Novo Nordisk A/S

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Novo Nordisk provides a highly detailed picture of its climate-policy lobbying. It names numerous concrete measures it has engaged on, ranging from the “U.S. EPA’s Clean Power Plan,” “Carbon tax in Denmark, to be equal across all industries,” the EU’s “post-2020 Renewable Energy Directive,” the “ICE ban in the EU from 2035,” the Danish “regulation on surplus heating from production sites,” and the EU “Clean Energy Package,” among others, demonstrating full transparency on the specific legislation it seeks to influence. The company also spells out how it lobbies and who it targets, citing mechanisms such as “Co-signing advocacy letters/open letters,” “Contribution to public hearings,” “Bilateral engagement,” joining initiatives like the RE100 letter to the “Energy Ministers of the EU,” and working through the Buyers’ Principle with utilities and national associations; these examples show both direct and indirect engagement with clearly identified decision-makers in Europe, Denmark and the United States. Finally, it is explicit about the policy outcomes it is pursuing: it wants to “remove regulatory and administrative barriers, provide clarity on long-term ownership of Guarantees of Origin, encourage cross-border renewable energy transactions,” “accelerate cost-effective renewable thermal technologies,” secure “ambitious renewable energy targets” in the Clean Energy Package, and supports a carbon tax and the EU 2035 ICE ban “with no exceptions.” This level of specificity across policies, mechanisms, and desired outcomes reflects comprehensive transparency in Novo Nordisk’s climate lobbying disclosures. 4
Lobbying Governance
Overall Assessment Comment Score
Limited Novo Nordisk affirms a public commitment to align its external engagement with climate goals, noting that “we have set ambitious emission reduction targets with an emissions trajectory in line with the 1.5 degree pathway in the Paris Agreement,” and explicitly answering “Yes” when asked if it has a position to conduct engagement in line with the Paris Agreement. However, the company does not disclose any processes for how these external engagement or lobbying activities are monitored or managed for alignment with its climate commitments, nor does it identify any individual or committee responsible for overseeing this alignment. We found no evidence of a defined governance structure, review procedures, or accountability measures specific to lobbying or policy advocacy alignment. 1