Post Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Post Holdings Inc. discloses a basic internal mechanism to oversee climate-related policy engagement, noting that "all engagements that have a connection to the topic of GHG emissions and/or climate change has at least one member of our ESG Steering Committee and/or ESG Operations Council actively involved and informed and/or our Senior Director, ESG oversees the engagement." This statement identifies a named oversight structure—the ESG Steering Committee / ESG Operations Council—and a specific individual, the "Senior Director, ESG," demonstrating that climate-focused advocacy activities receive sign-off from senior personnel. The company also repeats that oversight arrangement when asked about consistency with its climate commitments, again confirming that these bodies "actively" monitor such engagements. However, beyond this internal sign-off, the disclosure offers no detail on how lobbying positions are reviewed, how direct and indirect lobbying are aligned, or whether trade-association memberships are assessed; moreover, the company admits "No, and we do not plan to have one in the next two years" regarding a public commitment to conduct engagement in line with the Paris Agreement. The absence of information about monitoring criteria, corrective actions, or public reporting of alignment indicates the governance remains limited to an internal oversight step rather than a comprehensive framework that covers both direct and indirect lobbying activities. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Post Holdings Inc. discloses a basic internal mechanism to oversee climate-related policy engagement, noting that "all engagements that have a connection to the topic of GHG emissions and/or climate change has at least one member of our ESG Steering Committee and/or ESG Operations Council actively involved and informed and/or our Senior Director, ESG oversees the engagement." This statement identifies a named oversight structure—the ESG Steering Committee / ESG Operations Council—and a specific individual, the "Senior Director, ESG," demonstrating that climate-focused advocacy activities receive sign-off from senior personnel. The company also repeats that oversight arrangement when asked about consistency with its climate commitments, again confirming that these bodies "actively" monitor such engagements. However, beyond this internal sign-off, the disclosure offers no detail on how lobbying positions are reviewed, how direct and indirect lobbying are aligned, or whether trade-association memberships are assessed; moreover, the company admits "No, and we do not plan to have one in the next two years" regarding a public commitment to conduct engagement in line with the Paris Agreement. The absence of information about monitoring criteria, corrective actions, or public reporting of alignment indicates the governance remains limited to an internal oversight step rather than a comprehensive framework that covers both direct and indirect lobbying activities.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Post Holdings gives only a basic picture of its climate-related lobbying. It indicates that it is "actively participating" in Extended Producer Responsibility (EPR) programs in Canada and is monitoring "extended producer responsibility (EPR) legislation throughout the US and Canada," but it does not name any specific bills, regulatory dockets or governmental proceedings, so readers cannot tell exactly which measures it has tried to influence. The company describes broad channels of engagement—participation in the "CDP Supply Chain and the Supplier Leadership on Climate Transition (Supplier LOCT) programs" and membership in trade bodies such as the Consumer Brands Association and the Sustainable Packaging Coalition—yet it does not spell out whether it lobbies directly, through written submissions, meetings or other tools, nor does it identify the government agencies or lawmakers it approaches. Finally, while it says its involvement in EPR programs is intended to help "build more efficient recycling systems," it does not articulate concrete policy changes, targets, or positions it is advocating. Together, these disclosures show a willingness to acknowledge that climate-related policy engagement exists, but they stop short of providing the detail needed to understand the exact policies, methods or outcomes the company seeks.	D