Indivior PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Indivior provides some indications that lobbying activities are subject to high-level oversight, but it does not disclose any process that explicitly links, monitors, or enforces alignment between those activities and climate goals. The company notes that “the Compliance, Ethics & Sustainability Committee (CESC), a committee of Indivior PLC’s Board of Directors, has oversight of Indivior’s Global Integrity & Compliance Program,” and that the Board and its Nomination & Governance Committee “received comprehensive briefings on the Group’s public policy strategies.” It also states that the Chief Integrity & Compliance Officer “has a direct reporting line to the Nomination and Governance Committee of the Board,” while the ESG Committee “will have oversight of the climate change action plan and implementation.” These passages show that formal bodies and named executives review public policy and advocacy work, indicating some governance of lobbying in general. However, the disclosures focus on compliance with laws and on the company’s opioid-treatment advocacy; they contain no description of how climate-related lobbying positions are evaluated, no mention of trade-association reviews, and no monitoring mechanism that connects lobbying to climate objectives. Indeed, the company states, “No, and we do not plan to have one in the next two years” when asked whether it has a commitment to conduct engagement in line with the Paris Agreement. Because the oversight described is generic and not tied to climate-lobbying alignment, and because there is no evidence of direct or indirect climate-lobbying review, this indicates only limited governance of lobbying from a climate perspective. View Sources	D

Overall Assessment

Analysis

Score

Limited

Indivior provides some indications that lobbying activities are subject to high-level oversight, but it does not disclose any process that explicitly links, monitors, or enforces alignment between those activities and climate goals. The company notes that “the Compliance, Ethics & Sustainability Committee (CESC), a committee of Indivior PLC’s Board of Directors, has oversight of Indivior’s Global Integrity & Compliance Program,” and that the Board and its Nomination & Governance Committee “received comprehensive briefings on the Group’s public policy strategies.” It also states that the Chief Integrity & Compliance Officer “has a direct reporting line to the Nomination and Governance Committee of the Board,” while the ESG Committee “will have oversight of the climate change action plan and implementation.” These passages show that formal bodies and named executives review public policy and advocacy work, indicating some governance of lobbying in general. However, the disclosures focus on compliance with laws and on the company’s opioid-treatment advocacy; they contain no description of how climate-related lobbying positions are evaluated, no mention of trade-association reviews, and no monitoring mechanism that connects lobbying to climate objectives. Indeed, the company states, “No, and we do not plan to have one in the next two years” when asked whether it has a commitment to conduct engagement in line with the Paris Agreement. Because the oversight described is generic and not tied to climate-lobbying alignment, and because there is no evidence of direct or indirect climate-lobbying review, this indicates only limited governance of lobbying from a climate perspective.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Indivior provides only limited insight into its climate-related lobbying. It notes that "Indivior Fine Chemical Plant worked closely with the UK Environmental Agency on climate related matters" and that a company climate-change risk assessment was "audited, accepted and well received by the UK Environmental Agency," which at least identifies one policymaking target and implies a direct engagement mechanism. Beyond these brief references, however, the company does not name any specific climate policy, regulation or legislative proposal it sought to influence, nor does it explain what changes or outcomes it was pursuing through this contact. As a result, while the disclosure shows that some climate-policy engagement occurred, it lacks the detail needed to understand either the precise policies involved or the objectives behind the lobbying activity.	D