Brambles Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Brambles provides a very detailed picture of its climate-related lobbying. It names a suite of specific EU measures it has worked on – the “EU Packaging and Packaging Waste Directive (PPWD – Directive 94/62/EC),” the “framework directive on waste (2008/98/EC),” and the Circular Economy Action Plan that forms part of the EU Green Deal – and explains that these are the focus of its engagement. The company sets out how it engages, describing direct work with the European Commission (e.g., “CHEP EMEA has been assisting the European Commission to understand circular economy principles”), participation in EU working groups to “define the guidelines to promote reusable packaging in EU legislation,” and indirect lobbying through trade bodies such as “Plastics Europe … and Reloop” as well as joint efforts with “industry associations, including our competitors,” thereby clearly identifying both mechanisms and targets. Brambles is also explicit about the concrete policy outcomes it seeks: it wants legislation that prioritises “prevention and reuse” over a purely recycling-based approach, seeks legal frameworks that “protect the legal title of its assets” and “incentivise product-as-a-service” models, and aims to “increase the amount of reusable packaging equipment put on the EU market.” This combination of identified policies, clearly described engagement channels and targets, and well-articulated desired policy changes demonstrates a high level of transparency around the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Brambles gives only a brief outline of how it governs its policy engagement, stating that it "mainly engages with policy makers and organizations to promote the circular economy … which is consistent with its climate strategy and a decarbonization of the economy," and that the "Chief Compliance Officer is responsible for ensuring that all policy-related activities are in line with Brambles' strategic objectives and internal policies," while noting that "our Global Head for Sustainability also leads Government Affairs in Europe" and that "all employees, including the Government Affairs team, have to follow our policies." These disclosures indicate that at least one named senior officer has oversight and that the company expects lobbying activity to align with broader strategy, but they do not describe any formal review cycle, monitoring tools, or criteria for assessing either direct advocacy positions or the stances of trade associations. There is no reference to a climate-lobbying audit, no explanation of how inconsistencies would be identified or remedied, and no evidence that the Board or a committee receives regular reports on lobbying alignment, so the governance of lobbying—particularly climate-related lobbying—remains only lightly sketched rather than systematically documented.	1