Scotts Miracle-Gro Co/The

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	ScottsMiracle-Gro has implemented some measures to align its policy engagement with its climate change strategy by noting that “To ensure that all our direct and indirect activities that influence policy are consistent with our climate change strategy, we participate in trade association meetings to discuss our mutual ESG goals and strategies” and that “We engage directly with a number of trade associations on a variety of ESG issues.” The company also “discloses our positions on various related issues on our website and within our Corporate Responsibility Report,” and states that “Our ESG strategy, including climate-related commitments, is being integrated into our business plans and led by a cross-functional ESG team.” However, the company does not disclose a formal review or approval process for lobbying, nor does it name any individual or committee responsible for oversight or provide any dedicated audit or reporting on lobbying alignment. We found no evidence of a public commitment to align its engagement activities with the Paris Agreement, noting “No, and we do not plan to have one in the next two years.” These disclosures indicate attention to aligning indirect policy influence with environmental commitments, but the absence of a clear governance structure or specific oversight body suggests only limited transparency and accountability in its climate lobbying governance. View Sources	C

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Scotts Miracle-Gro offers only limited insight into its climate-related lobbying. It says it engages with policymakers on “adaptation and resilience, particularly regarding water,” and on “policies that impact consumer practices … and improve resource efficiency for sustainable indoor plant cultivation,” but it never names a specific bill, regulation, or jurisdiction, so readers cannot see exactly which policies it has sought to influence. The company likewise provides no detail on how or through whom it conducts this advocacy, stating merely that it “look[s] to support policy and engage with policymakers,” without describing meetings, submissions, or any other mechanism, and without identifying the government bodies or officials involved. Finally, it outlines only broad aspirations—such as ensuring that water stewardship is addressed constructively and advocating for “harmonization with independent raters and rankers” to lower reporting burdens—without setting concrete policy changes or measurable targets. This high-level language signals some engagement but stops well short of transparent disclosure of its lobbying activities.	D