues, seeking the "Adoption of gasification and other forms of technology that do not pollute air," expressing "support [for] the rationalization of the management of water resources," and backing a "rational, holistic and just allocation, utilization, management and development of the country’s land resources" through a national land-use act. By naming the legislation, describing the engagement channels and counterparts, and spelling out the concrete policy changes it supports, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Ayala Corp provides extensive detail on its internal climate-risk governance, yet almost nothing on how it manages lobbying or advocacy. The only statement that pertains to lobbying alignment is the affirmation that the company has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes”, which indicates intent but not process. Other disclosures such as the Board “oversees the group's strategy, systems and procedures, including climate-related issues”, the Sustainability Committee’s endorsement of the Climate Ambition Project, and the CRO/CSO who “leads integration efforts” all describe climate strategy oversight rather than any mechanism for reviewing or controlling policy advocacy. We found no evidence of procedures that check lobbying positions, assess trade-association alignment, or designate specific oversight for lobbying activities. Therefore, beyond the high-level Paris-alignment pledge, the company does not disclose how it monitors, manages, or enforces consistency in either its direct or indirect lobbying, indicating only limited governance in this area.	1