Hilton Food Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Hilton Food Group provides some indication that its climate-related external engagement is overseen, but the disclosures stop short of detailing a structured lobbying governance framework. The company states that “Relevant consultations are completed either by or with the oversight of the Group Corporate Social Responsibility team, who are responsible for developing and implementing The Sustainable Protein Plan, this ensures the activities are consistent with overall climate strategies,” and confirms that it has “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement.” These statements demonstrate a high-level commitment and identify the CSR team as an oversight body for engagement activities, signalling limited governance of how advocacy is kept in line with climate goals. However, the evidence does not describe concrete mechanisms for monitoring or managing direct lobbying, does not reference reviews of trade-association positions, and does not assign responsibility for lobbying alignment to a named individual or board committee beyond the general sustainability oversight already described. We found no evidence of a formal process for auditing lobbying activities, no disclosure of how misalignment would be addressed, and no reporting on the company’s own or its associations’ policy advocacy. Therefore, while the company discloses oversight for climate-related engagement, the transparency and specificity required to demonstrate a robust lobbying governance process are not present. View Sources	1

Overall Assessment

Analysis

Score

Limited

Hilton Food Group provides some indication that its climate-related external engagement is overseen, but the disclosures stop short of detailing a structured lobbying governance framework. The company states that “Relevant consultations are completed either by or with the oversight of the Group Corporate Social Responsibility team, who are responsible for developing and implementing The Sustainable Protein Plan, this ensures the activities are consistent with overall climate strategies,” and confirms that it has “a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement.” These statements demonstrate a high-level commitment and identify the CSR team as an oversight body for engagement activities, signalling limited governance of how advocacy is kept in line with climate goals. However, the evidence does not describe concrete mechanisms for monitoring or managing direct lobbying, does not reference reviews of trade-association positions, and does not assign responsibility for lobbying alignment to a named individual or board committee beyond the general sustainability oversight already described. We found no evidence of a formal process for auditing lobbying activities, no disclosure of how misalignment would be addressed, and no reporting on the company’s own or its associations’ policy advocacy. Therefore, while the company discloses oversight for climate-related engagement, the transparency and specificity required to demonstrate a robust lobbying governance process are not present.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Hilton Foods discloses a comprehensive set of climate lobbying activities. It identifies multiple specific policies, including the “Defra Food Data Transparency Partnership,” the EU Code of Conduct on Responsible Food Business and Marketing Practices, and UK and EU deforestation due diligence legislation, demonstrating full transparency around the policies it has engaged on. The company details its lobbying mechanisms, noting engagement “directly and as part of industry groups,” membership of the “Eco Working Group,” signing letters advocating for mandatory due diligence alongside investors and customers, collaboration with EFECA in support of Defra’s implementation of UK deforestation legislation, and participation in alliances such as the Seafood Ethics Action Alliance and the Food Network for Ethical Trade, all targeting Defra and national-level UK policymakers. It also articulates clear outcomes sought, including eliminating deforestation from its supply chains by 2025, supporting policy implementation “with minor exceptions” while resolving issues around the “scope and immediacy of data flows,” and advocating for robust human rights and environmental standards, confirming a high level of transparency about its intended policy changes.	4