Direct Line Insurance Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Direct Line Insurance Group discloses a basic structure for overseeing how its policy engagement aligns with climate goals, stating that "DLG's Climate Executive Steering Group reports to the Sustainability Committee who provide oversight of progress made in the Group's sustainability strategy" and confirming that it has "a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." This shows an internal chain of responsibility and a formal committee charged with monitoring alignment, which indicates that climate-related lobbying is at least partially governed. The company also emphasises that "all of our sustainability activity aligns with the Business Ambition for 1.5°C pledge," signalling an intention that lobbying or wider engagement be consistent with Paris-aligned targets. However, the disclosure does not describe any concrete mechanisms for assessing or correcting the positions taken through direct lobbying or through trade associations, nor does it provide detail on how the Sustainability Committee evaluates alignment beyond general oversight of the sustainability strategy. We found no evidence of regular lobbying reviews, association audits, escalation procedures, or the publication of a lobbying-alignment report. Consequently, while the presence of a named oversight body and a stated commitment to Paris alignment suggest moderate governance, the lack of detailed monitoring processes and coverage of indirect lobbying limits the strength of the framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Direct Line Insurance Group discloses a basic structure for overseeing how its policy engagement aligns with climate goals, stating that "DLG's Climate Executive Steering Group reports to the Sustainability Committee who provide oversight of progress made in the Group's sustainability strategy" and confirming that it has "a public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement." This shows an internal chain of responsibility and a formal committee charged with monitoring alignment, which indicates that climate-related lobbying is at least partially governed. The company also emphasises that "all of our sustainability activity aligns with the Business Ambition for 1.5°C pledge," signalling an intention that lobbying or wider engagement be consistent with Paris-aligned targets. However, the disclosure does not describe any concrete mechanisms for assessing or correcting the positions taken through direct lobbying or through trade associations, nor does it provide detail on how the Sustainability Committee evaluates alignment beyond general oversight of the sustainability strategy. We found no evidence of regular lobbying reviews, association audits, escalation procedures, or the publication of a lobbying-alignment report. Consequently, while the presence of a named oversight body and a stated commitment to Paris alignment suggest moderate governance, the lack of detailed monitoring processes and coverage of indirect lobbying limits the strength of the framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Direct Line Insurance Group PLC provides partial but uneven insight into its climate-related lobbying. It identifies broad subject areas it works on – flood-resilience measures, resilient property repairs and, more specifically, efforts to “accelerate the UK’s transition to electric vehicles” – yet it stops short of naming the exact statutes, consultations or regulatory proposals it has sought to influence, so the actual policies remain largely generic. The company gives limited information on how it lobbies: it notes participation in the Electric Vehicle Fleet Accelerator coalition and says its Chief Executive has “directly engaged with policy makers,” but does not spell out whether this takes the form of meetings, submissions or correspondence, nor does it identify the particular government departments or legislators approached. Where the company is most specific is in the outcomes it is pursuing through the EVFA, aiming for “a commitment from members to convert fleets to electric by 2030,” “building wider confidence in the use of electric vehicles,” and “encouraging the expansion of the national charging network and upgrade of the electricity grid,” all of which point to clear policy objectives. Taken together, these disclosures show moderate transparency: the desired policy outcomes are well articulated, but the underlying policy instruments and the detailed methods and targets of lobbying are only lightly sketched.	C