Liontrust Asset Management PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Liontrust discloses a formal structure for overseeing its policy engagement activities, noting that “Rebecca Shelley is the named Non-Executive Director for Responsible Capitalism” and that “The Head of Responsible Capitalism reports to the Chief Executive and to the Board,” which indicates clear lines of accountability. The company confirms that political or governmental outreach is governed by a written policy, stating that “Liontrust’s political engagements are aligned with its commitments to the PRI” and that “The RC team oversees this policy … [which] is reviewed and updated, as needed, on an annual basis,” demonstrating a recurring review mechanism. This oversight body therefore has responsibility for ensuring that any external engagement, including political contacts, remains consistent with its responsible-investment stance. However, while the disclosure shows a process for approving “any policies, proposals, reports or activities prepared or carried out by the RC team that impact the wider Group,” we found no evidence of a stand-alone climate-lobbying audit, no description of how the firm tests the alignment of trade-association positions with its own climate objectives, and no detail on corrective actions should misalignment occur. The governance therefore covers policy engagement in general and names accountable parties but does not extend to a systematic review of indirect lobbying or a publicly reported assessment of climate-lobbying alignment, limiting the strength of the framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Liontrust discloses a formal structure for overseeing its policy engagement activities, noting that “Rebecca Shelley is the named Non-Executive Director for Responsible Capitalism” and that “The Head of Responsible Capitalism reports to the Chief Executive and to the Board,” which indicates clear lines of accountability. The company confirms that political or governmental outreach is governed by a written policy, stating that “Liontrust’s political engagements are aligned with its commitments to the PRI” and that “The RC team oversees this policy … [which] is reviewed and updated, as needed, on an annual basis,” demonstrating a recurring review mechanism. This oversight body therefore has responsibility for ensuring that any external engagement, including political contacts, remains consistent with its responsible-investment stance. However, while the disclosure shows a process for approving “any policies, proposals, reports or activities prepared or carried out by the RC team that impact the wider Group,” we found no evidence of a stand-alone climate-lobbying audit, no description of how the firm tests the alignment of trade-association positions with its own climate objectives, and no detail on corrective actions should misalignment occur. The governance therefore covers policy engagement in general and names accountable parties but does not extend to a systematic review of indirect lobbying or a publicly reported assessment of climate-lobbying alignment, limiting the strength of the framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Liontrust Asset Management PLC offers only limited insight into its climate-policy lobbying. It names broad policy frameworks such as the US Inflation Reduction Act and the EU “Fit for 55” package, but the disclosures do not explain how, or even whether, the firm attempted to shape those measures, focusing instead on engagement with investee companies. The company does describe the tools it uses—meetings, emails, calls and letters—and cites dialogues with 93 firms, including detailed discussions with 11 companies and three banks on financing the transition, yet none of these interactions are directed at identifiable government bodies or regulators. The outcomes it seeks are expressed in broad terms—encouraging portfolio companies to adopt Paris-aligned, science-based decarbonisation targets and pressing banks to support the energy transition—without specifying what legislative or regulatory changes it wants to see. Taken together, the disclosures show some willingness to discuss approach and objectives but provide little concrete detail on policy engagement, target audiences or desired rule changes, resulting in a limited level of transparency on climate lobbying.	D