Grainger PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Grainger PLC provides a comprehensive and detailed picture of its climate-policy lobbying activities. It names several specific policies it engages on – the UK Government’s Net Zero Strategy, the Future Homes Standard, Building Regulations connected to climate change adaptation, and proposed climate-related reporting requirements – showing exactly where its advocacy is focused. The company also explains how it engages, citing participation in “workshops, discussions via industry bodies, and consultation responses,” attendance at forums, and “ongoing meetings with UK Government ministers,” thereby making clear both the mechanisms it uses and its primary target, the UK Government. Finally, Grainger is explicit about what it wants these engagements to achieve: it seeks “specific guidance in Government policies to ensure that landlords can access data whilst maintaining compliance with privacy regulations,” backs “energy efficiency requirements for private rented properties, and future requirements to replace fossil fuel heating systems with low carbon alternatives,” and calls for “the detailed technical specification of the regulations to be confirmed as soon as possible.” It also advocates for improvements in “building design, adapting to warmer temperatures and potential regulations regarding embodied carbon measurement and reporting,” confirming these positions are aligned with the Paris Agreement. Together, these disclosures demonstrate a high level of transparency on the policies lobbied, the methods and targets of engagement, and the concrete outcomes the company is seeking.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Grainger PLC has implemented a structured governance framework to ensure that its engagement activities, both direct and indirect, align with its climate change strategy. In particular, “Grainger’s Director of Corporate Affairs oversees all engagement activity to ensure that it is aligned to the company’s business strategies” and “oversees the business’s sustainability function which includes the business’s strategy on climate change,” ensuring “any direct or indirect engagement activities in relation to policy are consistent with Grainger’s overall sustainability strategy, and business strategy.” At regular meetings of the Management Committee and Executive Committee, “participants in specific engagement activities (such as those who sit on British Property Federation Committees) feedback on the engagement activities and the outcomes,” and “Actions arising from engagement activities are discussed, allocated to a specific representative and disseminated to appropriate business divisions.” While these measures indicate strong governance, we found no evidence of a dedicated external audit or publicly available review of lobbying alignment, nor detailed criteria for assessing the policy positions of industry bodies with which Grainger engages.	3