Rolls-Royce Holdings PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Rolls-Royce Holdings PLC provides a highly detailed picture of its climate-policy lobbying. It names a broad slate of specific initiatives it has worked on, including the “EU Fit for 55 package”, the “EU SAF blending mandate”, the “EASA Environmental Labelling Programme”, the European Union’s “Clean Aviation Joint Undertaking”, its support for the ICAO long-term net-zero goal, and the UK-focused Hydrogen in Aviation alliance linked to the Jet Zero Strategy, demonstrating clear disclosure of the exact policies and legislative frameworks it seeks to influence. The company is equally explicit about how it lobbies and whom it targets: it reports “direct conversations with policy-makers from all EU Institutions (in person and written)”, “participation in stakeholder roundtables” and “official EU consultations”, “1-2-1 engagements with government ministers representing climate, transport, energy and environment”, representation on the Clean Aviation Governing Board, and work through the HIA alliance that will act “constructively with Government, local authorities, and the aviation and hydrogen sectors”. These statements identify both the mechanisms (meetings, written submissions, board membership, public-private partnerships) and the target bodies (European Commission, EU Institutions, UK Government and local authorities). Finally, Rolls-Royce spells out the policy outcomes it is pursuing: it supports “proposals on SAF mandates for aviation, consensus on emissions reduction pathways for maritime, more ambitious clean energy targets, and a more ambitious ETS, including the provision of maritime emissions for the first time”; it pushes for “a long-term net zero carbon goal for the aviation sector”, for “increasing SAF usage across the aviation industry”, and for the UK to focus on “supporting the delivery of the infrastructure needed for the UK to be a global leader” in hydrogen-powered flight. By clearly linking each engagement to a concrete objective and stating the reasons for its positions, the company demonstrates a comprehensive level of transparency across all aspects of its climate lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Rolls-Royce discloses several elements of a governance process to keep its climate-related lobbying in line with its net-zero strategy, but the disclosure stops short of providing full detail on oversight or on how direct lobbying is monitored in practice. The company states that we have a well established framework for our climate-related policy engagement, which includes a public position on the global policy principles we advocate for and explains that for each trade association or industry body engagement we look to align these principles with those that we work with, adding that if alignment cannot be achieved we will ultimately look to cease relationships with that entity. It also confirms that during 2022, we completed a review of the associations we are members of to better understand their positions with regards to climate change, and will continue to engage with them to help shape their thinking and approach to ensure it remains consistent with our own, showing an active mechanism for managing indirect lobbying. Board-level responsibility is indicated, as delivery of our sustainability approach, including execution of policies and progress against our priorities and targets, is overseen by the Safety, Ethics & Sustainability Committee at Board level, and the environment & sustainability committee at management level; however the company does not explicitly state that these bodies sign off or audit lobbying activities themselves. While the narrative references direct engagement, such as engaging our government partners in our core geographies in support of the policy principles set out above, the process for monitoring those interactions is not described, and there is no published lobbying-alignment report. Consequently, the disclosure demonstrates a defined policy framework and an active review of trade-association positions, but lacks detailed information on direct-lobbying controls and on how the named committees formally review or approve lobbying alignment, indicating a moderate level of governance.	2