Unilever PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Unilever discloses climate-policy engagement in a highly transparent manner. It names a wide range of identifiable measures it has lobbied on, including the Global Plastics Treaty, the EU Emissions Trading Scheme, the Renewable Energy, Energy Efficiency and Energy Performance of Buildings Directives, carbon-pricing systems in the EU, UK, France, South Africa and Germany, Extended Producer Responsibility rules in Europe, North America and Asia, higher renewable-energy targets in Japan, and UK Transition Plan Taskforce guidance, among many others. The company also explains how it approaches policymakers, describing direct meetings with “government ministers and negotiators from North America, South America, Europe (including the European Union institutions), Asia, and Australasia,” “direct communication with the rapporteur and all the shadow rapporteurs” on the EU ETS, co-signing public letters to the European Commission President and UK Prime Minister, speaking on panels at COP27 and COP28, and working through coalitions such as RE100, the Carbon Pricing Leadership Coalition and the Business Coalition for a Global Plastics Treaty. Targets of these efforts are clearly identified, for example the EU Commission, G7 representatives, Environment and Climate Change Canada and legislative staff in New York. Finally, Unilever states explicit policy objectives: it seeks “a price on carbon of $40–80 t/CO₂e by 2020 rising to $50–100 t by 2030,” calls for “tripling global renewables capacity by 2030,” supports phasing out free allowances in the EU ETS, advocates for “binding rules, targets and standards” in a plastics treaty, and urges governments to integrate food into their NDCs and NAPs. By specifying the laws it engages on, the channels and audiences it uses, and the concrete legislative outcomes it pursues, Unilever demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	Unilever discloses a detailed and multi-layered system that monitors, reviews and publicly reports on the alignment of both its direct and indirect climate lobbying with the companys 1.5 C objectives, indicating strong governance. It states that Global climate advocacy priorities are defined through an annual planning and review process all direct lobbying priorities are assessed to ensure consistency with our objectives in delivering the 1.5C ambition of the Paris Agreement. Plans are approved by the Chief Sustainability Officer and the Global Head of Communications and Corporate Affairs, showing a clear process, regular review cycle and named senior sign-off for direct lobbying. For indirect lobbying, Unilever explains that it has conducted an in-depth review of our main trade associations to assess their alignment with the Paris Agreement and our climate policy positions and have published this review on our website, and notes that earlier this year, we published our first Climate Policy Engagement Review which sets our climate policy priorities and critically examines the positions and engagement activities of our main industry associations, thereby making a public audit of lobbying alignment available. Ongoing oversight mechanisms include that Unilever reviews its membership of industry associations on an annual basis and is committed to conducting a full, global industry association review every three years, with the internal Trade Association Standard requiring each association to confirm that their climate policy work is consistent with Unilevers positions at the point of joining or renewing membership. Where misalignment persists, if an industry associations position cannot be made consistent with Unilevers we will determine whether to withdraw our membership and make our withdrawal public, demonstrating an enforcement pathway. Accountability is anchored at the top: Our CEO and Executive Board member, Hein Schumacher, is ultimately responsible for overseeing our climate change agenda, while The Board has overall accountability for the management of all risks and opportunities, including climate change, and monthly reviews are undertaken by the Global Head of Sustainability Environment and the Global Head of Corporate Affairs. Taken togetherboard-level oversight, a named executive owner, recurring reviews of both direct lobbying plans and trade-association positions, escalation and withdrawal procedures, and a publicly released alignment reviewthis indicates comprehensive and transparent governance of climate lobbying; the only area not fully detailed is whether the published review is subject to independent third-party assurance, but the breadth and public nature of the disclosed processes nonetheless demonstrate an advanced framework.	4