United Utilities Group PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	United Utilities Group PLC offers a high level of transparency on its climate-related public-policy engagement. It names a broad suite of specific measures it has worked on, including the Industrial Emissions Directive (IED), Ofwat’s consultation on “UK water industry regulatory reporting: climate-related reporting,” proposals for “a common performance commitment on greenhouse gas emissions for all water and wastewater companies,” the Climate Change Act 2008 adaptation-report requirements, mandatory TCFD-aligned reporting rules, and Listing Rules 9.8.6R(8) and the Companies Act climate-disclosure regulations. The company also discloses how it lobbies and whom it targets: it describes a “workshop with Ofwat representative in advance of the consultation issue,” “online meetings between industry and Ofwat representatives,” formal written submissions, and, in the environmental sphere, that “we have been communicating with the Environment Agency regarding IED regulations through multiple routes for a number of years,” as well as outreach in which “we wrote to every MP and local authority offering to talk through the benefits our plan will deliver.” Finally, United Utilities is explicit about the results it seeks. It supports expanding the scope of operational GHG reporting in the Annual Performance Report but asks for clarification so that it covers “only emissions relating to the transportation, treatment and disposal of sludge”; it presses Ofwat to update emissions baselines to 2024/25 forecasts, revise the cap-and-collar mechanism and increase the net-zero uplift; and, for the IED, it aims to “accelerate implementation from AMP8 to AMP7” while using permit improvement conditions to allow time to meet Best Available Techniques, stating that “this will reduce the environmental impacts of releases to land, air and water from our sludge treatment activities.” By clearly identifying the policies, the engagement channels and targets, and the concrete changes it is pursuing, the company demonstrates comprehensive disclosure of its climate-policy lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
None	United Utilities Group PLC focuses extensively on its climate change mitigation governance, but it does not disclose any process for aligning or overseeing its lobbying activities. The company explains that “Within our Environment Planning and Innovation directorate we have a dedicated carbon team whose objective is to develop and drive our climate change mitigation strategy” and that “The strategy is overseen by the climate change mitigation steering group,” with “new director-led working groups” including one “specifically tasked with managing and improving our climate related strategy and engagement.” It also highlights commitments through signatories such as the “UN Race to Zero” and its role in Water UK’s Net Zero 2030 Routemap, and describes the Trustee’s oversight of climate-related risks and TCFD reporting through various sub-committees. However, we found no evidence of any governance policy, oversight structure, or review mechanism specifically dedicated to ensuring that its direct or indirect lobbying activities are aligned with its climate strategy, nor any named individual or committee responsible for lobbying oversight.	0