DCC PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	DCC indicates that it has put basic controls in place to keep its policy engagement in line with its climate strategy, stating that “DCC businesses engagement and participation with trade associations is subject to the normal internal standards” and that it has “produced a set of guidance points for all DCC members of trade associations in relation to climate policy.” The company adds that “Any issues are reported through line management though the executive management teams,” providing a concrete, if limited, escalation mechanism to address potential mis-alignment in indirect lobbying. Oversight of these matters sits within the wider sustainability governance architecture: “The Board of DCC oversees sustainability matters, with support from the Governance and Sustainability Committee of the Board and governance at management level, notably our Executive Sustainability Committee,” while the Executive Sustainability Committee, chaired by the Chief Executive, is “responsible for coordinating sustainability matters at management level, monitoring sustainability performance and supporting reporting to the Governance and Sustainability Committee and the Board.” This shows that senior executives and the board receive regular sustainability reports that could encompass lobbying issues, but the disclosures do not explicitly confirm that lobbying alignment is reviewed, nor do they describe any formal process for assessing or acting on the positions of trade associations or the company’s own direct advocacy. There is also no publicly available lobbying-alignment audit or evidence that direct lobbying is governed in the same way as trade-association engagement. Overall, the company discloses a policy and an internal reporting pathway for trade-association lobbying and identifies senior committees that might oversee it, which indicates moderate but incomplete governance; however, the lack of detail on direct lobbying oversight, systematic reviews, or public reporting leaves several governance elements undisclosed. View Sources	C

Overall Assessment

Analysis

Score

Moderate

DCC indicates that it has put basic controls in place to keep its policy engagement in line with its climate strategy, stating that “DCC businesses engagement and participation with trade associations is subject to the normal internal standards” and that it has “produced a set of guidance points for all DCC members of trade associations in relation to climate policy.” The company adds that “Any issues are reported through line management though the executive management teams,” providing a concrete, if limited, escalation mechanism to address potential mis-alignment in indirect lobbying. Oversight of these matters sits within the wider sustainability governance architecture: “The Board of DCC oversees sustainability matters, with support from the Governance and Sustainability Committee of the Board and governance at management level, notably our Executive Sustainability Committee,” while the Executive Sustainability Committee, chaired by the Chief Executive, is “responsible for coordinating sustainability matters at management level, monitoring sustainability performance and supporting reporting to the Governance and Sustainability Committee and the Board.” This shows that senior executives and the board receive regular sustainability reports that could encompass lobbying issues, but the disclosures do not explicitly confirm that lobbying alignment is reviewed, nor do they describe any formal process for assessing or acting on the positions of trade associations or the company’s own direct advocacy. There is also no publicly available lobbying-alignment audit or evidence that direct lobbying is governed in the same way as trade-association engagement. Overall, the company discloses a policy and an internal reporting pathway for trade-association lobbying and identifies senior committees that might oversee it, which indicates moderate but incomplete governance; however, the lack of detail on direct lobbying oversight, systematic reviews, or public reporting leaves several governance elements undisclosed.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	DCC PLC offers only limited insight into its climate-related lobbying. It acknowledges that it "engage[s] with governments and regulators both directly and through business and trade associations" and refers to working through bodies such as UPEI, yet it does not name any specific climate laws, regulations or bill numbers it has tried to influence. The sole concrete reference – a submission to the UK Department for Business, Energy and Industrial Strategy on an audit reform White Paper – is not clearly climate-related, while climate references such as the "EU Green Deal Industrial Plan 2023" and the "US Inflation Reduction Act 2022" are mentioned only in passing without indicating any lobbying activity. The company identifies only one broad mechanism, indirect advocacy via trade associations, and provides scant targeting detail beyond noting that those associations lobby “EU institutions.” Finally, its objectives remain aspirational; phrases like "create pathway for rLPG and rDME in new sectors," commitment to a "Just Transition," and a desire to "reduce CO2e in LPG" do not translate into defined policy changes or measurable legislative outcomes. Taken together, the disclosures give a general sense that DCC participates in policy discussions but stop short of the specificity needed to understand what it lobbies for, how it does so, or what concrete results it seeks.	D