AFRY AB

AFRY AB has established a policy-driven framework that links its sustainability commitments to its external policy engagement, as its "sustainability policy guides the company in participating in engagement activities that are consistent with our climate commitment" and its "sustainability e-learning, which is mandatory for all employees, is the process in which we ensure that the organization's engagement activities are consistent with the overall climate change strategy." The company has also initiated "mapping on our trade and business associations on Group level for alignment with the 1.5 degree ambition" and holds a "public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement," even noting that "By engaging directly with policy makers through high-level forums such as COP26, we challenge the way we work today." These elements demonstrate a concrete policy and process to align both indirect and direct lobbying with the company's climate strategy, but the company does not disclose any specific individual or formal body charged with overseeing or reviewing these lobbying activities, nor does it describe a structured approval, sign-off, or recurring audit process for its policy engagement beyond the initial mapping, and we found no evidence of regular monitoring mechanisms for climate lobbying alignment.