Shaftesbury Capital PLC

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Shaftesbury Capital PLC has implemented a structured governance framework for its climate lobbying by establishing the Environment, Sustainability and Community (ESC) Management Committee to oversee all direct and indirect activities that influence climate change policy. As the company states, The ESC Management Committee manages the Groups day to day ESC activities and is responsible for ensuring that any direct and indirect activities that influence climate change policy are firmly aligned with the ESC Strategy and business strategy. This committee, which includes the Groups Director of Sustainability and Technology and a designated Non-executive Director (who also Chairs our Board ESC Committee), reviews any proposed activities with the intention of influencing climate change policy and requires that they must be reported to the ESC Management Committee for approval prior to implementation to ensure alignment with the companys climate change strategy. Meeting quarterly with formal meeting papers and minutes of the decisions made during the meeting, the committee reports to ExCo and the Board, demonstrating a clear process and lines of accountability. While the company integrates climate considerations into its supplier code of conduct and publishes regular sustainability reporting such as its Annual Report and Sustainability Data Report, we found no evidence of a standalone, publicly available audit or review specifically dedicated to assessing the alignment of its climate-related lobbying activities. View Sources	3

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Shaftesbury Capital PLC provides only limited transparency on its climate-policy lobbying. It names one identifiable policy engagement—its “Support for Westminster Council’s climate emergency policy” and, more broadly, its advocacy for “Net zero and nature restoration” and “climate-related reporting,” but these references are too general to show the full scope of its lobbying activity. The company does give some insight into how and where it lobbies: it participates in “industry working groups” and a “zero emissions working group,” and it “signed the business letter which called for prioritisation of Net zero and nature restoration to build a resilient UK,” which was sent to Westminster City Council and to the U.K. Prime Ministers Liz Truss and Rishi Sunak. However, beyond those examples it does not explain whether it also meets officials, submits consultation responses, or uses other channels. On desired outcomes, the company expresses high-level aims such as “protecting and restoring nature and delivering a net zero economy in support of the UK’s targets” and asks government for a “robust plan… in the short and long term,” including stronger “planning, building regulations and agriculture” measures, but it does not set out concrete legislative changes or emissions targets it is pursuing. Taken together, the disclosures reveal only a partial picture of the company’s lobbying activities, mechanisms, and objectives.	1