Migros Ticaret AS – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Migros Ticaret AS has implemented a structured process to align its policy engagement with its climate change strategy, starting with its “Environmental Policy and Commitments,” which “is shared with our employees via e-mail and circulars and with the public via our corporate website,” and reinforced by the “Orange Book” guide that “explains all our corporate policies and Migros Code of Ethics with transparency and in detail.” Mandatory online training ensures employees understand and adopt these policies, with those who fail exams required to retake them, and “only a select number of executives are authorized for official engagement with policymakers.” To maintain accountability, “if an employee of Migros is detected to be involved in an engagement activity that directly violates our climate change strategy, the detected inconsistency is reported to our Industrial Relations department,” and the individual “may be referred to the disciplinary committee” where they “may receive a penalty” including warnings or dismissal. This demonstrates structured oversight for direct lobbying activities but the company does not disclose any process for managing indirect lobbying through trade associations nor does it specify Board-level or senior executive governance of these practices. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Migros Ticaret AS has implemented a structured process to align its policy engagement with its climate change strategy, starting with its “Environmental Policy and Commitments,” which “is shared with our employees via e-mail and circulars and with the public via our corporate website,” and reinforced by the “Orange Book” guide that “explains all our corporate policies and Migros Code of Ethics with transparency and in detail.” Mandatory online training ensures employees understand and adopt these policies, with those who fail exams required to retake them, and “only a select number of executives are authorized for official engagement with policymakers.” To maintain accountability, “if an employee of Migros is detected to be involved in an engagement activity that directly violates our climate change strategy, the detected inconsistency is reported to our Industrial Relations department,” and the individual “may be referred to the disciplinary committee” where they “may receive a penalty” including warnings or dismissal. This demonstrates structured oversight for direct lobbying activities but the company does not disclose any process for managing indirect lobbying through trade associations nor does it specify Board-level or senior executive governance of these practices.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Migros Ticaret AS provides only limited insight into its climate-policy lobbying. It states that it undertakes “climate-related engagement activities with policymakers in accordance with the Paris Agreement,” but it does not identify any specific laws, regulations or jurisdictions it has tried to influence, nor does it explain why no such detail is given. The company refers to generic engagement with policymakers and to reporting its climate work through CDP, yet it does not clarify how these interactions are carried out or which government bodies or officials are approached. In terms of objectives, Migros highlights its own commitment to reach net-zero emissions by 2050 and to align with the Paris Agreement, but it does not spell out the concrete policy changes it seeks to advance through its lobbying. Overall, the disclosure acknowledges that some engagement takes place and affirms it is not used to oppose climate regulation, yet it lacks the specificity needed to demonstrate strong transparency on the policies, mechanisms, and outcomes involved.	D