Eli Lilly & Co – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Eli Lilly discloses multiple internal structures that monitor how its public-policy engagement relates to environmental goals, indicating a moderate level of governance over climate-related lobbying. The board states that it "exercises governance oversight of our political expenditures and lobbying activities," while the Directors and Corporate Governance Committee is charged with "identifying current and emerging environmental, social, political, and governance trends and public policy issues" and the board "receives semi-annual updates on political engagement, including trade association memberships," showing a clear oversight mechanism and regular reporting cadence. At the management level, the company describes a formal Legislative and Regulatory Tracking Committee that "includes representatives from our global health, safety, and environment (HSE) team; Legal; and Corporate Affairs" and "oversees environmental advocacy efforts with legislative and regulatory bodies and coordinates Lilly's activities among various trade groups involved in environmental advocacy," meeting "at least semi-annually" and convening additional sessions for emerging issues. Complementing this, an "EU HSE Regulatory Tracking Group" monitors new rules in Europe, and regional HSE representatives "work closely with our Director of Corporate Health, Safety and Environment to ensure consistency," illustrating processes that cover both direct lobbying and engagement through associations. The company also confirms a public pledge to conduct engagement "in line with the goals of the Paris Agreement." It has disclosed to CDP that its climate lobbying positions are aligned with four trade associations: INDIEC (Indiana Industrial Energy Consumers, Inc.), European Federation of Pharmaceutical Industries and Associations, American Chemistry Council and EuropaBio. It detailed that "we did not attempt to influence their position" [...] as "our position is consistent". However, despite these disclosures, it does not explain the criteria for assessing or remedying misaligned trade-association positions, leaving the depth of its alignment actions unclear. Nor has Lilly published review or audit of climate-lobbying alignment. Consequently, while the presence of board-level oversight and dedicated tracking committees indicates strong procedural foundations, the absence of publicly described alignment tests or corrective actions limits the evidence of a fully robust climate-lobbying governance framework. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Eli Lilly discloses multiple internal structures that monitor how its public-policy engagement relates to environmental goals, indicating a moderate level of governance over climate-related lobbying. The board states that it "exercises governance oversight of our political expenditures and lobbying activities," while the Directors and Corporate Governance Committee is charged with "identifying current and emerging environmental, social, political, and governance trends and public policy issues" and the board "receives semi-annual updates on political engagement, including trade association memberships," showing a clear oversight mechanism and regular reporting cadence. At the management level, the company describes a formal Legislative and Regulatory Tracking Committee that "includes representatives from our global health, safety, and environment (HSE) team; Legal; and Corporate Affairs" and "oversees environmental advocacy efforts with legislative and regulatory bodies and coordinates Lilly's activities among various trade groups involved in environmental advocacy," meeting "at least semi-annually" and convening additional sessions for emerging issues. Complementing this, an "EU HSE Regulatory Tracking Group" monitors new rules in Europe, and regional HSE representatives "work closely with our Director of Corporate Health, Safety and Environment to ensure consistency," illustrating processes that cover both direct lobbying and engagement through associations. The company also confirms a public pledge to conduct engagement "in line with the goals of the Paris Agreement." It has disclosed to CDP that its climate lobbying positions are aligned with four trade associations: INDIEC (Indiana Industrial Energy Consumers, Inc.), European Federation of Pharmaceutical Industries and Associations, American Chemistry Council and EuropaBio. It detailed that "we did not attempt to influence their position" [...] as "our position is consistent". However, despite these disclosures, it does not explain the criteria for assessing or remedying misaligned trade-association positions, leaving the depth of its alignment actions unclear. Nor has Lilly published review or audit of climate-lobbying alignment. Consequently, while the presence of board-level oversight and dedicated tracking committees indicates strong procedural foundations, the absence of publicly described alignment tests or corrective actions limits the evidence of a fully robust climate-lobbying governance framework.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Eli Lilly discloses a reasonable amount of detail on its climate-related public-policy engagement. It identifies two specific pieces of European legislation that it seeks to influence—the Corporate Sustainability Reporting Directive and the EU Emissions Trading System—and places them in the broader categories of climate-related reporting standards and carbon-pricing policy, respectively. The company also explains how it engages, noting both direct contact with EU institutions and indirect involvement through the industry association EFPIA, including participation in formal consultations, thereby naming the mechanisms and the policymaking targets for its lobbying. However, when describing what it hopes to achieve, the company limits itself to broad aims such as aligning new rules with the European Commission’s Green Goals and ensuring any framework is “risk-based, agile and proportionate,” without setting out specific amendments, numerical targets or other concrete outcomes. This leaves its policy positions only partially articulated, providing moderate overall transparency.	C