Embracer Group AB – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
None	Embracer Group AB outlines its decentralized model and highlights that “The Chief of Staff, Legal & Governance is responsible for implementing and monitoring of the governance model” and that the “Audit and Sustainability Committee’s tasks are to monitor the integrity of Embracer Group’s financial reporting system, internal controls, Internal Audit, operation procedure and the enterprise risk management framework,” yet the company does not disclose any mechanisms or processes for governing political lobbying or for aligning either direct advocacy or trade association engagement with its climate objectives. We found no evidence of a policy or procedure for reviewing lobbying positions, no reference to assessing industry associations for alignment, and no mention of a specific individual or body tasked with overseeing lobbying alignment, which indicates the absence of a dedicated lobbying governance framework. View Sources	E

Overall Assessment

Analysis

Score

None

Embracer Group AB outlines its decentralized model and highlights that “The Chief of Staff, Legal & Governance is responsible for implementing and monitoring of the governance model” and that the “Audit and Sustainability Committee’s tasks are to monitor the integrity of Embracer Group’s financial reporting system, internal controls, Internal Audit, operation procedure and the enterprise risk management framework,” yet the company does not disclose any mechanisms or processes for governing political lobbying or for aligning either direct advocacy or trade association engagement with its climate objectives. We found no evidence of a policy or procedure for reviewing lobbying positions, no reference to assessing industry associations for alignment, and no mention of a specific individual or body tasked with overseeing lobbying alignment, which indicates the absence of a dedicated lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
None	No evidence found	E