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Ferrexpo PLC’s disclosures focus extensively on climate change risk governance but do not reference any oversight or alignment of lobbying activities. For example, it notes that “climate change is a standing agenda item for all HSEC committee meetings and all Board meetings” and that “the HSEC Committee meets on a quarterly basis to discuss sustainability topics,” while the Board “delegated management of climate-related issues to the HSEC Committee,” which “reports the Group’s progress on climate change related matters, including progress against climate-related goals and targets” on a quarterly basis. However, we found no evidence of any policy, process, or named individual or committee responsible for overseeing, monitoring, or aligning the company’s direct or indirect lobbying activities with its climate-related objectives.
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E
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Ferrexpo provides virtually no transparency around climate-related lobbying. The disclosures mention policy areas such as the EU Emissions Trading System and the Carbon Border Adjustment Mechanism, noting that “Policy-making in the European Union is expected to take a leading role in global climate change regulation,” yet they never indicate that the company sought to influence these or any other measures. No information is given on lobbying tools or targets—there is only generic reference to engagement with bodies like the European Business Association and Ukrmetallurgprom, without clarifying whether these relationships involve advocacy toward governments. Similarly, the company states it has “carefully assessed [CBAM’s] impact to ensure our operations are fully prepared for a full-scale implementation,” but it does not spell out any policy changes it supports or opposes. Because the filings do not identify the policies lobbied, the mechanisms used, or the outcomes sought, they offer no meaningful insight into Ferrexpo’s climate lobbying activity.
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E
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