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| Overall Assessment |
Comment |
Score |
| Comprehensive |
CSL Ltd provides extensive and specific disclosure of its climate-related lobbying. It names a suite of concrete policies it engages on, including the “Swiss CO2 tax,” the “Swiss ETS,” “mandatory carbon reporting,” Australia’s “National Greenhouse and Energy Reporting” scheme and the U.S. “Greenhouse Gas Reporting Program,” demonstrating full transparency about the regulations in scope. The company also explains how and where it lobbies, stating that “CSL Behring has engaged with the Canton government on the Swiss CO2 tax and the Swiss ETS” and describing direct engagement with “the Australian Government Department of Environment” and “the US EPA,” thereby identifying both the mechanism (direct governmental engagement) and the specific governmental targets across three jurisdictions. Finally, CSL is clear about the outcomes it seeks: it “supports mandatory carbon reporting” because it “provides transparency to the market and other stakeholders,” and backs “regulatory amendments proposed from time to time where they maximise the fairness of the tax and the efficiency and effectiveness of its administration,” as well as amendments that “increase the efficiency, effectiveness and accuracy of the reporting program.” By outlining the policies addressed, the channels used, the government bodies approached, and the precise policy changes it advocates, CSL demonstrates a high level of transparency in its climate-policy lobbying.
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4
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| Overall Assessment |
Comment |
Score |
| Moderate |
CSL discloses a limited but discernible process for keeping its policy advocacy in step with its climate goals, stating that it "works directly with government and other stakeholders" and "cooperates thoughtfully with relevant industry associations in the development of industry positions that align with its Values and interests," which indicates some effort to align both direct and indirect engagement. The company adds that "Staff are apprised of these initiatives and equipped to ensure their engagement activities are consistent with CSL's overall climate change strategy," showing an internal mechanism to brief employees and guide their lobbying actions. However, the disclosure does not specify any formal oversight body or named individual responsible for verifying this alignment, nor does it describe monitoring steps such as periodic reviews or escalation procedures; moreover, CSL confirms "No, and we do not plan to have one in the next two years" when asked about a formal public commitment to align engagement with the Paris Agreement. Overall, while CSL provides a basic description of how it seeks to keep advocacy aligned with climate objectives and references collaboration with trade associations consistent with its values, it does not disclose a structured governance framework, dedicated oversight, or detailed monitoring processes that would demonstrate a stronger level of lobbying governance.
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2
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