Rathbones Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Rathbones Group PLC discloses an internal process that links its engagement and climate objectives to a formal oversight structure, indicating moderate governance of climate-related advocacy. It states that “a procedure has been adopted whereby potential new ESG engagements are presented for review and approval by the responsible investment committee. As part of this process, every engagement must demonstrate compliance with this policy, but also state intended outcomes, setting ‘precise and well informed objectives’,” and confirms that “progress against these objectives is tracked regularly.” Oversight is clearly assigned: “The overarching responsibility for our RI activities sits with the Rathbones Group board… our Responsible Investment Committee (RIC) provides oversight and guidance… Our Engagement Committee provides oversight of our engagement activities… and provides regular updates to the RIC.” These disclosures describe a concrete sign-off, monitoring and escalation pathway for climate-related engagement, and the firm has adopted specific documents such as a “group climate change engagement policy” and has endorsed the “Global Standard on Responsible Climate Lobbying,” suggesting an intention to align its activities with Paris-aligned outcomes. However, the evidence focuses on stewardship engagements with portfolio companies rather than on Rathbones’ own direct or trade-association lobbying; we found no disclosure of any process for reviewing the alignment of the company’s own policy advocacy or for assessing and managing its memberships in industry bodies. Likewise, while committee oversight is described, there is no published lobbying-alignment review or audit. This indicates a governance framework that sets policy and oversight for climate engagement but stops short of a comprehensive mechanism covering both direct and indirect corporate lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Rathbones Group PLC discloses an internal process that links its engagement and climate objectives to a formal oversight structure, indicating moderate governance of climate-related advocacy. It states that “a procedure has been adopted whereby potential new ESG engagements are presented for review and approval by the responsible investment committee. As part of this process, every engagement must demonstrate compliance with this policy, but also state intended outcomes, setting ‘precise and well informed objectives’,” and confirms that “progress against these objectives is tracked regularly.” Oversight is clearly assigned: “The overarching responsibility for our RI activities sits with the Rathbones Group board… our Responsible Investment Committee (RIC) provides oversight and guidance… Our Engagement Committee provides oversight of our engagement activities… and provides regular updates to the RIC.” These disclosures describe a concrete sign-off, monitoring and escalation pathway for climate-related engagement, and the firm has adopted specific documents such as a “group climate change engagement policy” and has endorsed the “Global Standard on Responsible Climate Lobbying,” suggesting an intention to align its activities with Paris-aligned outcomes. However, the evidence focuses on stewardship engagements with portfolio companies rather than on Rathbones’ own direct or trade-association lobbying; we found no disclosure of any process for reviewing the alignment of the company’s own policy advocacy or for assessing and managing its memberships in industry bodies. Likewise, while committee oversight is described, there is no published lobbying-alignment review or audit. This indicates a governance framework that sets policy and oversight for climate engagement but stops short of a comprehensive mechanism covering both direct and indirect corporate lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Rathbones Group PLC provides extensive and specific disclosure of its climate-policy lobbying. It names multiple identifiable policy areas it has tried to influence, including its support for an expanded net-zero mandate in the UK Energy Bill for Ofgem, written submissions to the UK Sustainable Disclosure Requirements (SDR) consultation, participation in the 2021 Global Investor Statement that calls for mandatory climate-risk disclosure, the phase-out of thermal-coal subsidies and strengthened national 2030 emissions targets, as well as letters urging banks to align financing with net-zero and government discussions on mandatory sustainability metrics for the food sector. The company also describes a range of mechanisms it uses—direct meetings with UK ministers and regulators, formal letters to the Secretary of State for Energy Security and Net Zero, co-signed investor letters to companies and banks, collaborative work through Climate Action 100+, IIGCC and Nature Action 100, and coordinated voting and proxy campaigns—while identifying the targets of those actions, such as UK government departments, Ofgem, audit firms, large emitters like Rio Tinto and ThyssenKrupp, and 23 European Climate Action 100+ focus companies. Finally, Rathbones is explicit about the outcomes it seeks: rapid implementation of Ofgem’s new mandate, mid-century domestic net-zero targets, strengthened 2030 commitments, mandatory TCFD-aligned disclosure, coal exit dates for banks, grid readiness for renewable connections and clear milestones for investee companies to obtain Science Based Targets initiative approval. This level of specificity across policies, mechanisms and desired results demonstrates comprehensive transparency around its climate-related lobbying activities.	A