3i Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	3i Group discloses a limited but identifiable framework for governing lobbying activities and how these relate to its climate strategy. It states that “Lobbying must only be undertaken with the prior approval of a member of the Executive Committee and in a manner that is lawful and adheres to 3i’s values,” demonstrating that an internal senior body signs-off on any lobbying before it occurs. In response to questions about consistency with its climate commitments the company explains that “Our engagement in relation to climate change policies, law and regulations is limited to providing input to industry association submissions and consultations when this opportunity is given by policy makers” and that “On occasion, we make direct submissions to public consultations, where warranted,” indicating a defined – albeit narrow – process intended to keep climate-related advocacy aligned with corporate objectives. Board-level involvement in sustainability is also referenced: “The Board of Directors is responsible for the oversight of the Group’s sustainability approach and policies… including developing and proposing the Group’s ESG approach,” but there is no explicit description of the Board or ESG Committee reviewing the substance or alignment of lobbying positions themselves. The disclosures do not discuss any systematic assessment of trade-association positions, withdrawal from misaligned bodies, or publication of a climate-lobbying alignment report, and no details are provided on how the pre-approval requirement is applied or monitored after engagement. This indicates that while oversight responsibility and a basic approval mechanism are disclosed, the company does not publish a comprehensive monitoring process or evidence of actively aligning both direct and indirect lobbying with its climate strategy. View Sources	C

Overall Assessment

Analysis

Score

Moderate

3i Group discloses a limited but identifiable framework for governing lobbying activities and how these relate to its climate strategy. It states that “Lobbying must only be undertaken with the prior approval of a member of the Executive Committee and in a manner that is lawful and adheres to 3i’s values,” demonstrating that an internal senior body signs-off on any lobbying before it occurs. In response to questions about consistency with its climate commitments the company explains that “Our engagement in relation to climate change policies, law and regulations is limited to providing input to industry association submissions and consultations when this opportunity is given by policy makers” and that “On occasion, we make direct submissions to public consultations, where warranted,” indicating a defined – albeit narrow – process intended to keep climate-related advocacy aligned with corporate objectives. Board-level involvement in sustainability is also referenced: “The Board of Directors is responsible for the oversight of the Group’s sustainability approach and policies… including developing and proposing the Group’s ESG approach,” but there is no explicit description of the Board or ESG Committee reviewing the substance or alignment of lobbying positions themselves. The disclosures do not discuss any systematic assessment of trade-association positions, withdrawal from misaligned bodies, or publication of a climate-lobbying alignment report, and no details are provided on how the pre-approval requirement is applied or monitored after engagement. This indicates that while oversight responsibility and a basic approval mechanism are disclosed, the company does not publish a comprehensive monitoring process or evidence of actively aligning both direct and indirect lobbying with its climate strategy.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	3i Group gives only limited insight into its climate-related lobbying. The company notes that it may “engage directly with government and regulatory bodies on matters of particular and direct importance to 3i and its businesses” and that such activity is “done principally through industry representative bodies such as the British Private Equity and Venture Capital Association (BVCA) and Invest Europe,” but it does not identify which public authorities were approached or describe concrete actions such as meetings, submissions or letters. It likewise offers no examples of specific climate policies, laws or regulations it has tried to influence, and it remains silent on the concrete legislative or regulatory outcomes it is seeking. As a result, the disclosure signals that lobbying may occur but provides almost no detail on the climate policy issues addressed, the mechanisms used, or the objectives pursued.	D