Mondi PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Mondi discloses a specific mechanism aimed at aligning its policy engagement with climate goals, stating that it has "set up a process to internally audit all activities that influence climate policy, ensuring consistency of those activities and communicating on actions and outcomes via the CDP disclosure," which demonstrates an internal review procedure focused on lobbying alignment rather than a mere policy statement. The company also references indirect lobbying governance by highlighting its participation in CEPI, "the European association representing the paper industry with Mondi as a long-lasting active member," and explaining that it seeks to "positively influence our sector and policy makers through responsible engagement on climate policy," indicating that the audit covers both its own advocacy and its trade-association activity. Mondi reiterates its strategic intent through a “public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement,” reinforcing that the audit is climate-focused. However, the disclosures stop short of identifying a responsible individual or board committee for overseeing this audit, do not clarify how often the audit occurs or how misalignments are remedied, and there is no publicly available climate-lobbying alignment report. Consequently, while a defined process and coverage of indirect lobbying indicate moderate governance, the absence of named oversight and limited transparency on outcomes signal that the framework is not yet robust or comprehensive. View Sources	2

Overall Assessment

Analysis

Score

Moderate

Mondi discloses a specific mechanism aimed at aligning its policy engagement with climate goals, stating that it has "set up a process to internally audit all activities that influence climate policy, ensuring consistency of those activities and communicating on actions and outcomes via the CDP disclosure," which demonstrates an internal review procedure focused on lobbying alignment rather than a mere policy statement. The company also references indirect lobbying governance by highlighting its participation in CEPI, "the European association representing the paper industry with Mondi as a long-lasting active member," and explaining that it seeks to "positively influence our sector and policy makers through responsible engagement on climate policy," indicating that the audit covers both its own advocacy and its trade-association activity. Mondi reiterates its strategic intent through a “public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement,” reinforcing that the audit is climate-focused. However, the disclosures stop short of identifying a responsible individual or board committee for overseeing this audit, do not clarify how often the audit occurs or how misalignments are remedied, and there is no publicly available climate-lobbying alignment report. Consequently, while a defined process and coverage of indirect lobbying indicate moderate governance, the absence of named oversight and limited transparency on outcomes signal that the framework is not yet robust or comprehensive.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Mondi provides a relatively detailed picture of what it tries to influence on climate policy. It names a number of concrete measures it has engaged on – including the European Commission’s sustainable bio-energy policy to 2030, the EU Packaging and Packaging Waste Regulation, the Single-Use Plastics Directive and international frameworks such as REDD+ – and refers to its work on the revision of the GHG Protocol and biomass carbon-neutrality discussions. The company also describes several routes it uses, such as commissioning a study with WWF aimed at the European Commission, submitting technical papers to policymakers and participating in CEPI working groups and other coalitions, although for most of these it does not spell out which government bodies or officials were contacted. Mondi is clear about the changes it seeks: it wants the “cascading use of wood” principle written into the EU’s bio-energy and circular-economy rules, EU-level guidance that incentivises this approach, decisions that recognise biomass carbon neutrality, and broader goals such as expanding global forest cover by 158 million hectares and restoring degraded land. By naming multiple specific policies and articulating several explicit outcomes, while giving at least some insight into its channels of influence, Mondi demonstrates a strong – though not fully comprehensive – degree of transparency in its climate-related lobbying.	3