Intermediate Capital Group PLC

Intermediate Capital Group PLC discloses a limited but defined process for keeping its policy-engagement activities in line with its climate strategy. It states that "new engagement initiatives through industry bodies or trade associations (such as Invest Europe or BVCA); are discussed and approved by the Executive Directors of ICG to ensure alignment to our climate change approach," and adds that "the ESG team, who develops and implements the climate change approach, is involved in such engagement initiatives to ensure alignment." This demonstrates a concrete mechanism for screening indirect lobbying via trade associations and identifies the Executive Directors and the ESG team as the parties responsible for sign-off and implementation. The company also makes "a public commitment ... to conduct your engagement activities in line with the goals of the Paris Agreement," indicating an explicit policy objective against which alignment is judged. However, we found no evidence of a systematic, published review of all trade-association positions, no disclosures on how the company governs its own direct lobbying activities, and no description of any board committee specifically overseeing lobbying or receiving regular lobbying-alignment reports; oversight references centre on broader ESG and investment processes rather than political advocacy. Therefore, while the company shows some governance by requiring executive approval and ESG team involvement for climate-related engagements, the disclosure lacks detail on monitoring, auditing, or corrective actions and does not cover direct lobbying, indicating only a moderate level of lobbying-governance transparency.