Serco Group PLC – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Serco Group PLC has instituted a formal governance framework to ensure its policy influencing is aligned with its climate change strategy but does not disclose any mechanism for managing indirect lobbying via trade associations or producing a dedicated audit of its lobbying alignment. The company explains that “Any policy influencing activity is peer reviewed by the HSE community and then reviewed by our Environmental Oversight Group and HSE Oversight Group, the Director, Business Compliance and Ethics, our HSE Director and Group Head of External Comms amongst other pertinent stakeholders,” and that if deemed appropriate “the Corporate Responsibility Committee will also be informed of any pertinent activities that influence policy.” Serco further notes that “We review Group strategy at least every 3 years to ensure it still remains consistent as there can be changes with regulatory, scientific, technical and political aspects,” and when asked about a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” the company responds simply “Yes.” However, we found no evidence of any process for reviewing or aligning its indirect lobbying through trade or industry associations, nor any public or third-party audit or report that evaluates the alignment of its lobbying activities with its climate goals. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Serco Group PLC has instituted a formal governance framework to ensure its policy influencing is aligned with its climate change strategy but does not disclose any mechanism for managing indirect lobbying via trade associations or producing a dedicated audit of its lobbying alignment. The company explains that “Any policy influencing activity is peer reviewed by the HSE community and then reviewed by our Environmental Oversight Group and HSE Oversight Group, the Director, Business Compliance and Ethics, our HSE Director and Group Head of External Comms amongst other pertinent stakeholders,” and that if deemed appropriate “the Corporate Responsibility Committee will also be informed of any pertinent activities that influence policy.” Serco further notes that “We review Group strategy at least every 3 years to ensure it still remains consistent as there can be changes with regulatory, scientific, technical and political aspects,” and when asked about a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” the company responds simply “Yes.” However, we found no evidence of any process for reviewing or aligning its indirect lobbying through trade or industry associations, nor any public or third-party audit or report that evaluates the alignment of its lobbying activities with its climate goals.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Serco Group PLC offers a moderate level of transparency on its climate-related lobbying. It identifies two distinct policy areas it has engaged on, naming both the "UK emissions trading scheme (ETS)" and the "UK Procurement Policy Note 06/21: Taking account of Carbon Reduction Plans," and providing basic contextual details such as the policy category, focus and geography. The company also explains how it seeks to influence these measures: it "provid[ed] comments via the Environmental Services Association" on the UK ETS and undertook a "review of our published 2022 carbon reduction plan with [the] policy lead and discussion on any future requirements should the policy be updated," thereby disclosing two concrete mechanisms and the governmental targets of those activities. On desired outcomes, the disclosure is more limited; the only explicit position reported is its "support with no exceptions" for Procurement Policy Note 06/21 and confirmation that this stance is Paris-aligned, while no goal or stance is described for its engagement on the UK ETS. Overall, the company explains what it lobbied on and how it did so, but provides fewer details on the specific policy changes it is seeking, resulting in a solid yet not fully comprehensive picture of its climate-policy lobbying.	C