BTS Group Holdings PCL – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	BTS Group Holdings PCL has instituted a comprehensive governance framework for climate-related lobbying, embedding oversight at the highest level and formalizing processes to align both its direct advocacy and its engagement through trade associations with the goals of the Paris Agreement. The Board of Directors “Approval of BTS Group climate strategy and positions on public policies relating to climate change to ensure alignment with the Paris Agreement” and “incorporate climate-related agendas and matters into corporate decision-making process” at least twice per year, indicating clear senior accountability for lobbying positions. A dedicated Sustainability Committee is tasked to “Monitor alignment between our climate position and climate policy positions of trade associations to which we belong” and to “Review and monitor the Company’s process to assess whether public policy engagement through trade associations aligns with the Paris Agreement,” ensuring indirect lobbying is systematically reviewed. The Sustainability Department acts as a coordination body to “Identify: impact, influences, and opportunities to engage with policy makers and trade associations,” “Monitor: review our climate position and alignment of climate policy positions for all activities and trade associations,” and “Report: disclose progress on the above actions to investors and other interested stakeholders,” which outlines a clear monitoring and reporting process. The company also affirms a public commitment to conduct engagement in line with Paris Agreement objectives. We found no evidence of a separately published audit or third-party review explicitly evaluating climate-lobbying alignment, which would further strengthen transparency. View Sources	B

Overall Assessment

Analysis

Score

Strong

BTS Group Holdings PCL has instituted a comprehensive governance framework for climate-related lobbying, embedding oversight at the highest level and formalizing processes to align both its direct advocacy and its engagement through trade associations with the goals of the Paris Agreement. The Board of Directors “Approval of BTS Group climate strategy and positions on public policies relating to climate change to ensure alignment with the Paris Agreement” and “incorporate climate-related agendas and matters into corporate decision-making process” at least twice per year, indicating clear senior accountability for lobbying positions. A dedicated Sustainability Committee is tasked to “Monitor alignment between our climate position and climate policy positions of trade associations to which we belong” and to “Review and monitor the Company’s process to assess whether public policy engagement through trade associations aligns with the Paris Agreement,” ensuring indirect lobbying is systematically reviewed. The Sustainability Department acts as a coordination body to “Identify: impact, influences, and opportunities to engage with policy makers and trade associations,” “Monitor: review our climate position and alignment of climate policy positions for all activities and trade associations,” and “Report: disclose progress on the above actions to investors and other interested stakeholders,” which outlines a clear monitoring and reporting process. The company also affirms a public commitment to conduct engagement in line with Paris Agreement objectives. We found no evidence of a separately published audit or third-party review explicitly evaluating climate-lobbying alignment, which would further strengthen transparency.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	BTS Group Holdings PCL provides only limited insight into its climate-policy lobbying. The company notes its role in establishing the Carbon Markets Club and its support for market-based instruments such as Thailand’s Voluntary Emission Reduction Programme (T-VER) and the Renewable Energy Certificate (REC) scheme, but it never identifies a specific piece of legislation or regulation it has tried to influence, nor does it confirm whether these are the only policies with which it engages. Likewise, although it refers generally to “engagement with stakeholders (investors, policy-makers, customers) on climate change” and mentions meetings with agencies such as the Office of Transport and Traffic Policy and Planning (OTP) and the Thailand Greenhouse Gas Management Organisation (TGO), it gives no detail on the lobbying channels used—such as letters, consultations, or direct meetings—or on the government bodies or officials that are the targets of any advocacy. Finally, the company states broad objectives such as promoting carbon-credit trading and achieving net-zero emissions by 2050, but it does not link these aspirations to concrete legislative changes or measurable policy outcomes it seeks. As a result, its disclosures reveal general climate ambitions but leave the substance, mechanisms, and targets of any lobbying largely unexplained.	D