Phoenix Group Holdings PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Phoenix Group Holdings PLC provides a highly detailed picture of its climate-related public-policy engagement. It names a wide range of specific measures it has tried to influence, including the "proposed reforms to Solvency II," the "modification of the matching adjustment," the "mandated roll-out of TCFD," the "UK Government Green Finance Strategy and Net Zero Transition Plan requirements," as well as the wider "UK Government low-carbon strategy and green-finance policy" and the post-pandemic "recovery package and policy framework that prioritises building back better and greener." The company is equally explicit about how it lobbies and whom it targets, citing "direct interaction and advice with BEIS civil servants and Ministers," "working closely with HMT and the PRA," attending "party conferences and third-party events," taking part in a "Government investment roundtable held jointly by the Prime Minister and Chancellor," and submitting consultation responses, thereby identifying both the mechanisms and the relevant government bodies. Finally, it spells out the concrete outcomes it seeks, such as "ensuring pension funds are better able to invest in green and illiquid initiatives," introducing "more flexibility into the regulations to help meet our net-zero ambitions," leveraging the UK Infrastructure Bank "to unlock increased private-sector capital for green investment," and supporting policy frameworks that drive "the investment needed in net-zero products, services and sectors." This breadth and specificity across policies, methods, targets and desired results demonstrate a comprehensive level of transparency in its climate-policy lobbying disclosures.	4

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Phoenix Group Holdings PLC articulates a commitment to align its lobbying with its climate strategy, noting “where appropriate, we will work directly with government to secure policy and regulatory frameworks which can drive the investment needed in net zero products, services, and sectors” and pledges that “we will advocate for the implementation of climate and energy policy and regulation to help unlock investment at scale.” The company also confirms it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement” by answering “Yes” when prompted. However, Phoenix does not disclose any structured governance processes—there is no description of a monitoring or review mechanism, the company does not identify a specific individual or committee responsible for oversight, and we found no evidence of steps to manage indirect lobbying through industry associations. As such, while the firm publicly commits to Paris-aligned engagement, it does not disclose how these commitments are governed, reviewed, or enforced.	1