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VNV Global AB’s disclosures center on ESG due diligence in investment decisions—with emphasis that “our due diligence process involves, amongst others, areas like the diversity of the team, the positive impact of digital service on people and the planet, and an analysis of exposure to sustainability risks and how well these risks are identified and managed” and that “significant ESG risks are flagged and escalated to the general counsel”—but we found no evidence of any internal mechanisms or oversight structures governing political or climate-related lobbying. The text stresses that “VNV Global’s Board of Directors in its entirety is ultimately responsible for the Company’s sustainability strategy,” and that “management monitors the implementation of the Sustainability Policy on an ongoing basis,” yet there is no mention of who oversees lobbying, how lobbying activities are reviewed, or any process to align direct or indirect advocacy with climate goals. No individual or committee is identified as responsible for lobbying oversight, nor are any procedures described for engaging or exiting trade associations based on climate positions.
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